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Brazil medical device regulations

Official sources linked

ANVISA rules and guidance for medical device market access, registration, and lifecycle compliance. Each code opens a metadata page with the official source and readable HTML when available.

37 documents8 categories100% linked to official sourcesauthority ANVISA37 readable HTML
CodeRegulationCategoryEffectiveProvenance
IN 426/2026
IN 426/2026 — UDI database transmission and management
Complete ANVISA Legis native HTML expression, including every operative paragraph and native table row/cell/span in source order. The served page declares UTF-8 but appends a Latin1-encoded nonoperative editorial disclaimer; its three replacement characters are preserved as publisher artifacts, not silently repaired. Operative legal text is intact. The controlling publication is the federal DOU; scope and later currentness require separate verification.
RegistrationMarch 1, 2026Official
RDC 925/2024
Personalized Medical Devices
Requirements for manufacture, commercialization, import, and use of personalized medical devices, including patient-matched and custom-made devices.
RegistrationSeptember 24, 2024Official
RDC 903/2024
RDC 903/2024 — transfers and company-data changes
Complete eight-page official Espírito Santo health-secretariat hosted expression of ANVISA RDC 903/2024. It addresses corporate/commercial operations with unchanged technical-sanitary conditions; Article3 excludes unrelated corporate-name changes. The federal DOU publication controls. This source does not establish one route for every device/IVD change or later currentness.
RegistrationSeptember 9, 2024Official
RDC 848/2024
Essential Safety and Performance Requirements
Essential safety and performance requirements for medical devices and in vitro diagnostic medical devices (IVDs). Replaces the previous essential requirements framework used with RDC 751/2022.
RegistrationSeptember 4, 2024Official
RDC 884/2024
UDI Implementation Timeline Extension
Amends RDC 591/2021, extending UDI implementation deadlines. Rectified in the Official Gazette on July 2, 2024.
UDIJuly 1, 2024Official
IN 290/2024
Leveraging Foreign Regulatory Authorizations (AREE)
Establishes an optimized analysis procedure for Class III/IV marketing authorization petitions by using assessments from Equivalent Foreign Regulatory Authorities (AREE/EFRA), including FDA, Health Canada, Japan, and Australia TGA.
RegistrationJune 3, 2024Official
RDC 857/2024
RDC 857/2024 — sanitary-surveillance fee collection procedures
Complete ANVISA Legis native HTML expression, including every operative paragraph and native table row/cell/span in source order. The served page declares UTF-8 but appends a Latin1-encoded nonoperative editorial disclaimer; its three replacement characters are preserved as publisher artifacts, not silently repaired. Operative legal text is intact. The controlling publication is the federal DOU; scope and later currentness require separate verification. Source explicitly identifies DOU publication May8,2024 and corrected republication May9,2024; selected expression retains the republication note.
RegistrationJune 3, 2024Official
RDC 830/2023
In Vitro Diagnostic (IVD) Medical Devices
Regulation for IVD medical devices including classification (Class I-IV), registration pathways, self-testing requirements, and companion diagnostics. Replaced RDC 36/2015.
RegistrationJune 1, 2024Official
RDC 850/2024
GMP Certificate Extension for MDSAP Manufacturers
Amends Article 8 of RDC 497/2021 so qualifying Good Manufacturing Practices certificates granted through MDSAP are valid for four years, subject to continued participation in MDSAP.
GMP/QMSApril 1, 2024Official
RDC 837/2023
Clinical Investigations with Medical Devices
Procedures and Good Clinical Practice requirements for clinical investigations with medical devices in Brazil whose results may support Class III and IV registration.
Clinical TrialsDecember 15, 2023Official
RDC 751/2022
Medical Device Registration and Classification
Core regulation for medical device classification (Class I-IV) and registration pathways (notification vs. marketing authorization) in Brazil.
ClassificationMarch 1, 2023Official
RDC 777/2023
RDC 777/2023 — amendment to RDC 751/2022
Complete two-page official Espírito Santo health-secretariat hosted expression of ANVISA RDC 777/2023, amending the medical-device RDC 751/2022. The Annex II grid and publisher disclaimer are retained. The federal DOU publication controls; this MD amendment does not establish IVD rules or later currentness.
RegistrationMarch 1, 2023Official
RDC 743/2022
RDC 743/2022 — risk classifications and decision-period annexes
Complete ANVISA Legis native HTML expression, including every operative paragraph and native table row/cell/span in source order. The served page declares UTF-8 but appends a Latin1-encoded nonoperative editorial disclaimer; its three replacement characters are preserved as publisher artifacts, not silently repaired. Operative legal text is intact. The controlling publication is the federal DOU; scope and later currentness require separate verification.
RegistrationSeptember 1, 2022Official
RDC 657/2022
Software as Medical Device (SaMD)
Requirements for regularizing Software as a Medical Device (SaMD), including classification, technical documentation, software validation, cybersecurity, labeling, and post-market responsibilities.
Software/SaMDJuly 1, 2022Official
RDC 687/2022
GMP Inspection and Certification Programs for Medical Devices
Inspection programs and criteria for granting or renewing Good Manufacturing Practices certificates for medical device manufacturers, including use of MDSAP audit reports and regulatory-authority inspection information.
GMP/QMSJune 1, 2022Official
RDC 665/2022
Good Manufacturing Practice (GMP) for Medical Devices
GMP requirements for medical device manufacturers including quality management system, design controls, and production processes. Replaced RDC 16/2013.
GMP/QMSMay 2, 2022Official
RDC 591/2021
Unique Device Identification (UDI) System
Brazil's UDI system requiring unique identifiers, machine-readable and human-readable labeling, and submission to ANVISA's UDI database. Implementation deadlines were later amended by RDC 884/2024.
UDIJanuary 10, 2022Official
RDC 551/2021
Field Safety Corrective Actions Notification
Requires registration holders to execute and notify field safety corrective actions, including recalls, corrections, and safety communications to ANVISA and healthcare facilities.
VigilanceOctober 1, 2021Official
RDC 497/2021
GMP and Distribution/Storage Certification Procedures
Administrative procedures for granting Good Manufacturing Practices certificates and Good Distribution and/or Storage Practices certificates. Article 8 amended by RDC 850/2024 to extend MDSAP-linked certificates from 2 to 4 years.
GMP/QMSJune 1, 2021Official
IN 74/2020
Instrução Normativa No. 74/2020 — change-control annexes
Complete ANVISA Legis native HTML expression of IN 74/2020, including both change-control annexes for scoped medical-device and IVD subjects. The publisher states that its text does not replace the official Gazette publication. Later amendments/currentness and subject-specific applicability require separate verification.
RegistrationSeptember 18, 2020Official
RDC 40/2015
Notification Process for Class I and II Medical Devices
Simplified notification process for Class I and II medical devices. Revoked by RDC 751/2022.
RegistrationOctober 26, 2015Official
RDC 67/2009
Technovigilance Rules for Medical Devices
Establishes technovigilance rules for medical device registration holders in Brazil. Defines adverse event reporting requirements, timelines, and post-market surveillance procedures.
VigilanceDecember 23, 2009Official
ANVISA — notified-device alteration FAQ
Alteração de notificação
Complete captured official ANVISA seven-question FAQ on notified-device alterations, including every answer, original list, warning and source link. The complete captured answers are presented together for reading. The portal records 2020 publication and March2023 modification; these are page metadata rather than legal effective dates. Historical source guidance and its statements about combined changes are preserved without certifying current law or merging the distinct registration and notification routes. Source-only; no fact, fee, timeline, binding or question-status promotion.
Registration—Official
ANVISA — registered-device alteration FAQ
Alteração pós-registro
Complete captured official ANVISA seven-question FAQ on postregistration alterations, including every answer, original list, warning and source link. The complete captured answers are presented together for reading. The portal records 2020 publication and March2023 modification; these are page metadata rather than legal effective dates. Historical source guidance and its statements about combined changes are preserved without certifying current law or merging the distinct registration and notification routes. Source-only; no fact, fee, timeline, binding or question-status promotion.
Registration—Official
Decreto nº 10.178, de 18 de dezembro de 2019
Decree No. 10.178/2019 — complete Chamber consolidated text
Complete official Chamber consolidated HTML of the general economic-activity risk-classification and administrative-decision framework: Articles 1–21 with inserted Article 18-A, all publisher amendment annotations, source article anchors, legal links, crest and signatures. This is not a medical-device or IVD-specific instrument. Any application to ANVISA procedures requires the specific companion authority and its exceptions; the text does not establish a universal 60-day or 90-day device alteration period. The historical capture is preserved without a currentness or blanket legal-effect determination.
General—Official
Exports carry source + retrieval date

