BrazilEU conformity assessment Prior approval / evidence record
EU CE Mark
- Benefit
Not an AREE under IN 290/2024 Art. 6
Maintained reference · planning ranges remain estimates · reviewed 2026-08-30
Prior approval / evidence record
Japan MHLW
- Benefit
Recognised AREE for IN 290/2024, evidenced by the Shonin pre-market approval
- Timeline Savings
None published
Maintained reference · planning ranges remain estimates · reviewed 2026-08-30
Prior approval / evidence record
Health Canada
- Benefit
Recognised AREE for IN 290/2024, evidenced by the Medical Device Licence
- Timeline Savings
None published
Maintained reference · planning ranges remain estimates · reviewed 2026-08-30
Prior approval / evidence record
Class IV
- Verification Status
official-verified
- Official Source
- Title
ANVISA RDC 743/2022 — analysis deadlines per subject and act (Anexo)
- Url
https://anvisalegis.datalegis.net/action/ActionDatalegis.php?acao=abrirTextoAto&tipo=RDC&numeroAto=00000743&seqAto=000&valorAno=2022&orgao=RDC/DC/ANVISA/MS&cod_modulo=310&cod_menu=9434
- Prior Approval Benefits
- FDA 510(k)/PMA (via IN 290/2024)
- MDSAP for B-GMP
- Notes
- RDC 743/2022 Anexo: equipment registration 250 days, materials Risk III registration 320 days (no tacit approval for Risk III materials), IVD 365 days
- Lei 6.360/1976 Art. 12 §3º separately binds ANVISA to 90 days for health-product petitions — RDC 743 subject-specific clocks govern in practice
- Clinical evidence mandatory
- 10 year validity
- Clinical Trial Required
Yes
Maintained reference · planning ranges remain estimates · reviewed 2026-08-30
BrazilSource authority not specified Regulatory reference
Reliance does not bind ANVISA: ANVISA decides the Brazilian petition independently of the decision issued by the reference authority (AREE).
Conditions
- Applies to the optimized procedure under RDC 741/2022.
Effective from 2022-09-01
Regulatory reference
Japan Ministry of Health, Labour and Welfare (MHLW) pre-market approval (Shonin) is the accepted Japanese reference authorization under the optimized review procedure.
Conditions
- Requires authorization by at least one listed AREE and essentially identical device/indications (IN 290/2024 Art. 7º).
- Applies to class III/IV primary registration petitions (IN 290/2024 Art. 2º).
Effective from 2024-06-03
Correction: the official IN 290/2024 list names only 'Japan Ministry of Health, Labour and Welfare (MHLW) - Pre-market approval (Shonin)'. PMDA and the Ninsho category are not named in the Brazilian list.
Regulatory reference
- Statement
ANVISA's optimized (reliance) review for Class III/IV device registration under RDC 741/2022 is available only for devices previously authorized by an AREE listed exhaustively in IN 290/2024 Art. 6: TGA (ARTG), Health Canada (Medical Device Licence), US FDA (510(k)/PMA/De Novo) and Japan MHLW (Shonin). China's NMPA is not listed, so an NMPA registration certificate gives no access to the optimized procedure and the ordinary route (RDC 751/2022 / RDC 830/2023) applies.
- Source Jurisdiction Id
china
- Source Approval
China NMPA medical device registration certificate (Class II/III) or Class I filing record
- Target Jurisdiction Id
brazil
- China Classes In Scope
NMPA Class II/III certificates and Class I filings; target: ANVISA Class III/IV registration (optimized procedure)
- Edge Type
No Reliance Route
- Market Access Strength
none
- Regulatory Layer
Product Marketing
- Local Application Required
Yes
- Target Decision Retained
Yes
Conditions
- Art. 7 I: device must be authorized by at least one AREE listed in Art. 6
- Art. 7 II: AREE document must refer to an essentially identical device
- Art. 13: ANVISA retains independent decision
- Independent verification is incomplete. Treat this record as a research lead, not a confirmed benefit or exclusion; see the 2026-09-15 independent review.
