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Editor's note: This article was originally published on December 18, 2024, and was updated on March 3, 2025, as per the latest developments. The updated contents are marked in red below.
On December 17, 2024, Brazil issued the Resolution No. 951/2024, introducing a new notification system for personal hygiene products, cosmetics, perfumes, and disposables, initially set for implementation on March 3, 2025.1 On February 28, 2025, Brazil announced Resolution No. 965/2025, delaying the implementation to April 7, 2025, and revising the transitional policy timelines.2
To enter the Brazilian market, personal hygiene products, cosmetics, and perfumes are required to complete a regularization process. To be specific, products listed in Article 34 of Resolution RDC No. 907/2024 shall complete a pre-market registration, while others are subject to a notification. Upon completion, a process number will be assigned, which shall be displayed on the product label.
Currently, product notifications are submitted through the Electronic Cosmetics Automation System (SGAS). With the implementation of Resolution No. 951/2024 on April 7, 2025, all new notifications for personal hygiene products, cosmetics and perfumes shall be filed via the Solicita petitioning system, also referred to as Datavisa. To facilitate a smooth transition, the Resolution sets transitional policies for product notification and labelling, as outlined below.
1) Product Notification
For products notified in SGAS, their records shall be migrated using the electronic migration form available on the portal of the Brazilian Health Regulatory Agency (Anvisa). Key dates and obligations are as follows:
Starting April 7, 2025, companies responsible for product regularization shall complete the migration within the validity period of the original notification. Failure to do so may result in penalties, or cancellation of the notification. Upon migration, products will be granted a new 10-year notification period, effective from the publication date on the Anvisa portal.
From April 7, 2025, any modifications to product notifications previously submitted in SGAS shall be made through the new system, using the migration form mentioned above. These modifications will be regarded as equivalent to the migration.
Until December 31, 2025, companies responsible for product regularization can still declare their interest in the continued commercialization of notified products in SGAS. However, from January 1, 2026, this declaration shall be made exclusively through the migration.
2) Product Labelling
Upon migration, the Solicita petitioning system will assign a new process number, replacing the one previously issued by SGAS. However, companies may continue using labels with the SGAS process number for product manufacturing during the transitional periods specified in the table below.
Migration Date | Transitional Periods |
From April 7, 2025, to December 31, 2026 | 6 years |
From January 1, 2027, to December 31, 2028 | 4 years |
Since January 1, 2029 | 2 years |
Notes: 1) The migration date to the Solicita petitioning system, as published on the Anvisa portal, will mark the beginning of transitional periods; 2) The transitional periods are applicable solely to labels that are in full compliance with the regulations governing the product category; 3) Products manufactured within transitional periods are permitted to include both SGAS and Solicita system process numbers on their labels until the expiration of their validity. | |
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