Cancelamento de Registro — Registration Cancellation
Cancelamento de Registro (registration cancellation) is ANVISA's most severe pre-market enforcement action — the permanent revocation of a device's marketing authorisation in Brazil.
When ANVISA may cancel a registration
ANVISA may initiate cancelamento de registro when:
- The registered device is found to present an unacceptable risk to public health that cannot be adequately mitigated;
- The registration holder has materially misrepresented information in the registration dossier;
- The device is no longer manufactured, imported or available and the registration holder requests cancellation;
- The registration holder has not complied with ANVISA's compulsory recall order after repeated notices;
- The GMP certificate (CBPF) has lapsed and cannot be renewed; or
- The AFE of the registration holder has been permanently cancelled.
Process for cancellation
- ANVISA initiates a formal administrative proceeding (processo administrativo) and formally notifies the registration holder in writing of the intent to cancel and the specific grounds.
- The registration holder has the right to present a defence.
- ANVISA's collegiate board issues a decision.
- If cancellation is upheld, it is published in the Diário Oficial da União (DOU).
- The registration holder must immediately cease distribution and implement a recall of all stock.
- The registration holder may appeal through the administrative appeals process and, ultimately, judicial review.
Official sources
Verify all information against official ANVISA sources before making regulatory decisions.
"Any devices manufactured and distributed under the cancelled registration remain subject to post-market surveillance requirements, and customers must be notified of the cancellation status. Devices cannot be legally sold or distributed after the cancellation date, regardless of when they were manufactured."