Brazil ANVISA Registration vs Notification: Product Classification

Quick overview

Source review: October 19, 2026 · For: Brands, manufacturers and regulatory teams evaluating individual cosmetic SKUs for Brazil.

A common oversimplification is that Grau 1 cosmetics do not require registration and Grau 2 cosmetics always do. In practice, ANVISA distinguishes *products requiring registration (registro) from products exempt from registration but subject to notification (notificação or comunicação prévia)*. The familiar Grau 1/Grau 2 terms and the petition route should be reviewed as separate questions.

1. Which products currently require ANVISA registration?

Official requirement: ANVISA publishes a list of categories requiring registration. Products outside that list generally take the notification pathway, provided they meet the legal definition of cosmetics and no category-specific rule changes the analysis. [BR-S01]

• ANVISA registration category: Tanning products (bronzeador) / Primary classification question: Intended tanning function versus ordinary skin-care claims
• ANVISA registration category: Antiseptic hand gel / Primary classification question: Antiseptic or antimicrobial intended use
• ANVISA registration category: Hair-straightening products / Primary classification question: Chemical function, active ingredients and safety evidence
• ANVISA registration category: Products that straighten and color hair / Primary classification question: Dual-function product and corresponding requirements
• ANVISA registration category: Hair-curling products / Primary classification question: Chemical alteration of the hair shape
• ANVISA registration category: Sunscreen / Primary classification question: SPF/UVA claims and dedicated substantiation
• ANVISA registration category: Children's sunscreen / Primary classification question: Sun protection for children and age-related precautions
• ANVISA registration category: Insect repellents / Primary classification question: Skin-applied repellency claims and efficacy support
• ANVISA registration category: Children's insect repellents / Primary classification question: Repellency, target ages and warnings

ANVISA's examples of registration-exempt products include deodorant, shampoo, soap, nail polish and perfume. Those examples are not a substitute for reading the real intended use and labeling. For instance, a product presented in marketing as a “cleansing gel” should not be assumed to follow ordinary skin-care notification if it is in fact an antiseptic hand gel. [BR-S01]

2. Does Grau 2 mean that registration is mandatory?

No. Grau 1 and Grau 2 refer to the product's risk and use characteristics in the broader cosmetics classification framework. A Grau 2 product may raise heightened labeling, safety or performance-evidence questions, but it is not automatically one of the categories on ANVISA's mandatory-registration list. Record risk classification, administrative route and any special rules separately. [BR-S01][BR-S02]

A product with an anti-wrinkle or anti-dandruff claim may require claim substantiation or additional analysis. That does not alone show it is on the mandatory registration list. Conversely, a sunscreen does not become a notification product merely because a similar SKU took a simplified route in another market.

3. Which regulation and filing system should be used in 2026?

Regulation: RDC 907/2024 consolidated Brazil's requirements for cosmetic definitions, classification, labeling and packaging, microbiological parameters and regularization procedures. ANVISA's 2024 consolidation notice identifies it as replacing RDC 752/2022. An older FAQ may still quote the superseded number; do not build current filing instructions around that citation. [BR-S02]

Filing system: From April 7, 2025, ANVISA moved new petitions and relevant changes for registration-exempt cosmetics to Solicita/Datavisa. Its announcement identifies petition codes including 2726 (notification), 2727 (migration), 2728 (cancellation), 2729 (continuation of commercialization) and 2730 (notification amendment). Use these as evidence of the migration, and confirm the currently available petition item in the actual system at filing. [BR-S03]

An old SGAS workflow screenshot is not a reliable operating procedure for a new notification in 2026.

4. How does registration differ from notification in practice?

• Workstream: Classification / Notification product: Confirm the exempt category and intended use / Registered product: Confirm a mandatory registration category
• Workstream: Formula review / Notification product: Assess compliance with applicable ingredient requirements / Registered product: Assess compliance plus any category-specific conditions
• Workstream: Label and claims / Notification product: Keep appropriate evidence and compliant labeling / Registered product: Keep evidence and meet any special label/test requirements
• Workstream: Submission / Notification product: Current Solicita/Datavisa notification petition / Registered product: Applicable registration petition and its current checklist
• Workstream: Technical documents / Notification product: Separate petition information from retained supporting evidence / Registered product: Prepare application-specific uploads and supporting evidence
• Workstream: Regulatory outcome / Notification product: Record completion of the applicable notification process / Registered product: Do not treat filing as approval; verify the formal authorization/publication

This is a working comparison, not a fixed list of documents that every company must upload. Requirements vary by product and petition item. [BR-S01][BR-S03][BR-S09]

5. A six-step SKU classification workflow

• Control the product list. Record SKU, shades, variants, formula versions and planned labels.
• Describe actual use. Capture application site, frequency, target user and claimed results, not only the brand's commercial category.
• Review the Portuguese-facing claims. Include packaging, website and retailer listing claims in the decision.
• Compare with the current ANVISA registration list. Record any listed category and the relevant special rules.
• Screen formula-specific concerns. Sunscreen, children's use, chemical hair treatments and antiseptic or repellent claims warrant specific attention.
• Issue a traceable classification memo. Include review date, source, interpretation and open questions for each SKU.

6. Four classification mistakes to avoid

• Equating Grau 2 with mandatory registration. They answer different questions.
• Treating notification as prior technical approval of the formula. Company responsibilities continue.
• Transferring another market's product classification unchanged. Brazilian definitions and special rules still apply.
• Treating a registration submission number as evidence of approval. Check the formal regulatory status before commercialization.

Frequently asked questions

Does ordinary shampoo require registration? ANVISA lists shampoo among examples generally exempt from registration. Confirm the actual purpose, formula and claims of the individual product. [BR-S01]

Do all children's products require registration? That would be too broad. The official list specifically includes children's sunscreen and children's repellents. Other products must still be analyzed under their own definitions and applicable requirements. [BR-S01]

Do notification products need supporting tests? They may, depending on product risks and claims. A simplified administrative path does not make safety, quality and truthful claims optional.

Who files the petition? The filing arrangement depends on the Brazilian product holder and approved business structure. See importer AFE and local roles.