Mandatory INMETRO Certification for These Products Effective Dec 31: Full Analysis of Brazil’s Regulatory Updates
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Time:2026-08-21 15:43:43


In 2026, Brazil’s ANVISA is undergoing regulatory upgrades at a remarkable pace. This article provides a complete breakdown of key changes within Brazil’s medical device regulatory framework for 2026‑2027, helping stakeholders identify trends, calculate compliance costs and make adequate preparations.




https://saude.es.gov.br/Media/sesa/Legisla%C3%A7%C3%A3o/Outros/Instru%C3%A7%C3%A3o%20Normativa%20-%20IN%20n%C2%BA%20283,%20de%2007_03_2024.pdf


一、Expansion of Mandatory INMETRO Certification



Important Note:Enforcement starts on 31 December 2026. Valid ANVISA registration does not grant exemption.
Brazil adopts a dual‑regulatory model: ANVISA governs marketing authorisation, while INMETRO administers product conformity assessment. For certain medical devices, an INMETRO certificate must be obtained prior to applying for ANVISA registration. Customs will verify certificates during import clearance; shipments lacking valid documentation will be detained.

(一)Scope of Covered Products
Pursuant to IN Normative Instruction No. 283 dated 7 March 2024, personal hygiene support aids including commode chairs, shower chairs and toilet risers will fall under mandatory INMETRO conformity assessment as of 31 December 2026. Products shall undergo testing in compliance with ISO 17966:2016.

Thirty‑one medical device categories in total will be subject to mandatory requirements, covering dialysis equipment, neonatal care devices, patient monitors, dental equipment, respiratory support devices, wheelchairs and hygiene aids.


Specific product list as below:

(二)Key Procedures for INMETRO Certification
  • Map applicable regulations & standards and complete product‑family classification
  • Appoint a local Brazilian authorised representative with medical‑device import qualifications
  • Select an OCP certification body accredited by INMETRO
  • Submit application documents and undergo technical‑file review
  • Conduct factory audit plus product sampling for type‑testing
  • Resolve non‑conformities, pass final review and obtain certification; gain authorisation to apply the conformity mark
  • Maintain certificate validity: surveillance audits shall be performed at least every 15 months

Important Risk Reminder: Even for products holding existing ANVISA registration certificates, valid INMETRO certificates must still be presented for import clearance after 31 December 2026. If an INMETRO certificate expires, the corresponding ANVISA registration shall become invalid concurrently.

Timelines for enterprises are tight. Certification includes laboratory testing and factory audits. Enterprises are advised to launch assessments immediately to avoid end‑of‑year application backlogs that may block product shipments.


二、Proposed Mandatory MDSAP



Under ANVISA’s 2026‑2027 Regulatory Agenda (Ordinance No. 1.484/2025, effective 1 January 2026), amendments will be made to RDC No. 687/2022. The plan is to make MDSAP audits compulsory for overseas medical‑device manufacturers as the primary or even sole pathway for GMP certification.

MDSAP remains voluntary in Brazil at present, yet it has already achieved de‑facto semi‑mandatory status. Since 2024, more than half of Brazil’s GMP certificates have been issued via the MDSAP route, making MDSAP the mainstream market‑access pathway.


三、Launch of SIUD — Brazil’s National UDI Database



On 18 February 2026, ANVISA issued Normative Instruction No. 426/2026, setting operational rules for SIUD (Sistema de Informação de Identificação Única de Dispositivos Médicos), Brazil’s national UDI database. This normative instruction entered into force on 1 March 2026.

SIUD serves as Brazil’s domestic UDI digital platform, comparable with FDA’s GUDID and the EU’s EUDAMED. It constitutes the core operational implementation vehicle for UDI regulation RDC No. 591/2021.


(一)Two Distinct Timelines Must Be Distinguished
UDI compliance consists of two independent mandatory timelines for labelling marking and database submission, which shall not be confused.
UDI labelling / packaging marking deadlines (stipulated in RDC No. 591/2021):
  • Class IV (highest risk): 10 July 2025 (already in force)
  • Class III (high risk): 10 January 2026 (already in force)
  • Class II (moderate risk): 10 January 2027
  • Class I (low risk): 10 January 2028

Mandatory submission deadlines for the SIUD database:
  • Class IV: 1 September 2029
  • Class III: 1 March 2030
  • Class II: 1 March 2031
  • Class I: 1 March 2032
Voluntary data submission is allowed prior to each mandatory deadline. Please note that UDI‑marking obligations for Class IV and Class III devices are already legally binding. Enterprises which have not completed UDI coding and label adjustments are already non‑compliant.

(二)Core Operational Rules

UDI data must be submitted to SIUD before products are placed on the Brazilian market. The Brazilian Registration Holder (BRH) or domestic Brazilian manufacturer may authorise third‑party agents for submission; however, legal liability remains with the BRH.


四、WHO Recognition



On 1 July 2026, WHO released the first batch of the Transitional List of WHO‑Recognised Authorities for Medical Devices (tWLAs‑MD), which includes Brazil’s ANVISA.

Practical implications for enterprises: tWLAs‑MD delivers a WHO‑endorsed regulatory‑reliance signal. Assessment conclusions issued by listed authorities may be referenced by other jurisdictions to streamline review procedures. This framework does not constitute automatic mutual recognition. Each state retains full sovereignty over product approvals, yet formal foundations for global regulatory coordination are established.


五、2026‑2027 Regulatory Updates



ANVISA’s official 2026‑2027 Regulatory Agenda contains 161 priority topics, of which 14 relate to medical devices. Beyond the measures listed above, key developments include:
SaMD Regulatory Revision:Update regulatory pathways and classification criteria for Software‑as‑a‑Medical‑Device
Modernisation of Vigilance System:Revise adverse‑event‑related regulations and strengthen reporting obligations for registration holders
Strengthened IVD Regulation:Formulate dedicated provisions for in‑vitro‑diagnostic devices subject to pre‑market review
Special Review Track for Innovative Medical Devices:Establish dedicated assessment pathways for innovative medical devices

Deepened International Cooperation:Sign bilateral cooperation agreements with China NMPA, South Korea MFDS and other authorities; participate intensively in global regulatory harmonisation.


六、Closing Remarks



For Chinese enterprises, Brazil represents far more than a standalone growth market. It functions as a strategic hub covering Latin America and connecting to global regulatory‑reliance networks. For further information, please consult Wiselink.


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