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BR

Classification in Brazil

RDC 751/2022 brought Brazil much closer to the international rule set, which makes classification tractable — and leaves registration as the hard part.

The framework

AUTHORITY
ANVISA
INSTRUMENT
RDC 751/2022
MARKET ACCESS
ANVISA registration or notification
APPROACH
Rules cascade
ON MDCLASSIFY
The engine for this market is implemented. Classify a device and the result appears alongside the EU class.

How it differs from the EU

Brazil's classification rules were substantially aligned with international practice by RDC 751/2022, so the cascade behaves in ways a European regulatory professional will recognise. That alignment is genuine and it is the good news. The difficulty in this market sits elsewhere: registration with ANVISA is documentation-heavy, requires a local registration holder, and the route depends on the class — the lower two classes are notified, the upper two registered, with materially different timelines. Getting the class right early therefore changes the project plan more than it changes the technical file.

Why the class does not simply transfer

Four classes, I to IV, on the international pattern rather than the European one. As with Canada, the shared Roman numerals invite a mapping that does not hold: the Brazilian scale has an extra step relative to the EU labels, and the boundary between notification and registration falls between II and III with no European counterpart.

NOTE —

RDC 751/2022 transposes Annex VIII rule for rule, so the reasoning carries across; what does not carry is the label. Brazilian Class III is the equivalent of European Class IIb, and Class IV of European Class III. Two Brazilian provisions have no European counterpart: Regra 16 classifies artificial tears and ophthalmic lubricants as Class III, and Regra 18 states the intact-skin exception without restricting it to material of animal origin.

The classes

CLASSRISKINDEPENDENT REVIEW
ILowNotification
IIMedium-lowNotification
IIIMedium-highRegistration
IVHighRegistration

Common questions

How are medical devices classified in Brazil?

Under RDC 751/2022, in four classes from I to IV. The rules were aligned much more closely with the international rule set than the framework they replaced.

What does the class change in Brazil?

Whether the device is notified or registered with ANVISA, and how much documentation that requires. Classes I and II are notified; Classes III and IV are registered, with longer timelines.

Do I need a local presence in Brazil?

A local registration holder is required. This is independent of the device's class and applies to manufacturers outside Brazil.

Classify a device

The questionnaire classifies under the EU MDR and reports the Brazil class alongside it, with the rules that produced each. Tick this market when you start.

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