Changes after registration in Brazil

Source-linked rules for common changes to a registered medical device. Read the scope and conditions with each rule; unverified details are listed separately.

Does changing a device brand name or logo require an update?

A change to the registered brand name and a change to logo artwork can follow different rules. The legal manufacturer, device design and intended purpose remain the same.

  • Filing route and prior approval

Classify an ordinary alteration before implementation

Fact-level verified

Changes to notification or registration are approval-required, immediate, or non-reportable. Classes I/II use immediate implementation except non-reportable changes. Minor non-technical images, layout, symbols or text without added risk, and contact/postal-address updates, can be non-reportable when they do not change the design; control them in the holder’s quality system and incorporate them into later petitions. A trade-name change is not automatically a logo-artwork exemption.

Conditions
  • Device identity, intended purpose, manufacturing process and legal person must be established. A new factory or legal manufacturer must be assessed separately.
  • Filing route and prior approval

Immediate subjects distinguish names from identifiers

Fact-level verified

IN 74 Annex II lists commercial-name changes and foreign legal-manufacturer or factory corporate-name changes as immediate subjects. For equipment and materials it also expressly lists commercial-model name/code changes. The IVD rows separately list commercial name, commercial presentation and legal manufacturer without a manufacturing-process change; the equipment model/code wording must not be applied automatically to an IVD orderable REF.

Conditions
  • Use the actual product sector and its petition subject; an internal order code is not automatically the commercial model or registered presentation.
  • Labels and identifiers

Portuguese language requirement

Fact-level verified

Information on labels and in instructions for use must be written in Portuguese.

Conditions
  • RDC 751/2022 Art. 46 I for devices (in force from 1 March 2023); RDC 830/2023 Art. 46 I mirrors the rule for IVDs.

Effective from 2023-03-01

e-IFU is permitted with conditions (RDC 751/2022 Art. 33 §§5º-6º: SIUD upload within 30/180 days); petition labeling documents must be in Portuguese (Art. 63).

