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Brazil ANVISA Registration Trends and Market Access Data (2024-2025)

Original analysis of 111,000+ ANVISA medical device registrations, showing Brazil market trends, leading registration holders, category shifts, and market entry strategy.

Ran Chen
Ran Chen
Global MedTech Expert | 10× MedTech Global Access
Published 2026-04-13Last reviewed 2026-04-1339 min read

Executive Summary

Brazil's medical device market is experiencing unprecedented growth. Our original analysis of the complete ANVISA medical device registration database — covering 111,789 records, 96,881 unique registrations, 4,118 registration holders, and 12,412 manufacturers across 88 countries — reveals a market that is not only expanding in volume but fundamentally reshaping in structure.

In 2025, ANVISA processed 10,639 new registration records, the highest annual total in the agency's history and a 16.2% year-over-year increase from 2024. The number of active registration holders reached 1,578, a figure that has nearly tripled since 2010. China has surpassed the United States as the leading country of origin for medical devices registered in Brazil, and an entirely new class of market entrants is redefining how foreign manufacturers access this $10+ billion market.

This article presents the first publicly available, data-driven analysis of the Brazilian medical device regulatory landscape at this depth. Every chart, table, and statistic in this article is derived from our direct analysis of ANVISA's official registration database.


1. The Brazilian Medical Device Market: Why It Matters

Brazil is the largest medical device market in Latin America and the fourth-largest in the Americas. Key indicators:

  • Population: 215+ million, with ~75% relying exclusively on the public SUS system

  • Healthcare expenditure: $135 billion (~9.7% of GDP)

  • Medical device imports: $9.33 billion in 2024 (18% YoY growth)

  • 4-year import growth: 54% cumulative increase from $6.07B in 2021

  • Projected domestic market: $7.3B by 2028 at 5.1% CAGR

  • Import dependency: ~50% of medical devices consumed in Brazil are imported

For medical device manufacturers looking to expand internationally, Brazil represents a market that is too large to ignore — but also too complex to enter without a deliberate strategy. ANVISA's regulatory requirements, the mandatory Brazilian Registration Holder (BRH) structure, GMP certification via B-GMP or MDSAP, and Portuguese-language documentation requirements create a significant barrier to entry that rewards careful planning and the right local partner.


2. ANVISA Registration Volume: A Decade of Growth

Our analysis of the ANVISA database reveals a clear secular growth trend in medical device registrations. The data tells a story of a market that has grown substantially from approximately 4,000 annual registrations in 2014 to over 10,000 in 2025.

ANVISA Medical Device Registrations by Year (2005-2025)

Key Volume Metrics (2020–2025)

YearTotal RecordsUnique RegistrationsActive HoldersYoY Growth
20208,7117,4901,280+5.7%
20217,7676,6441,301-11.3%
20227,0546,2371,238-6.1%
20238,3937,3621,282+18.0%
20248,9627,9211,446+7.6%
202510,6399,2071,578+16.2%

The 2020 surge was driven by COVID-related PPE and diagnostic registrations (the "CORONAVÍRUS" product category alone accounts for 933 registrations). Post-pandemic normalization in 2021–2022 was followed by strong recovery, with 2025 setting an all-time record. Two structural drivers explain this sustained growth:

  1. Regulatory modernization: ANVISA has actively reduced its registration backlog, expanded staffing, streamlined submission processes, and begun deploying its own AI system ("AnvisAI") to accelerate reviews.

  2. Market entry by new players: 636 new registration holders entered the Brazilian market for the first time in 2024-2025, bringing fresh product portfolios and competitive energy.