Effective from 2024-06-03
Source passage: Art. 6º Para fins de adoção do procedimento otimizado de análise são consideradas as seguintes AREE e respectivas comprovações de registro ou autorização: I - Austrália: Australia Therapeutic Goods Administration (TGA) - Australian Register of Therapeutic Goods (ARTG); II - Canadá: Health Canada (HC) - Medical Device Licence; III - Estados Unidos da América (EUA): US Food and Drug Administration (US FDA) - 510(k) Clearance, Premarket Approval (PMA) ou 513(f)(2) "De Novo"; e IV - Japão: Japan Ministry of Health, Labour and Welfare (MHLW) - Pre-market approval (Shonin).
Prior approval / evidence record
Class III
- Verification Status
official-verified
- Official Source
- Title
ANVISA RDC 743/2022 — analysis deadlines per subject and act (Anexo)
- Url
https://anvisalegis.datalegis.net/action/ActionDatalegis.php?acao=abrirTextoAto&tipo=RDC&numeroAto=00000743&seqAto=000&valorAno=2022&orgao=RDC/DC/ANVISA/MS&cod_modulo=310&cod_menu=9434
- Prior Approval Benefits
- FDA 510(k)/PMA (via IN 290/2024)
- MDSAP for B-GMP
- Notes
- RDC 743/2022 Anexo: equipment registration 250 days, materials Risk III registration 320 days (no tacit approval for Risk III materials), IVD 365 days
- Lei 6.360/1976 Art. 12 §3º separately binds ANVISA to 90 days for health-product petitions — RDC 743 subject-specific clocks govern in practice
- B-GMP certificate mandatory
- 10 year validity
- Clinical Trial Required
No
Maintained reference · planning ranges remain estimates · reviewed 2026-08-30
Prior approval / evidence record
MDSAP B-GMP validity extension (RDC 850/2024)
- Name
MDSAP B-GMP validity extension (RDC 850/2024)
- Description
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.
- Timeline Reduction
4 years of B-GMP validity instead of 2, so one renewal cycle removed
- Eligibility
- Manufacturer participates in MDSAP
- Participation maintained throughout the validity of the certificate
Maintained reference · planning ranges remain estimates · reviewed 2026-08-30
Prior approval / evidence record
NMPA-ANVISA cooperation MoU (2020): no recognition effect
reliance.china-nmpa-bilateral-programme
Pending verification↗- Statement
NMPA Commissioner Jiao Hong and ANVISA Director-President Antonio Barra Torres signed a Memorandum of Understanding on cooperation on 26 November 2020 covering information exchange in the regulation of drugs, medical devices and cosmetics. ANVISA's official cooperation page lists the 'Memorando de Entendimento entre Anvisa e NMPA' under China, and a separate BRICS regulators' MoU. Neither instrument creates recognition of NMPA registrations; they are information-exchange frameworks.
- Source Jurisdiction Id
china
- Source Approval
China NMPA medical device registration certificate (Class II/III) or Class I filing record
- Target Jurisdiction Id
brazil
- China Classes In Scope
All device classes (framework MoU; no product-level effect)
- Market Access Strength
none
- Regulatory Layer
Product Marketing
- Local Application Required
Yes
- Target Decision Retained
Yes
Conditions
- Information exchange only; no reliance or mutual recognition of registrations
- ANVISA also lists a BRICS (RU/IN/CN/ZA) regulators' MoU
- Independent verification is incomplete. Treat this record as a research lead, not a confirmed benefit or exclusion; see the 2026-09-15 independent review.