  • Supporting documents

Materials for an ordinary alteration

Fact-level verified

File the applicable petition subject, the fee or exemption where applicable, a declaration listing the requested alterations, and documentary evidence supporting them. A single label mock-up does not replace the subject-specific technical dossier or manufacturer evidence.

  • Supporting documents

Notified MD forms separate manufacturer, plant and model/code fields

Fact-level verified

The official material/equipment notification forms identify the local applicant, legal manufacturer and individual manufacturing plants separately. For families they request commercial model codes/descriptions as stated, together with product/presentation information, applicable conformity-certification particulars and signed legal/technical declarations that labels and IFU meet RDC 751. These fields help distinguish an office identity update from a factory or model change; the form alone does not replace a registered subject’s checklist.

  • Change-specific government fees

TFVS depends on the alteration subject and company size

Fact-level verified

RDC 857 Annex I7.9.1 sets product-registration alteration/inclusion factor 738 DV2 at BRL3514.32,2987.17,2460.02,1405.73,351.43 or175.72 by company-size column. The separate label/IFU alteration item7.9.2 factor 742 DV0 is exempt. Map the actual petition subject to its factor; a commercial-name or manufacturer change is not automatically a label-only exempt petition.

Conditions
  • Company size, subject code and any statutory exemption determine the actual GRU. This is not a portfolio-wide single fee.
  • Change-specific review time

Listed alteration decision periods are not all implementation dates

Fact-level verified

RDC 743’s Annex lists 30 days for the enumerated immediate device/IVD alteration subjects and 150 days for approval-required subjects; the latter rows exclude tacit approval. These are printed as days, not expressly working days. MD Art. 22 as replaced by RDC 777, and IVD RDC 830 Art. 22, provide publication independently of documentary review without printing the old 30-day publication phrase. Do not treat the table as a guaranteed pre-implementation wait or as approval for any combined transfer.

Conditions
  • The Annex retains historical RDC 340 cross-references. The actual listed subject, full instruction and express authority deadline govern.
  • Change-specific review time

Approval clocks depend on a complete instruction

Fact-level verified

Under Decree 10178 Arts. 10–15, the approval period starts when all necessary instruction elements are submitted; the authority must state the deadline. A documentary-complement request can suspend the clock, with the stated new-fact exception. These provisions do not create a universal 60-day or 90-day device alteration period.

  • Labels and identifiers
  • Existing stock and transition

Finished stock and unused label stock have different limits

Fact-level verified

For an ordinary alteration, old and new finished-device versions may be imported and sold until expiry or the end of useful life. Unused packaging, labels and IFUs may be exhausted for 120 days from publication of the alteration. Changes made to resolve safety or performance problems are excluded from both permissions. The publication trigger does not create an implementation-date clock for an unpublished non-reportable artwork change.

Conditions
  • These are ordinary alteration rules. Holder transfers follow RDC 903 instead.
  • Labels and identifiers

Commercial-name UDI rules do not identify an internal REF

Fact-level verified

RDC 591 Annex II2.9 as amended by RDC 884 requires a new UDI-DI where a change could create identification ambiguity, and expressly for trade/commercial-model name changes. Under2.12 a label change solely to add UDI is not itself a regularization-change petition. A customer’s internal REF is not automatically a commercial model or UDI-DI; establish what registered and issued identifiers actually change.

Conditions
  • Apply the class/product implementation stage and current SIUD suspension list; operation of SIUD is not a universal mandatory reporting date.

How do I update a manufacturer's name without changing the legal entity?

The same legal manufacturer changes its name, potentially alongside the device brand. A transfer to another legal entity is a separate question; permission to combine filings needs its own evidence.

  • Filing route and prior approval

Classify an ordinary alteration before implementation

Fact-level verified

Changes to notification or registration are approval-required, immediate, or non-reportable. Classes I/II use immediate implementation except non-reportable changes. Minor non-technical images, layout, symbols or text without added risk, and contact/postal-address updates, can be non-reportable when they do not change the design; control them in the holder’s quality system and incorporate them into later petitions. A trade-name change is not automatically a logo-artwork exemption.

Conditions
  • Device identity, intended purpose, manufacturing process and legal person must be established. A new factory or legal manufacturer must be assessed separately.
  • Filing route and prior approval

Immediate subjects distinguish names from identifiers

Fact-level verified

IN 74 Annex II lists commercial-name changes and foreign legal-manufacturer or factory corporate-name changes as immediate subjects. For equipment and materials it also expressly lists commercial-model name/code changes. The IVD rows separately list commercial name, commercial presentation and legal manufacturer without a manufacturing-process change; the equipment model/code wording must not be applied automatically to an IVD orderable REF.

Conditions
  • Use the actual product sector and its petition subject; an internal order code is not automatically the commercial model or registered presentation.
  • Supporting documents

Materials for an ordinary alteration

Fact-level verified

File the applicable petition subject, the fee or exemption where applicable, a declaration listing the requested alterations, and documentary evidence supporting them. A single label mock-up does not replace the subject-specific technical dossier or manufacturer evidence.

