Brazil’s UDI Update: ANVISA plans major medical device registration updates

by Ashley Howell | September 25, 2022 | Blog

Brazil’s medical device market regulator, ANVISA announced major updates to its Resolution of the Collegiate Board of Directors (RDC) 185/2001.  The changes will serve to strengthen the country’s medical device registration regulations upon their effective date of March 1, 2023. 

The updates (link in Portuguese) to RDC No. 185/2001 further define the rules for classifying the risk of medical devices, the requirements for labeling and instructions for use and the procedures for notification or registration of medical devices. 

The resolution’s major changes include: 

  • Adoption of specific classification rules for new technologies including software as a medical device (SaMD) and nano-materials. The updated classification rules generally align with EU MDR classifications. 
  • Consolidation of notification, registration and change rules in a single RDC. 
  • Incorporation of rules for the Documentary Repository of Medical Devices. Note: this requires uploading the Instructions for Use (IFUs) to an ANVISA portal. 
  • Incorporation of rules for IFU format. 
  • Adoption of the Table of Contents structure (IMDRF’s Table of Contents) for Technical Dossiers, enabling the use of dossiers prepared for multiple jurisdictions.
  • Forecasting situations for depletion of finished products, packaging, labels and IFUs.
  • Formalization of the procedural reassessment process.
  • General modernization of the text and updating of terminology. 

 

What changes can a medical device manufacturer doing business in Brazil expect? 

Medical device manufacturers doing business in Brazil should review the changes in this update and access the risk classification, procedures, specifications, and notification process.  

 

How will the new resolution affect how risk classification works? 

Medical devices will be classified according to the level of risk they present to the patient and the regulatory process will change as the risk level increases. 

The risk classifications are: 

  • I – Low risk
  • II – Medium risk
  • III – High risk 
  • IV – Maximum risk 

 

Medical devices classified in risk classes I and II are subject to notification as per Article 6 of the resolution.  Medical devices classified in risk classes III and IV are subject to registration, per Article 7 of the resolution. 

 

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