Representation

Regulatory Representation
Across the US, UK and EU

Regulatory engagement with the FDA, MHRA and EMA requires an authorised presence in each jurisdiction before a single submission is made. PrimeRA holds designated representation across all three markets, acting as your named point of contact with each agency under a fixed monthly retainer.

When Representation is Required

A legal prerequisite, not an administrative step

Representation is a statutory requirement that must be in place before formal regulatory submissions are made and clinical or commercial activities begin. For formal filings such as CTAs, INDs and MAAs, the FDA, EMA and MHRA each require a designated, in-jurisdiction representative. Certain pre-submission interactions - including scientific advice and specific early access or designation routes - may proceed without a representative in place, but the requirement applies to all substantive submissions. It applies regardless of programme stage or company size.

For early-stage ATMP developers, academic spinouts and international companies entering the EU, UK or US market for the first time, establishing that presence is among the first and most important steps in any regulatory programme. PrimeRA provides that presence through a team with direct experience of the agency landscape you are navigating.

FDA · United States
Representation required when:
Submitting an IND, NDA or BLA as a foreign sponsor
Requesting a pre-submission or Type A, B, C or D meeting
Engaging the FDA for Orphan Drug Designation, Fast Track, Breakthrough Therapy, RMAT or RPDD (Rare Pediatric Disease Designation) applications
Conducting clinical investigations under FDA jurisdiction
Receiving or responding to any formal FDA correspondence
EMA · European Union
Representation required when:
Filing a Clinical Trial Application (CTA) via CTIS
Applying for PRIME, Orphan or Paediatric designation as a non-EEA entity
Submitting a Marketing Authorisation Application (MAA)
Engaging national competent authorities as a non-EU entity
MHRA · United Kingdom
Representation required when:
Submitting a Clinical Trial Authorisation in Great Britain
Seeking a Great Britain and Northern Ireland marketing authorisation

Scientific advice, ILAP, PIP and PIM/EAMS do not require UK representative designation.

United States
FDA Β· 21 CFR Part 312 / Part 207

US Agent

Any foreign sponsor seeking to engage the FDA - whether through an IND, NDA, BLA or pre-submission meeting - is required to designate a US Agent. PrimeRA acts as that named contact: receiving agency correspondence, managing communication timelines.

Our team supports every interaction, flags what requires action and by when, and coordinates with your internal team to ensure regulatory continuity.

Named US Agent designation filed with FDA
Receipt and informed relay of all FDA correspondence
Point of contact for FDA-initiated queries
US Capitol building at dusk
European Parliament, Brussels
European Union
EMA Β· CTR Article 74 / Regulation (EU) 536/2014

EU Representative

Non-EU sponsors submitting a Clinical Trial Application or Marketing Authorisation Application must appoint an EU Representative established within the Union. PrimeRA holds that designation, providing a legally compliant point of contact with the EMA and national competent authorities across member states.

From PRIME designation through to MAA, we remain your single named representative, ensuring continuity, regulatory credibility, and a responsive interface with the agency.

Legally designated EU Representative per CTR requirements
Named contact for EMA and national competent authorities
Receipt and informed relay of EMA correspondence with recommended next steps
Supports CTA, PRIME, Orphan Designation and MAA milestones
Access to EMA SME status - PrimeRA's registered SME designation can be extended to eligible non-EEA clients, unlocking significant fee reductions across EMA procedures
Fee reduction on scientific advice procedures in the EU for qualifying programmes
United Kingdom
MHRA Β· SI 2004/1031 (as amended)

UK Representative

Post-Brexit, the UK operates its own regulatory framework for clinical trials and medicines, with the MHRA acting independently of the EMA. Non-UK sponsors submitting a Clinical Trial Authorisation or seeking a marketing authorisation are required to appoint a UK-established representative as the legal point of contact for that procedure.

PrimeRA holds UK representation as a standalone service or as part of a dual UK/EU mandate, providing a single point of continuity across both jurisdictions where development strategies span both markets.

UK-established legal representative for CTA and MAA procedures
Named point of contact with the MHRA
Receipt and contextualised relay of MHRA correspondence
Available as standalone or combined UK + EU mandate
Tower Bridge at dusk, London
Why PrimeRA

Representation that works alongside your strategy

01
ATMP and Specialist Expertise

Our team brings deep experience in ATMPs, rare diseases and complex biologics. Representation with PrimeRA is informed by experience and an understanding of the science and pain points ahead.

02
Single Mandate, Multiple Jurisdictions

For developers managing both designations and regulatory consultancy needs, consolidating these with a single partner removes the complexity of coordinating mulitple providers and ensures consistent positioning with each agency.

03
Representation as Strategy

We interpret every item of agency correspondence in the context of your programme. Whether you have in-house regulatory expertise or require broader strategic support when engaging agencies, that understanding shapes every interaction.

Service Scope

What's included β€” and what's not

The retainer covers all representation obligations. Work that goes beyond designation - such as submission authoring or strategic advisory - is scoped separately under our Delivery and Strategy & Insight pillars.

Included in retainer
Formal designation as US Agent, EU Representative or UK Representative
Receipt of all agency correspondence on your behalf
Contextualised relay to your team with recommended actions
Named point of contact for agency-initiated queries
Designation transfer coordination
Scoped separately
Submission authoring (IND, CTA, MAA, BLA) - see Delivery
Regulatory strategy and development pathway advice - see Strategy & Insight
Scientific advice meeting preparation and attendance -see Strategy & Insight
Orphan designation application authoring - see Delivery
Regulatory due diligence and gap analysis - see Strategy & Insight
FAQs

Common questions

Yes. Designation is a legal requirement distinct from having regulatory support. Your consultant may advise on strategy, but the FDA, MHRA and EMA each require a formally designated contact established within the relevant jurisdiction - a specific compliance obligation that advisory relationships do not always satisfy. PrimeRA holds that designation while working alongside any existing regulatory counsel you have.
If you are conducting clinical trials or seeking a marketing authorisation in the EU or UK, yes. Non-EU sponsors must appoint an EU Representative under the CTR; non-UK sponsors must appoint a UK-established representative under the MHRA framework. These are separate designations and must be held by entities established in the respective territory. PrimeRA satisfies both requirements.
Every item received from the FDA, EMA, MHRA or national competent authorities is reviewed by a member of our regulatory team, assessed against your programme timeline, and relayed with recommended next steps and any applicable deadline.
Transfer is a standard process and PrimeRA manages it in full. We prepare the necessary notifications to each agency, coordinate handover of the correspondence record, and ensure there is no gap in your designated coverage during transition. The process typically completes within 60 days of notice.
Absolutely. Representation services are available on a jurisdiction-by-jurisdiction basis. Clients often begin with the market most immediately relevant to their development timeline and add further jurisdictions as the programme progresses. There is no requirement to hold all three simultaneously.

Ready to establish your regulatory presence?

Discuss your programme