  • Supporting documents

Notified MD forms separate manufacturer, plant and model/code fields

Fact-level verified

The official material/equipment notification forms identify the local applicant, legal manufacturer and individual manufacturing plants separately. For families they request commercial model codes/descriptions as stated, together with product/presentation information, applicable conformity-certification particulars and signed legal/technical declarations that labels and IFU meet RDC 751. These fields help distinguish an office identity update from a factory or model change; the form alone does not replace a registered subject’s checklist.

  • Change-specific government fees

TFVS depends on the alteration subject and company size

Fact-level verified

RDC 857 Annex I7.9.1 sets product-registration alteration/inclusion factor 738 DV2 at BRL3514.32,2987.17,2460.02,1405.73,351.43 or175.72 by company-size column. The separate label/IFU alteration item7.9.2 factor 742 DV0 is exempt. Map the actual petition subject to its factor; a commercial-name or manufacturer change is not automatically a label-only exempt petition.

Conditions
  • Company size, subject code and any statutory exemption determine the actual GRU. This is not a portfolio-wide single fee.
  • Change-specific review time

Listed alteration decision periods are not all implementation dates

Fact-level verified

RDC 743’s Annex lists 30 days for the enumerated immediate device/IVD alteration subjects and 150 days for approval-required subjects; the latter rows exclude tacit approval. These are printed as days, not expressly working days. MD Art. 22 as replaced by RDC 777, and IVD RDC 830 Art. 22, provide publication independently of documentary review without printing the old 30-day publication phrase. Do not treat the table as a guaranteed pre-implementation wait or as approval for any combined transfer.

Conditions
  • The Annex retains historical RDC 340 cross-references. The actual listed subject, full instruction and express authority deadline govern.
  • Change-specific review time

Approval clocks depend on a complete instruction

Fact-level verified

Under Decree 10178 Arts. 10–15, the approval period starts when all necessary instruction elements are submitted; the authority must state the deadline. A documentary-complement request can suspend the clock, with the stated new-fact exception. These provisions do not create a universal 60-day or 90-day device alteration period.

  • Labels and identifiers
  • Existing stock and transition

Finished stock and unused label stock have different limits

Fact-level verified

For an ordinary alteration, old and new finished-device versions may be imported and sold until expiry or the end of useful life. Unused packaging, labels and IFUs may be exhausted for 120 days from publication of the alteration. Changes made to resolve safety or performance problems are excluded from both permissions. The publication trigger does not create an implementation-date clock for an unpublished non-reportable artwork change.

Conditions
  • These are ordinary alteration rules. Holder transfers follow RDC 903 instead.
  • Labels and identifiers

Commercial-name UDI rules do not identify an internal REF

Fact-level verified

RDC 591 Annex II2.9 as amended by RDC 884 requires a new UDI-DI where a change could create identification ambiguity, and expressly for trade/commercial-model name changes. Under2.12 a label change solely to add UDI is not itself a regularization-change petition. A customer’s internal REF is not automatically a commercial model or UDI-DI; establish what registered and issued identifiers actually change.

Conditions
  • Apply the class/product implementation stage and current SIUD suspension list; operation of SIUD is not a universal mandatory reporting date.
  • Labels and identifiers

Portuguese language requirement

Fact-level verified

Information on labels and in instructions for use must be written in Portuguese.

Conditions
  • RDC 751/2022 Art. 46 I for devices (in force from 1 March 2023); RDC 830/2023 Art. 46 I mirrors the rule for IVDs.

Effective from 2023-03-01

e-IFU is permitted with conditions (RDC 751/2022 Art. 33 §§5º-6º: SIUD upload within 30/180 days); petition labeling documents must be in Portuguese (Art. 63).

  • Combined filing

Interdependent alterations follow the approval-required petition

Fact-level verified

An immediate alteration that is interdependent with an approval-required alteration must be filed jointly with it and incorporated into that petition. Approval-required changes take effect only after the final decision is published in the Diário Oficial da União.

  • Combined filing

Registered change petitions do not absorb unrequested subjects

Fact-level verified

The official registered-device alteration FAQ says that a petition permits only its requested alteration item and other inserted alterations are disregarded. This must be read with the legal rule requiring an interdependent immediate change to accompany the approval-required change. It does not authorize combining every name/address/REF/holder change into one fee or decision.

  • Combined filing

Multiple notified MD alterations can share a petition

Fact-level verified

The official notification-alteration FAQ permits more than one alteration in the same notification petition if every alteration is identified in the form and declaration. Omitted alterations risk refusal. This does not transfer a notification to another holder or authorize batching different regularizations.

What changes when the manufacturer's office address changes?

An office address change for the same legal entity, potentially alongside name and brand changes. This does not cover moving a factory or manufacturing site, and a combined filing cannot be assumed.

  • Filing route and prior approval

Classify an ordinary alteration before implementation

Fact-level verified

Changes to notification or registration are approval-required, immediate, or non-reportable. Classes I/II use immediate implementation except non-reportable changes. Minor non-technical images, layout, symbols or text without added risk, and contact/postal-address updates, can be non-reportable when they do not change the design; control them in the holder’s quality system and incorporate them into later petitions. A trade-name change is not automatically a logo-artwork exemption.

Conditions
  • Device identity, intended purpose, manufacturing process and legal person must be established. A new factory or legal manufacturer must be assessed separately.
  • Filing route and prior approval

Immediate subjects distinguish names from identifiers

Fact-level verified

IN 74 Annex II lists commercial-name changes and foreign legal-manufacturer or factory corporate-name changes as immediate subjects. For equipment and materials it also expressly lists commercial-model name/code changes. The IVD rows separately list commercial name, commercial presentation and legal manufacturer without a manufacturing-process change; the equipment model/code wording must not be applied automatically to an IVD orderable REF.

