Exterior of a large pharmaceutical manufacturing facility at dusk

FOREIGN SITE GMP EVIDENCE — CANADA

The shortcut is gone. The evidence is not.

The shortcut is gone. The evidence is not.

On 16 February 2026 Health Canada ended the Foreign Site Reference Number process, effective immediately and without notice. Foreign sites can no longer submit GMP evidence on their own behalf, new applications are refused, and existing reference numbers are marked discontinued. Foreign warehouses no longer appear on site licences. Every foreign site’s GMP evidence now travels through the Canadian importer’s site licence application.

Exterior of a large pharmaceutical manufacturing facility at dusk

FOREIGN SITE GMP EVIDENCE — CANADA

The shortcut is gone. The evidence is not.

On 16 February 2026 Health Canada ended the Foreign Site Reference Number process, effective immediately and without notice. Foreign sites can no longer submit GMP evidence on their own behalf, new applications are refused, and existing reference numbers are marked discontinued. Foreign warehouses no longer appear on site licences. Every foreign site’s GMP evidence now travels through the Canadian importer’s site licence application.

Container ship at port

WHAT CHANGED

The burden moved to the importer.

The burden moved to the importer.

Under the old process a foreign manufacturer could be assessed once and referenced by every importer who used it. That mechanism no longer exists. Each importer now assembles and submits a full GMP evidence package for each foreign site, on each application, amendment and renewal. Where several importers share a manufacturer, each submits separately. The manufacturer has no way to do it for them.

WHERE THIS BITES

Four consequences.

Four consequences.

01

Guidance that has not caught up

Health Canada’s site licence application form and site licensing guidance still reference the old process as acceptable evidence. Anyone working from the published documents is working from something superseded.

02

Relationships that were never documented

Importers who relied on a manufacturer’s reference number often have no GMP evidence of their own, no quality agreement, and no established route to request either.

03

Repeated submissions

A manufacturer supplying several Canadian importers now fields the same document request from each of them, with no shared file to point at.

04

Timeline exposure

GMP evidence is now reviewed inside the site licence pathway rather than ahead of it, which changes when a gap is discovered and how much runway is left to close it.

WHAT WE DO

Assemble the file, not just the application.

Review of existing foreign site documentation and identification of what is missing.

GMP evidence package assembly to the standard required for site licence submission.

Quality agreement drafting between importer and foreign site.

Supplier risk assessment and manufacturer qualification.

Site licence application, amendment and renewal support.

Coordination with the foreign site where language, confidentiality or reluctance is an obstacle.

Audit readiness review.

WHO THIS IS FOR

Two sides of the same file.

Two sides of the same file.

Canadian importers

Importers who now carry evidence obligations they previously delegated to a manufacturer’s reference number.

Foreign manufacturers

Sites in the US, Europe and Asia that supply Canada and need their documentation to survive a Canadian importer’s submission.

WHY KOMPETE

Registered, and on the file.

Registered, and on the file.

Kompete is a registered Trading Partner with Health Canada’s NNHPD under company code 79873. We work on both the importer and the manufacturer side of foreign site qualification.

Send us the site list before the next submission.

Send us the site list before the next submission.

Bring us the foreign sites, the importer of record and the submission you are working toward. We will tell you what evidence exists, what is missing and how the file gets assembled.