China contains manufacturers with very different products, sites, licenses, quality histories and international experience. “A Chinese pharmaceutical manufacturer” is therefore not a due-diligence conclusion. The relevant question is whether a named legal entity and named site can support a defined product, target market and responsibility model.
1. Verify the legal entity and manufacturing site
- Chinese and English legal names, unified social credit code and ownership structure;
- manufacturing-site address, production authorization and current scope;
- which entity will sign the commercial, quality, technology and confidentiality agreements;
- whether testing, storage, packaging or other work will be subcontracted;
- which entity controls the relevant people, equipment, records and bank/payment relationship.
Use official NMPA or government public-query channels where available, and reconcile translated names carefully. Similar English company names can refer to different legal entities or sites. [7]
2. Confirm the product-to-license and product-to-site fit
Check the precise dosage form, sterile/non-sterile route, production address and activities. Then conduct a product-level fit assessment covering formulation, container-closure system, batch scale, equipment train, material constraints, analytical package, process maturity and target-market requirements. A licensed dosage form does not automatically make every product in that form feasible.
3. Map the China responsibility structure
China's Drug Administration Law establishes the marketing authorization holder system and requires an authorization holder using contract manufacture to entrust a qualified manufacturer, sign agreements and supervise the contracted quality system. [1] The current NMPA announcement adds detailed requirements for contract-manufacturing supervision, technology transfer and quality responsibilities, with specific considerations for sterile drugs. [2]
For an overseas sponsor, these China-side roles must be mapped to the target-market applicant, authorization holder, importer, testing and release responsibilities. Do not assume that a China manufacturing agreement by itself satisfies the destination market.
4. Verify the target-market regulatory pathway
- Who owns or will own the dossier and product-specific data?
- Which site information, validation, stability and inspection evidence will be required?
- Does adding or changing the China site require a prior approval, variation or notification?
- Who answers authority questions and provides inspection support?
- How will post-approval changes be assessed and synchronized across markets?
Regulatory “support” should be translated into named deliverables, owners and acceptance criteria.
5. Review quality-system evidence
Assess recent deviations, OOS/OOT, CAPA, change control, data integrity, complaints, recalls, supplier management, validation, training, stability, product-quality review and management oversight. EU GMP Chapter 7 and FDA's quality-agreement guidance both emphasize defined control and responsibilities for outsourced manufacture. [4] [5]
6. Put inspection history in context
Check the authority, site, date, scope, classification or outcome, observations, company response and current status. Distinguish “inspected,” “inspection closed,” “approved application” and “certified”—they are not interchangeable. Use official data sources such as FDA's inspection and compliance resources when relevant, and avoid describing an inspection letter as a facility endorsement unless the authority explicitly says so. [6]
7. Evaluate technology-transfer readiness
WHO expects a planned transfer with a sending unit, receiving unit, gap analysis, quality-risk management, trained personnel, documented responsibilities and evidence that the receiving unit can reproduce the transferred product, process or analytical procedure. [3] Review the document package, product knowledge, methods, equipment differences, scale-up assumptions, materials, validation, stability and acceptance criteria before setting commercial dates.
8. Assess supply-chain and continuity risk
- active ingredient, excipient and primary-packaging sources;
- import/export permits, customs, cold chain or controlled-material requirements;
- forecast, campaign scale, lead time, testing and release duration;
- safety stock, spare capacity, backup utilities and disaster recovery;
- currency, payment, tax, insurance, logistics and inventory ownership;
- shortage notification, alternate-source strategy and exit transfer.
9. Protect intellectual property and data by design
Before confidential review, agree permitted use, access, storage location, onward disclosure, return/destruction and breach handling. In the data room, use an index, named reviewers, access logs and document-level questions. The manufacturing and quality agreements should later define ownership of improvements, methods, validation data, regulatory work product and continuing access after termination.
10. Use four diligence stages
Verify legal entity, site, public license/registration information, public inspection context and credible third-party records.
Review a focused technical, quality, regulatory and supply package with a documented gap log.
Test actual operations, source records, data trails, facilities, laboratories, people and project governance.
Reconcile the commercial, quality, technical, IP, regulatory, continuity and exit responsibilities before commitment.
11. Ask for evidence, not superlatives
| Claim | Evidence to request |
|---|---|
| “We can manufacture this dosage form” | Current site scope, proposed equipment train, similar-product rationale and product-specific gap assessment. |
| “We have international experience” | Authority, site, date and scope of inspections or filings; anonymized project processes where disclosure is permitted. |
| “We support registration” | Country, deliverables, data ownership, response process and named responsible functions. |
| “We have strong quality” | Recent operational examples, metrics, investigations, CAPA effectiveness and management review evidence. |
| “We can meet the launch date” | Critical path, assumptions, resource plan, materials, validation, filing dependencies and decision gates. |
Frequently asked questions
Is an NMPA manufacturing authorization enough for export supply?
No. It verifies a China-side authorization context; the target market's filing, inspection, import, testing and release requirements must also be satisfied.
Can a public database replace a site audit?
No. Public sources verify identity and context. Operational and product-specific evidence still requires structured diligence.
How should translated company names be handled?
Record the exact Chinese legal name and identifier alongside the chosen English translation in every agreement and verification log.
When should pricing be finalized?
After enough technical, regulatory, quality and supply assumptions are defined to prevent the price from hiding scope gaps.
What is the most important exit clause?
There is no single clause. Ensure continuing access to required records, investigation support, inventory disposition, data/IP rights and orderly transfer assistance.
Authoritative sources
- NMPA — Drug Administration Law of the People's Republic of China
- NMPA — Announcement on Strengthening Supervision and Administration of Contract Manufacturing of Drugs (No. 134, 2025)
- WHO TRS 1044, Annex 4 — Technology transfer in pharmaceutical manufacturing
- European Commission — EU GMP Chapter 7: Outsourced Activities
- U.S. FDA — Contract Manufacturing Arrangements for Drugs: Quality Agreements
- U.S. FDA — Pharmaceutical Inspections and Compliance
- NMPA — Government Services and Public Query Portal
This article is an industry perspective for general business discussion. It is not legal, regulatory or medical advice. Project requirements must be confirmed with the responsible parties and applicable authorities.