Conditions
  • Use the actual product sector and its petition subject; an internal order code is not automatically the commercial model or registered presentation.
  • Supporting documents

Materials for an ordinary alteration

Fact-level verified

File the applicable petition subject, the fee or exemption where applicable, a declaration listing the requested alterations, and documentary evidence supporting them. A single label mock-up does not replace the subject-specific technical dossier or manufacturer evidence.

  • Supporting documents

Notified MD forms separate manufacturer, plant and model/code fields

Fact-level verified

The official material/equipment notification forms identify the local applicant, legal manufacturer and individual manufacturing plants separately. For families they request commercial model codes/descriptions as stated, together with product/presentation information, applicable conformity-certification particulars and signed legal/technical declarations that labels and IFU meet RDC 751. These fields help distinguish an office identity update from a factory or model change; the form alone does not replace a registered subject’s checklist.

  • Change-specific government fees

TFVS depends on the alteration subject and company size

Fact-level verified

RDC 857 Annex I7.9.1 sets product-registration alteration/inclusion factor 738 DV2 at BRL3514.32,2987.17,2460.02,1405.73,351.43 or175.72 by company-size column. The separate label/IFU alteration item7.9.2 factor 742 DV0 is exempt. Map the actual petition subject to its factor; a commercial-name or manufacturer change is not automatically a label-only exempt petition.

Conditions
  • Company size, subject code and any statutory exemption determine the actual GRU. This is not a portfolio-wide single fee.
  • Change-specific review time

Listed alteration decision periods are not all implementation dates

Fact-level verified

RDC 743’s Annex lists 30 days for the enumerated immediate device/IVD alteration subjects and 150 days for approval-required subjects; the latter rows exclude tacit approval. These are printed as days, not expressly working days. MD Art. 22 as replaced by RDC 777, and IVD RDC 830 Art. 22, provide publication independently of documentary review without printing the old 30-day publication phrase. Do not treat the table as a guaranteed pre-implementation wait or as approval for any combined transfer.

Conditions
  • The Annex retains historical RDC 340 cross-references. The actual listed subject, full instruction and express authority deadline govern.
  • Change-specific review time

Approval clocks depend on a complete instruction

Fact-level verified

Under Decree 10178 Arts. 10–15, the approval period starts when all necessary instruction elements are submitted; the authority must state the deadline. A documentary-complement request can suspend the clock, with the stated new-fact exception. These provisions do not create a universal 60-day or 90-day device alteration period.

  • Labels and identifiers
  • Existing stock and transition

Finished stock and unused label stock have different limits

Fact-level verified

For an ordinary alteration, old and new finished-device versions may be imported and sold until expiry or the end of useful life. Unused packaging, labels and IFUs may be exhausted for 120 days from publication of the alteration. Changes made to resolve safety or performance problems are excluded from both permissions. The publication trigger does not create an implementation-date clock for an unpublished non-reportable artwork change.

Conditions
  • These are ordinary alteration rules. Holder transfers follow RDC 903 instead.
  • Labels and identifiers

Commercial-name UDI rules do not identify an internal REF

Fact-level verified

RDC 591 Annex II2.9 as amended by RDC 884 requires a new UDI-DI where a change could create identification ambiguity, and expressly for trade/commercial-model name changes. Under2.12 a label change solely to add UDI is not itself a regularization-change petition. A customer’s internal REF is not automatically a commercial model or UDI-DI; establish what registered and issued identifiers actually change.

Conditions
  • Apply the class/product implementation stage and current SIUD suspension list; operation of SIUD is not a universal mandatory reporting date.
  • Labels and identifiers

Portuguese language requirement

Fact-level verified

Information on labels and in instructions for use must be written in Portuguese.

Conditions
  • RDC 751/2022 Art. 46 I for devices (in force from 1 March 2023); RDC 830/2023 Art. 46 I mirrors the rule for IVDs.

Effective from 2023-03-01

e-IFU is permitted with conditions (RDC 751/2022 Art. 33 §§5º-6º: SIUD upload within 30/180 days); petition labeling documents must be in Portuguese (Art. 63).

  • Combined filing

Interdependent alterations follow the approval-required petition

Fact-level verified

An immediate alteration that is interdependent with an approval-required alteration must be filed jointly with it and incorporated into that petition. Approval-required changes take effect only after the final decision is published in the Diário Oficial da União.

  • Combined filing

Registered change petitions do not absorb unrequested subjects

Fact-level verified

The official registered-device alteration FAQ says that a petition permits only its requested alteration item and other inserted alterations are disregarded. This must be read with the legal rule requiring an interdependent immediate change to accompany the approval-required change. It does not authorize combining every name/address/REF/holder change into one fee or decision.

  • Combined filing

Multiple notified MD alterations can share a petition

Fact-level verified

The official notification-alteration FAQ permits more than one alteration in the same notification petition if every alteration is identified in the form and declaration. Omitted alterations risk refusal. This does not transfer a notification to another holder or authorize batching different regularizations.

Does a catalogue or reference code change affect registration or UDI?