Effective from 2020-11-26
Source passage: The National Medical Products Administration (NMPA) Commissioner Jiao Hong signed a memorandum of understanding (MoU) on cooperation with Antonio Barra Torres, head of the Brazilian health regulatory agency ... on Nov 26. ... have agreed to further strengthen information exchanges in regulation of drugs, medical devices and cosmetics under the framework of the MoU
Regulatory reference
GMP reliance: a CBPF certificate based on an audit performed under the Medical Device Single Audit Program (MDSAP) is valid for 4 years, versus 2 years for the standard certificate.
Conditions
- RDC 497/2021 Art. 8º §1º, inserted by RDC 850/2024 (20 March 2024).
- ANVISA's Confiança Regulatória page additionally lists MDSAP auditing organizations and MERCOSUL member-state authorities as reference authorities for GMP.
Effective from 2024-03-20
CBPF renewal petition window: between 270 and 180 days before certificate expiry (Art. 37), with renewal granted automatically if ANVISA does not decide (Arts. 38-39).
Regulatory reference
Australia Therapeutic Goods Administration (TGA) listing on the Australian Register of Therapeutic Goods (ARTG) is accepted under the optimized review procedure for class III/IV device registration.
Conditions
- Requires authorization by at least one listed AREE and essentially identical device/indications (IN 290/2024 Art. 7º).
- IN 290/2024 Art. 2º: applies to class III/IV primary registration petitions.
- ANVISA decides independently (RDC 741/2022 Art. 13).
Effective from 2024-06-03
Framework: RDC 741/2022 (in force 1 September 2022) + IN 290/2024 (in force 3 June 2024).
Prior approval / evidence record
MDSAP
- Benefit
Audit reports substitute for the inspection report at B-GMP certification and extend the certificate to 4 years, but RDC 687/2022 Art. 14 keeps ANVISA free to inspect on site at any time, including during the certificate validity
- Timeline Savings
Removes the wait for an ANVISA inspection slot
Maintained reference · planning ranges remain estimates · reviewed 2026-08-30
Regulatory reference
US FDA marketing authorizations accepted under the optimized review procedure: 510(k) Clearance, Premarket Approval (PMA), or 513(f)(2) De Novo.
Conditions
- Requires authorization by at least one listed AREE and essentially identical device/indications (IN 290/2024 Art. 7º).
- Applies to class III/IV primary registration petitions (IN 290/2024 Art. 2º).
- ANVISA decides independently (RDC 741/2022 Art. 13).
Effective from 2024-06-03
Regulatory reference
Health Canada Medical Device Licence is accepted under the optimized review procedure for class III/IV device registration.
Conditions
- Requires authorization by at least one listed AREE and essentially identical device/indications (IN 290/2024 Art. 7º).
- Applies to class III/IV primary registration petitions (IN 290/2024 Art. 2º).
- ANVISA decides independently (RDC 741/2022 Art. 13).
Effective from 2024-06-03
Prior approval / evidence record
FDA 510(k)/PMA/De Novo
- Authority
FDA 510(k)/PMA/De Novo
- Benefit
Recognised AREE for IN 290/2024 optimized analysis of Class III and IV registrations
- Timeline Savings
None published — Art. 10 preserves queue position
Maintained reference · planning ranges remain estimates · reviewed 2026-08-30
BrazilUS FDA · Australia TGA · Health Canada · Japan MHLW / PMDA · Brazil ANVISA Prior approval / evidence record
Optimized analysis (procedimento otimizado, IN 290/2024)
- Name
Optimized analysis (procedimento otimizado, IN 290/2024)
- Description
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.
- Timeline Reduction
No published reduction — the RDC 743/2022 deadlines still apply and Art. 10 preserves queue position
- 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)
Maintained reference · planning ranges remain estimates · reviewed 2026-08-30
Prior approval / evidence record
TGA (Australia)
- Benefit
Recognised AREE for IN 290/2024, evidenced by the ARTG entry
- Timeline Savings
None published
Maintained reference · planning ranges remain estimates · reviewed 2026-08-30