Brazil medical device registration timeline
Source-linked clocksAgência Nacional de Vigilância Sanitária (ANVISA) review clocks and end-to-end planning ranges, using the 4-class (I, II, III, IV) classification system.
| Class / pathway | Review clock | Planning total | With prior approval | Provenance |
|---|---|---|---|---|
| Class I(Notification) Notificação decided within 30 days (RDC 743/2022 Anexo) | 30 days | 1-1.5 months | — | Verified |
| Class II(Notification) Notificação decided within 30 days (RDC 743/2022 Anexo) | 30 days | 1-1.5 months | — | Verified |
| Class III(Registration) RDC 743/2022 Anexo: equipment registration 250 days, materials Risk III registration 320 days (no tacit approval for Risk III materials), IVD 365 days | 250-320 days | 1-11 months | 8-12 months | Verified |
| Class IV(Registration) RDC 743/2022 Anexo: equipment registration 250 days, materials Risk III registration 320 days (no tacit approval for Risk III materials), IVD 365 days | 250-320 days | 1-11 months | 10-14 months | Verified |
Planning steps and estimates; these are not regulator deadlines.
Brazil Medical Device Registration Process
Step-by-step ANVISA registration process. Total estimated timeline: 1-1.5 months.
Step 1: Device Classification
2-4 weeksClassify device under ANVISA RDC 751/2022 (Class I, II, III, or IV).
Step 2: Appoint BRH
4-8 weeksForeign manufacturers must appoint a Brazil Registration Holder (BRH) for registration.
Step 3: GMP Certificate
6-12 monthsObtain ANVISA B-GMP certificate or MDSAP certificate covering Brazil. Facility audit required.
Step 4: Technical Documentation
2-4 monthsPrepare ANVISA-compliant technical dossier. Portuguese translation required.
Step 5: ANVISA Submission
1-2 weeksBRH submits registration application to ANVISA via electronic system.
Step 6: ANVISA Review
6-18 monthsANVISA conducts technical review. IN 290/2024 offers faster pathway with FDA/EU/TGA approval.
Step 7: Registration
2-4 weeksANVISA issues registration. Valid 10 years (or 5 years without MDSAP).
ANVISA uses the analysis already performed by a recognised equivalent foreign regulator as the sole or complementary reference for the registration decision. It shortens how much ANVISA has to re-review, not where the petition sits in the queue: Art. 10 states expressly that adopting the optimized procedure does not change the chronological order of petitions, and ANVISA publishes no reduced deadline for it.
Eligibility: Class III and IV primary registration petitions only, medical devices and IVDs (Art. 2), Prior authorisation by one of the four recognised AREE: TGA via the ARTG, Health Canada via a Medical Device Licence, US FDA via 510(k), PMA or De Novo, or Japan MHLW via Shonin (Art. 6), The device must be essentially identical to the one the AREE authorised, down to composition, indications, manufacturer and manufacturing process (Art. 5 II), Excluded if the AREE itself granted the authorisation through an abbreviated route similar to ANVISA optimized analysis (Art. 4), Filed as a secondary aditamento petition; omit it and the registration is analysed by the ordinary route (Art. 11), ANVISA keeps the right to revert to ordinary analysis with reasons (Art. 9) and to decide differently from the AREE (Art. 13)
RDC 497/2021 Art. 8 gives a Brazilian GMP certificate two years. RDC 850/2024 added a first paragraph doubling that to four years where the certificate was granted through MDSAP, conditional on the manufacturer staying in MDSAP for the whole certificate period.
Eligibility: Manufacturer participates in MDSAP, Participation maintained throughout the validity of the certificate
- Brazil Registration Holder (BRH) - mandatory for foreign manufacturers
- B-GMP certificate (Class III & IV)
- Portuguese labeling and IFU
- Clinical evidence (Class III & IV)
- UDI (phased: Class IV Jul 2025, Class III Jan 2026)
- Post-registration clocks: revalidação decided within 180 days (silence = approval); alteração (changes) within 150 days
MDSAP: MDSAP audit reports stand in for the inspection report when ANVISA grants or renews the B-GMP certificate, and RDC 850/2024 extends that certificate to 4 years for as long as the manufacturer stays in the programme. It is not an inspection waiver: RDC 687/2022 Art. 14 lets ANVISA inspect on site at any time, and refusing an inspection cancels the certificate.
Reviewed 2026-08-30. End-to-end totals remain planning estimates.