Check which identifier actually changes. A commercial catalogue, REF or order code is not automatically a device model, registered identifier, GTIN or UDI-DI. Rules for one identifier do not establish the route for another.

  • Filing route and prior approval

Classify an ordinary alteration before implementation

Fact-level verified

Changes to notification or registration are approval-required, immediate, or non-reportable. Classes I/II use immediate implementation except non-reportable changes. Minor non-technical images, layout, symbols or text without added risk, and contact/postal-address updates, can be non-reportable when they do not change the design; control them in the holder’s quality system and incorporate them into later petitions. A trade-name change is not automatically a logo-artwork exemption.

Conditions
  • Device identity, intended purpose, manufacturing process and legal person must be established. A new factory or legal manufacturer must be assessed separately.
  • Filing route and prior approval

Immediate subjects distinguish names from identifiers

Fact-level verified

IN 74 Annex II lists commercial-name changes and foreign legal-manufacturer or factory corporate-name changes as immediate subjects. For equipment and materials it also expressly lists commercial-model name/code changes. The IVD rows separately list commercial name, commercial presentation and legal manufacturer without a manufacturing-process change; the equipment model/code wording must not be applied automatically to an IVD orderable REF.

Conditions
  • Use the actual product sector and its petition subject; an internal order code is not automatically the commercial model or registered presentation.
  • Supporting documents

Materials for an ordinary alteration

Fact-level verified

File the applicable petition subject, the fee or exemption where applicable, a declaration listing the requested alterations, and documentary evidence supporting them. A single label mock-up does not replace the subject-specific technical dossier or manufacturer evidence.

  • Supporting documents

Notified MD forms separate manufacturer, plant and model/code fields

Fact-level verified

The official material/equipment notification forms identify the local applicant, legal manufacturer and individual manufacturing plants separately. For families they request commercial model codes/descriptions as stated, together with product/presentation information, applicable conformity-certification particulars and signed legal/technical declarations that labels and IFU meet RDC 751. These fields help distinguish an office identity update from a factory or model change; the form alone does not replace a registered subject’s checklist.

  • Change-specific government fees

TFVS depends on the alteration subject and company size

Fact-level verified

RDC 857 Annex I7.9.1 sets product-registration alteration/inclusion factor 738 DV2 at BRL3514.32,2987.17,2460.02,1405.73,351.43 or175.72 by company-size column. The separate label/IFU alteration item7.9.2 factor 742 DV0 is exempt. Map the actual petition subject to its factor; a commercial-name or manufacturer change is not automatically a label-only exempt petition.

Conditions
  • Company size, subject code and any statutory exemption determine the actual GRU. This is not a portfolio-wide single fee.
  • Change-specific review time

Listed alteration decision periods are not all implementation dates

Fact-level verified

RDC 743’s Annex lists 30 days for the enumerated immediate device/IVD alteration subjects and 150 days for approval-required subjects; the latter rows exclude tacit approval. These are printed as days, not expressly working days. MD Art. 22 as replaced by RDC 777, and IVD RDC 830 Art. 22, provide publication independently of documentary review without printing the old 30-day publication phrase. Do not treat the table as a guaranteed pre-implementation wait or as approval for any combined transfer.

Conditions
  • The Annex retains historical RDC 340 cross-references. The actual listed subject, full instruction and express authority deadline govern.
  • Change-specific review time

Approval clocks depend on a complete instruction

Fact-level verified

Under Decree 10178 Arts. 10–15, the approval period starts when all necessary instruction elements are submitted; the authority must state the deadline. A documentary-complement request can suspend the clock, with the stated new-fact exception. These provisions do not create a universal 60-day or 90-day device alteration period.

  • Labels and identifiers
  • Existing stock and transition

Finished stock and unused label stock have different limits

Fact-level verified

For an ordinary alteration, old and new finished-device versions may be imported and sold until expiry or the end of useful life. Unused packaging, labels and IFUs may be exhausted for 120 days from publication of the alteration. Changes made to resolve safety or performance problems are excluded from both permissions. The publication trigger does not create an implementation-date clock for an unpublished non-reportable artwork change.

Conditions
  • These are ordinary alteration rules. Holder transfers follow RDC 903 instead.
  • Labels and identifiers

Commercial-name UDI rules do not identify an internal REF

Fact-level verified

RDC 591 Annex II2.9 as amended by RDC 884 requires a new UDI-DI where a change could create identification ambiguity, and expressly for trade/commercial-model name changes. Under2.12 a label change solely to add UDI is not itself a regularization-change petition. A customer’s internal REF is not automatically a commercial model or UDI-DI; establish what registered and issued identifiers actually change.

Conditions
  • Apply the class/product implementation stage and current SIUD suspension list; operation of SIUD is not a universal mandatory reporting date.
  • Labels and identifiers

Portuguese language requirement

Fact-level verified

Information on labels and in instructions for use must be written in Portuguese.

Conditions
  • RDC 751/2022 Art. 46 I for devices (in force from 1 March 2023); RDC 830/2023 Art. 46 I mirrors the rule for IVDs.

Effective from 2023-03-01

e-IFU is permitted with conditions (RDC 751/2022 Art. 33 §§5º-6º: SIUD upload within 30/180 days); petition labeling documents must be in Portuguese (Art. 63).

