EMA Updates the Union List of Critical Medicines (ULCM)

The European Medicines Agency (EMA), together with the Heads of Medicines Agencies (HMA) and the European Commission, has published an updated Union List of Critical Medicines (ULCM), effective 12 December 2025.

The European Medicines Agency (EMA), together with the Heads of Medicines Agencies (HMA) and the European Commission, has published an updated Union List of Critical Medicines (ULCM), effective 12 December 2025.
December 16, 2025

The ULCM identifies medicines for human use whose continued supply is considered a priority for the European Union, as any disruption could have a serious impact on healthcare systems. This update represents the first annual revision of the list and includes the addition and adjustment of several active substances, as well as the inclusion of new ATC codes recognised as critical.

Alongside the revised list, the EMA has updated the associated Q&A document to provide further guidance and support to stakeholders. Medicines included in the ULCM are prioritised for EU-wide actions aimed at strengthening supply chains and minimising the risk of shortages or disruptions.

Marketing Authorisation Holders (MAHs) and National Competent Authorities (NCAs) are strongly encouraged to review the updated list to determine whether their products are affected and to assess any applicable reporting or preparedness requirements.

MAHs should note that medicinal products included in the ULCM are subject to stricter EMA deadlines, particularly regarding the submission of:

  • Manufacturer information
  • Marketing and Business Organisation (MBO) data
  • Structured pack size data

Ensuring timely compliance with these obligations is essential to support supply continuity and regulatory preparedness across the EU.

How Asphalion Can Support MAHs

Asphalion provides specialized RegOps and data management services to help pharmaceutical and biotech companies comply with EU regulatory requirements, including those related to the Union List of Critical Medicines (ULCM). Our support can include:

  • Data collection and validation for regulatory reporting, ensuring accurate submission of manufacturer, MBO, and pack size information
  • Preparation and submission of structured data in compliance with EMA requirements
  • Ongoing maintenance and updates of regulatory databases to reflect portfolio changes or updated obligations
  • Support for regulatory reporting timelines, helping MAHs meet the stricter deadlines associated with ULCM products

By leveraging Asphalion’s RegOps expertise, companies can streamline their data management processes, reduce regulatory risk, and maintain compliance with EU reporting obligations related to critical medicines.

Contact us: [email protected]

For further details, the updated Union List of Critical Medicines and related guidance are available on the EMA website:
EMA – Union List of Critical Medicines

Search News & Events

  • Filter by category

Share

Related news and events

NEWS | EMA PMS API Beta Release

As announced by the European Medicines Agency (EMA) during the PMS Info Day held on Tuesday, the PMS API Beta Release will be published today,

EVENT | EMA PMS INFO DAY

Today, ASPHALION expert Sonia Tejeda is participating in the Product Management Service (PMS) Information Day at the European Medicines Agency premises in Amsterdam, an important

EVENTS | Asphalion present at Key events this year

At Asphalion, we’re excited to be part of key events, conferences, and summits throughout 2026—great opportunities to connect, exchange insights, and collaborate with leaders across healthcare and medical devices. 

For further information

If you are interested in our services, or wish to get in touch for a general enquiry, please contact us for more information.

Fill the form and we will contact you as soon as possible.

You can also follow us on:

Schedule a Free Meeting

Schedule here a free 30-minutes meeting with one of our consultants and tell us about your project, challenges or doubts. 

We will be happy to assist you!

Schedule a meeting