PLANREFERENCE OUTLINE

Real-Time Release Testing Strategy Plan

Plan for replacing an end-product test with real-time release testing: the attribute and the evidence that in-process measurements predict it, the control strategy and diversion criteria, the quality-system elements Annex 17 requires, the release rules once approved, and the record of regulatory interaction.

What a template is not

A template is a document baseline to adapt inside your own quality system. SPEQ does not approve, validate, or take responsibility for what you issue from it, and using one is not evidence of compliance.

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HOW TO FILL THIS IN
How to Implement Real-Time Release Testing, step by step →
REGULATIONS MAPPED
EU GMP Annex 17ICH Q13
DOCUMENT TYPE
Plan
LAST UPDATED
October 2026
PURPOSE

The plan behind an application to replace an end-product test with real-time release testing. EU GMP Annex 17 sets minimum criteria — real-time measurements that accurately predict the finished-product attribute, scientific evidence for the combination of attributes and controls, and a robust basis for release — and lists the quality-system elements the strategy must sit within. This plan records each one.

What's Inside

✓The attribute to be replaced and the evidence that in-process measurements predict it
✓Control strategy: parameters, measurements, acceptance criteria and sampling
✓Diversion criteria for continuous processes
✓The Annex 17 quality-system elements with procedure references and owners
✓Release rules once RTRT is approved, including certificate-of-analysis wording
✓Record of regulatory interaction and the authorisation reference

How to Use It

1Start with one attribute and build the predictive evidence before designing controls.
2Define the control strategy and, for continuous processes, the diversion criteria.
3Reference an existing procedure for each quality-system element, or write one.
4Record regulatory interaction before and during assessment.
5After approval, apply the release rules exactly — including no fallback to end-product testing on failure.
6Train the cross-functional team before RTRT goes live, and schedule the periodic review of the plan’s effectiveness that the quality-system elements require, with change control for any model or sensor update.
DOCUMENT CONTENTS

The full section structure of this template — every section and sub-section, so you can use it as a baseline for your own site document.

—Document Control
› Document Information› Approval Signatures› Revision History› Distribution List
1Attribute and Prediction
2Control Strategy
3Quality System Elements
4Release Rules
5Regulatory Interaction
AAppendix A — Approval
REGULATORY CONTEXT

EU GMP Annex 17 (Revision 1, in operation 26 December 2018) defines RTRT, its minimum criteria (3.2), the quality-system elements (3.3), the requirement to use RTRT routinely once approved and not to substitute end-product testing on failure (3.10), and the certificate-of-analysis wording (3.11). ICH Q13 (2022) describes diversion criteria for continuous manufacturing (3.1.6). RTRT is used only where authorised; the plan structure is SPEQ practitioner synthesis.

MAPPED STANDARDS
EU GMP Annex 17ICH Q13
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