  • Combined filing

Interdependent alterations follow the approval-required petition

Fact-level verified

An immediate alteration that is interdependent with an approval-required alteration must be filed jointly with it and incorporated into that petition. Approval-required changes take effect only after the final decision is published in the Diário Oficial da União.

  • Combined filing

Registered change petitions do not absorb unrequested subjects

Fact-level verified

The official registered-device alteration FAQ says that a petition permits only its requested alteration item and other inserted alterations are disregarded. This must be read with the legal rule requiring an interdependent immediate change to accompany the approval-required change. It does not authorize combining every name/address/REF/holder change into one fee or decision.

  • Combined filing

Multiple notified MD alterations can share a petition

Fact-level verified

The official notification-alteration FAQ permits more than one alteration in the same notification petition if every alteration is identified in the form and declaration. Omitted alterations risk refusal. This does not transfer a notification to another holder or authorize batching different regularizations.

Can several changes be filed together?

Changes to brand, manufacturer name, office address and reference codes may occur together, including with a real transfer to another legal manufacturer, registration holder or owner. Assess transfer with each single change, and transfer with brand plus reference, manufacturer name plus reference, or office address plus reference changes: seven transfer combinations in total. Evidence must establish the exact combination and the order of filings and approvals. These combinations and their sequence are not all verified by the rules below; a rule for one change does not prove that a single application, fee or review period covers the combination.

  • Filing route and prior approval

Classify an ordinary alteration before implementation

Fact-level verified

Changes to notification or registration are approval-required, immediate, or non-reportable. Classes I/II use immediate implementation except non-reportable changes. Minor non-technical images, layout, symbols or text without added risk, and contact/postal-address updates, can be non-reportable when they do not change the design; control them in the holder’s quality system and incorporate them into later petitions. A trade-name change is not automatically a logo-artwork exemption.

Conditions
  • Device identity, intended purpose, manufacturing process and legal person must be established. A new factory or legal manufacturer must be assessed separately.
  • Filing route and prior approval

Immediate subjects distinguish names from identifiers

Fact-level verified

IN 74 Annex II lists commercial-name changes and foreign legal-manufacturer or factory corporate-name changes as immediate subjects. For equipment and materials it also expressly lists commercial-model name/code changes. The IVD rows separately list commercial name, commercial presentation and legal manufacturer without a manufacturing-process change; the equipment model/code wording must not be applied automatically to an IVD orderable REF.

Conditions
  • Use the actual product sector and its petition subject; an internal order code is not automatically the commercial model or registered presentation.
  • Combined filing
  • Filing route and prior approval

Interdependent alterations follow the approval-required petition

Fact-level verified

An immediate alteration that is interdependent with an approval-required alteration must be filed jointly with it and incorporated into that petition. Approval-required changes take effect only after the final decision is published in the Diário Oficial da União.

  • Filing route and prior approval

Registered holder succession differs from a notified product

Fact-level verified

For an unchanged registered product, the successor’s holder-transfer petition and predecessor’s cancellation petition must be filed concurrently within 180 days of the registered corporate act or asset-transfer contract, subject to the separate Mercosur trigger. Late petitions are refused. Products subject to notification or exemption are not transferred: the successor makes a new notification or regularization. A simple same-person corporate-name change is excluded from this transaction regime.

Conditions
  • Determine whether the foreign manufacturer, Brazilian holder, or both actually change legal person. A foreign corporate transaction does not by itself transfer the Brazilian registration.
  • Supporting documents

Materials for an ordinary alteration

Fact-level verified

File the applicable petition subject, the fee or exemption where applicable, a declaration listing the requested alterations, and documentary evidence supporting them. A single label mock-up does not replace the subject-specific technical dossier or manufacturer evidence.

  • Supporting documents

Notified MD forms separate manufacturer, plant and model/code fields

Fact-level verified

The official material/equipment notification forms identify the local applicant, legal manufacturer and individual manufacturing plants separately. For families they request commercial model codes/descriptions as stated, together with product/presentation information, applicable conformity-certification particulars and signed legal/technical declarations that labels and IFU meet RDC 751. These fields help distinguish an office identity update from a factory or model change; the form alone does not replace a registered subject’s checklist.

  • Combined filing
  • Supporting documents

Transfer documents and pending applications

Fact-level verified

Transfer requires the signed petition form, GRU proof of TFVS payment/exemption, Annex I transaction declaration and updated operating/sanitary licence. Pending initial applications are updated by an amendment rather than a transfer of an issued registration. Pending post-registration petitions transfer only when declared in Annex I; unlisted petitions are closed. Holder-only label/IFU updates may be implemented after transfer approval.

  • Supporting documents

Corporate operations can require separate AFE and GMP updates

Fact-level verified

RDC 903 Arts. 7–14 require the applicable company-authorization and GMP/distribution-certificate updates following corporate/commercial operations. A new legal person or unregularized successor needs initial AFE/AE as applicable. For a qualifying unchanged production line, CBPF update preserves certificate validity; an exclusively foreign operation is petitioned by the current certification applicant. Art. 13 lists the form, existing certificate, transaction declaration, applicable updated AFE publication, and successor-country GMP certificate or competent-authority transaction attestation for a foreign operation.

