FREQUENTLY ASKED QUESTIONS
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What should I know before exporting to Brazil?
Brazil represents one of the most popular destinations for medical device manufacturers, being the largest healthcare market in Latin America. But Brazil has a complex set of regulations that challenge foreign manufacturers. Anvisa (the Brazilian Health Regulatory Agency) carries out all registration and inspection processes, meaning that only companies based in Brazil can apply for registration. Companies based elsewhere that do not have subsidiaries in Brazil must instead rely on third-party companies legally constituted in the country, such as QualiThings, who will be legally responsible for the products commercialized in the Brazilian territory. It is recommended that foreign companies have local technical staff for customer support. Moreover, exporting regulated medical devices to Brazil might include the need for specific pre-market authorizations issued by Anvisa and other regulatory bodies. So, the commercialization of health products in Brazil relies on Anvisa’s approval. Most medical devices must be registered by Anvisa and the manufacturer might have to be certified by this Agency for Good Manufacturing Practices, a process which might include audits at the place of origin. Additionally, products regulated by Anvisa are subjected to approval at borders when entering Brazil and might be subjected to physical inspection.
How do I know if I need a pre-market authorization to sell my product in Brazil?
Brazil is the largest medical device market in Latin America and has a well-established but complex regulatory system. Before the medical devices can be marketed in Brazil, they must comply with Anvisa’s requirements, which vary significantly depending on the product’s risk class. As such, the correct classification of the medical device is crucial. Our company has the knowledge and expertise to work out the proper classification for your medical device and to assist with every step of the preparation and submission of your application.
What is the difference between "notificação" and "registro"?
Notification (“Notificação”): Anvisa’s authorization for risk class I and II devices is achieved through a simplified process. A technical dossier of the product, and the proposed label and instructions for use in Portuguese, must be submitted to Anvisa. Class I and II notifications do not expire but must be reviewed periodically. Registration (“Registro”): Risk class III and IV medical devices must take a regulatory route which requires BGMP certification prior to product’s authorization. This includes submitting to Anvisa a complete technical file containing clinical data, biocompatibility studies, performance tests, etc. Class III and IV registrations are valid for ten years. *Please note that additional certifications issued by other regulatory bodies (INMETRO, ANATEL) might be needed depending on the device’s features.
Can I transfer my market authorization (Registro or Notificação) to another Brazil Registration Holder (BRH)?
Yes! You can! Brazilian Resolution RDC 102/2016 allows great flexibility for registration transfers. However, transfers will require the cooperation of the previous BRH: they must sign the transfer contract and ask Anvisa to cancel the registration under their name. Anvisa will issue a new registration number once the transfer is approved, but the registration will carry the original expiry date.