FDA CFR 21 and obsolete ERP

Good morning all,

One of my customer is currently running a SAP Entreprise 4.7 release which will not be supported but SAP after march 2013.

One of is plant / factory has to start a FDA CRF 21 certification process in 2013. He does not want to perform an upgrade to ECC6 in 2013.

Is the obsolete unsupported ERP, a show stopper for the FDA certification.

Thanks.

Cédric