Conditions
  • Actual technical/sanitary characteristics and the entire affected production line must meet Art. 12. These establishment/certification acts are distinct from product-holder transfer and product alterations.
  • Change-specific government fees

TFVS depends on the alteration subject and company size

Fact-level verified

RDC 857 Annex I7.9.1 sets product-registration alteration/inclusion factor 738 DV2 at BRL3514.32,2987.17,2460.02,1405.73,351.43 or175.72 by company-size column. The separate label/IFU alteration item7.9.2 factor 742 DV0 is exempt. Map the actual petition subject to its factor; a commercial-name or manufacturer change is not automatically a label-only exempt petition.

Conditions
  • Company size, subject code and any statutory exemption determine the actual GRU. This is not a portfolio-wide single fee.
  • Change-specific government fees

Transfer TFVS is affected by successor size

Fact-level verified

RDC 857 Art. 10 conditions holder transfer on any positive TFVS difference associated with the successor’s economic size and provides no refund if it is smaller. Simultaneous renewal and later transfer use the specified size-reference dates; a later transfer also triggers the alteration charge. Calculate the actual petition and size difference rather than assuming an ordinary label-only exemption.

  • Change-specific review time

Listed alteration decision periods are not all implementation dates

Fact-level verified

RDC 743’s Annex lists 30 days for the enumerated immediate device/IVD alteration subjects and 150 days for approval-required subjects; the latter rows exclude tacit approval. These are printed as days, not expressly working days. MD Art. 22 as replaced by RDC 777, and IVD RDC 830 Art. 22, provide publication independently of documentary review without printing the old 30-day publication phrase. Do not treat the table as a guaranteed pre-implementation wait or as approval for any combined transfer.

Conditions
  • The Annex retains historical RDC 340 cross-references. The actual listed subject, full instruction and express authority deadline govern.
  • Change-specific review time

Approval clocks depend on a complete instruction

Fact-level verified

Under Decree 10178 Arts. 10–15, the approval period starts when all necessary instruction elements are submitted; the authority must state the deadline. A documentary-complement request can suspend the clock, with the stated new-fact exception. These provisions do not create a universal 60-day or 90-day device alteration period.

  • Labels and identifiers
  • Existing stock and transition

Transfer stock has its own effective-date sequence

Fact-level verified

The successor is responsible for remaining finished stock. Finished stock produced before the individual transfer/cancellation resolutions take effect may be imported or sold for at most180 days after that effective date. Outdated packaging cannot be used for new lots produced afterwards. Unless otherwise stated, those individual resolutions take effect90 days after publication. These180/90-day periods are stock/effect rules, not agency review periods.

  • Labels and identifiers

Commercial-name UDI rules do not identify an internal REF

Fact-level verified

RDC 591 Annex II2.9 as amended by RDC 884 requires a new UDI-DI where a change could create identification ambiguity, and expressly for trade/commercial-model name changes. Under2.12 a label change solely to add UDI is not itself a regularization-change petition. A customer’s internal REF is not automatically a commercial model or UDI-DI; establish what registered and issued identifiers actually change.

Conditions
  • Apply the class/product implementation stage and current SIUD suspension list; operation of SIUD is not a universal mandatory reporting date.
  • Labels and identifiers

Product holder transfer precedes SIUD transfer

Fact-level verified

IN 426 Art. 8 requires completion of the formal RDC 903 holder transfer before SIUD data transfer; successor data are transmitted for the new registration numbers within 30 days after the individual transfer/cancellation resolutions take effect. Art. 7§3 separately gives30 calendar days from publication for replacement where the change requires a new UDI-DI. These data deadlines are not agency variation-review periods.

Conditions
  • Actual product/class reporting applicability and any published product-specific suspension must be checked.
  • Labels and identifiers

Portuguese language requirement

Fact-level verified

Information on labels and in instructions for use must be written in Portuguese.

Conditions
  • RDC 751/2022 Art. 46 I for devices (in force from 1 March 2023); RDC 830/2023 Art. 46 I mirrors the rule for IVDs.

Effective from 2023-03-01

e-IFU is permitted with conditions (RDC 751/2022 Art. 33 §§5º-6º: SIUD upload within 30/180 days); petition labeling documents must be in Portuguese (Art. 63).

  • Combined filing

Registered change petitions do not absorb unrequested subjects

Fact-level verified

The official registered-device alteration FAQ says that a petition permits only its requested alteration item and other inserted alterations are disregarded. This must be read with the legal rule requiring an interdependent immediate change to accompany the approval-required change. It does not authorize combining every name/address/REF/holder change into one fee or decision.

  • Combined filing

Multiple notified MD alterations can share a petition

Fact-level verified

The official notification-alteration FAQ permits more than one alteration in the same notification petition if every alteration is identified in the form and declaration. Omitted alterations risk refusal. This does not transfer a notification to another holder or authorize batching different regularizations.

Regulation codes

What these codes are

Each row above represents one regulatory instrument. Its code is the authority’s identifier. A regulation page collects the metadata and official source; when readable HTML is available, article links can open and highlight the exact cited passage.

RDC

Resolução da Diretoria Colegiada

A Collegiate Board Resolution is ANVISA’s primary binding regulation. The number is sequential within the year (RDC 751/2022 is resolution 751 issued in 2022).

IN

Instrução Normativa

A Normative Instruction details how an RDC is applied — procedures, timelines, or documentary requirements. It does not replace the parent RDC.

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Tracked from official ANVISA publications · row IDs are stable — cite as regulations:brazil:anvisa-notified-device-change-faq