1Three questions, three kinds of evidence.
Each activity answers a different question about the same procedure, and each has its own source text.
| Activity | Question it answers | Typical evidence | Where it is set out |
|---|---|---|---|
| Validation | Is the procedure fit for its intended purpose? | A protocol, studies of each applicable performance characteristic and a report | 21 CFR 211.165(e), EU GMP 6.15, ICH Q2(R2) |
| Verification | Does an established procedure work here, on this material? | A verification protocol testing the characteristics at risk | 21 CFR 211.194(a)(2), EU GMP 6.15, FDA 2015 guidance section VI.C |
| Transfer | Can the receiving laboratory run the validated procedure? | A transfer protocol, comparative results and a report | EU GMP 6.37 to 6.41, ICH Q2(R2) section 2.2, ICH Q14 chapter 7 |
| Revalidation | Does the procedure still perform after a change? | Studies of the characteristics the change affects | ICH Q2(R2) section 2.2, FDA 2015 guidance section VIII.A |
2What validation requires.
US law requires that “the accuracy, sensitivity, specificity, and reproducibility of test methods employed by the firm shall be established and documented”.¹ Each laboratory record states the method used and where the data that establish it “meet proper standards of accuracy and reliability as applied to the product tested” can be found.² FDA defines analytical method validation as “the process of demonstrating that an analytical procedure is suitable for its intended purpose”. It expects validation data to be generated under a protocol approved by the sponsor, with predetermined and justified acceptance criteria, using qualified instrumentation.³
ICH Q2(R2) sets out which performance characteristics to study for each use and how: specificity, range, accuracy and precision, with robustness normally evaluated during development. A validation protocol comes before the study and a validation report after it.⁴ In the EU, Chapter 6 of the GMP guide states the principle in one line: “Testing methods should be validated.”⁵
3What verification requires.
Verification applies to a procedure someone else validated. Under 21 CFR 211.194(a)(2), a method in the current USP, National Formulary, AOAC Book of Methods or another recognised reference, or detailed in an approved new drug application and not modified, can be referenced by a statement of the method and its source. Even then, “The suitability of all testing methods used shall be verified under actual conditions of use.”²
FDA’s 2015 guidance says compendial methods “are verified rather than validated”. The verification protocol should include the compendial method with predetermined acceptance criteria and details such as reagents, equipment, chromatographic conditions, system suitability, sample preparation and stability. The extent of verification decides which characteristics are tested, for example specificity, detection and quantitation limits, precision or accuracy. Tighter specifications than the compendium, or a different synthetic route, process or matrix, can change what needs testing.³
The EU text is broader than compendial methods: “A laboratory that is using a testing method and which did not perform the original validation, should verify the appropriateness of the testing method.”⁵ A receiving laboratory that did not perform the original validation falls within that sentence too.
4What transfer requires.
EU GMP Chapter 6, in operation since 1 October 2014, has a section on technical transfer of testing methods.⁵
- Before transfer, the transferring site verifies that the methods match the marketing authorisation, reviews the original validation against current ICH requirements, and documents a gap analysis to identify supplementary validation.
- A detailed protocol describes the transfer. It identifies the testing and methods, additional training, the standards and samples to be tested, special transport and storage conditions, and acceptance criteria based on the current validation study.
- Deviations from the protocol are investigated before the transfer closes.
- The transfer report documents the comparative outcome and identifies areas that need further revalidation.
FDA treats transfer as a kind of analytical method comparability study. The originating and receiving laboratories run a preapproved protocol on the same lots, and the comparison evaluates accuracy and precision, especially interlaboratory variability. For a stability-
ICH Q2(R2) and Q14 put transfer inside lifecycle change management. Transfer to another laboratory calls for partial or full revalidation, comparative analysis of representative samples, or both, or a justification for not doing more transfer experiments.⁴⁶ Co-validation, where several sites generate the validation data together, can also satisfy transfer at the participating sites.⁴
5Where the activities meet.
ICH Q14’s examples treat a transfer with no change to the procedure separately from a change to it. If the procedure changes within the same principle, the examples call for partial or full revalidation of the characteristics the change affects; if the principle itself changes, full validation of the new procedure.⁶ In the US, any modification of an established method must be recorded with its reason and data showing results “at least as accurate and reliable” as the original.² FDA also recommends keeping enough retention samples, including marketed product and, where possible, pivotal clinical trial material, to support these comparative studies.³
6How it runs in Seal.
In Seal’s analytical method lifecycle, validation, verification and transfer remain distinct assessments, and each laboratory’s readiness is assessed on its own evidence rather than inferred from the newest procedure version. A sending-lab study supports review without marking the method transferred, and the transfer package records the strategy, receiving-lab equipment, materials and trained analysts, local execution and discrepancies.
Neil, Seal’s AI agent, can prepare an analytical method transfer review: it compares sending- and receiving-
References
- 121 CFR 211.165, Testing and release for distribution, eCFR. https:/
/ www. ecfr. gov/ current/ title- 21/ section- 211. 165 (read 6 November 2026) - 221 CFR 211.194, Laboratory records, eCFR. https:/
/ www. ecfr. gov/ current/ title- 21/ section- 211. 194 (read 6 November 2026) - 3Analytical Procedures and Methods Validation for Drugs and Biologics, Guidance for Industry, FDA, July 2015. https:/
/ www. fda. gov/ media/ 87801/ download (read 6 November 2026) - 4ICH Q2(R2) Validation of Analytical Procedures, ICH, adopted 1 November 2023, error corrections 30 November 2023 and 4 April 2025. https:/
/ database. ich. org/ sites/ default/ files/ ICH_ Q2%28R2%29_ Guideline_ 2023_ 1130_ ErrorCorrection_ 2025. pdf (read 6 November 2026) - 5EudraLex Volume 4, Part I, Chapter 6: Quality Control, European Commission, in operation since 1 October 2014. https:/
/ health. ec. europa. eu/ document/ download/ c74c8720- 27bf- 4252- 808f- d65a206a90bb_ en?filename=2014- 11_ vol4_ chapter_ 6. pdf (read 6 November 2026) - 6ICH Q14 Analytical Procedure Development, ICH, adopted 1 November 2023. https:/
/ database. ich. org/ sites/ default/ files/ ICH_ Q14_ Guideline_ 2023_ 1116. pdf (read 6 November 2026)
AQuestions and answers
Do compendial methods need to be validated?
Not in full. A USP or other recognised method used without modification is verified rather than validated: you show it works for your product under actual conditions of use. The characteristics you test depend on how far your product, matrix or specification differs from what the monograph assumed.
Can a method transfer be waived?
Yes, with a justification. ICH Q2(R2) and Q14 both allow a justification for not performing additional transfer experiments in place of comparative testing or revalidation. The reasoning should be documented like any other transfer decision.
What is co-validation?
Co-validation uses data generated at several sites to show the procedure meets its predefined performance criteria. Under ICH Q2(R2) it can also satisfy the requirements of analytical procedure transfer at the participating sites.
What goes in a method transfer protocol?
Under EU GMP, the testing and methods being transferred, any additional training, the standards and samples to be tested, special transport and storage conditions, and acceptance criteria based on the current validation study. FDA adds that both laboratories should test the same representative lots against predetermined criteria.
When does a method need revalidation?
When a change could affect its performance, such as new equipment or reagents, a different manufacturing process or formulation, or a revised procedure. The extent of revalidation depends on which performance characteristics the change affects.