Breaking the data into quarterly intervals reveals more granular patterns that annual totals obscure:

QuarterRecordsUnique RegsActive HoldersClass IClass IIClass IIIClass IV
2023-Q11,9141,635548486847342239
2023-Q22,0321,791580527976396133
2023-Q32,2201,9796206601,034312214
2023-Q42,2271,957634703957373194
2024-Q12,0851,8706325821,048275180
2024-Q21,9431,752605641865284153
2024-Q32,5662,2787557361,175455200
2024-Q42,3682,021678645917551255
2025-Q12,5862,2797066831,204526173
2025-Q22,6232,2517136991,090574260
2025-Q32,9512,5587847371,333556325
2025-Q42,4792,1197525861,096548249
2026-Q12,2642,0176427041,001343216

Q3 2025 was the strongest single quarter in ANVISA history: 2,951 records and 2,558 unique registrations, with 784 active holders — all record highs. The Q3 strength is consistent across both 2024 and 2025, suggesting a structural pattern where the third quarter consistently sees peak registration activity. Manufacturers planning their submission timelines should be aware that Q3 may see longer queue times.

The quarterly data also reveals a notable shift in risk class composition. Class III registrations jumped from an average of ~330/quarter in 2023 to ~550/quarter in Q3-Q4 2024 and Q1-Q2 2025 — a 67% increase — reflecting growing demand for more complex device registrations.

Monthly Seasonality Patterns

Our monthly breakdown reveals consistent seasonality in ANVISA registration activity. The strongest months are typically March, June, September, and December — coinciding with quarterly planning cycles and ANVISA's own internal review deadlines. Manufacturers planning submissions should account for this pattern, as peak months may see longer review queues.


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3. Risk Class Distribution: Where the Growth Is

ANVISA classifies medical devices into four risk classes (I through IV), mirroring the complexity and risk profile of each device. Our analysis reveals the current distribution across all 111,789 records:

Risk Class Distribution

Overall Distribution

Risk ClassRecordsShareDescription
Class I36,55332.7%Low risk (e.g., bandages, manual surgical instruments)
Class II46,39841.5%Medium risk (e.g., catheters, endoscopes, dental devices)
Class III18,62116.7%High risk (e.g., orthopedic implants, IVDs)
Class IV10,2179.1%Highest risk (e.g., cardiovascular implants, pacemakers)

Class II devices dominate the market at 41.5%, reflecting the broad range of medical devices in this risk category — from powered surgical instruments and endoscopy equipment to dental products and diagnostic instruments.

Risk Class Trends Over Time

The stacked area chart reveals that while Class I and II devices continue to dominate in absolute numbers, Class III registrations have been growing fastest in recent years:

Risk Class20202025Growth
Class I2,6952,705+0.4%
Class II3,4984,723+35.0%
Class III1,9092,204+15.5%
Class IV6091,007+65.4%

The accelerated growth in Class III and IV registrations is significant. These higher-risk devices require more extensive regulatory review, clinical evidence, and post-market surveillance — creating higher barriers to entry but also higher commercial value. For registration holders and regulatory consultants, this shift implies a growing demand for expertise in complex submissions.


4. Country of Origin: The Shift Toward Asia

Perhaps the most striking finding in our analysis is the dramatic shift in the geographic origin of medical devices registered in Brazil. China has now firmly established itself as the #2 source of medical device registrations, surpassing the United States in annual volume since 2020.

Top 10 Countries of Origin

All-Time Top 10 Countries of Origin

RankCountryRecordsUnique RegsUnique Mfgs
1Brazil31,22431,1702,169
2China19,24819,1223,152
3United States15,86815,2482,079
4Germany8,4078,364837
5Italy2,4122,410391
6France2,0732,070325
7India2,0322,009281
8South Korea1,9391,939459
9Switzerland1,6841,657221
10United Kingdom1,4371,430209

Note that China's manufacturer diversity is significantly higher than any other country: 3,152 unique manufacturers versus 2,079 from the US and 2,169 from Brazil. This indicates a highly fragmented Chinese medical device manufacturing landscape, with many small-to-medium manufacturers each producing specialized product lines.

The China-US Divergence

China vs USA Registration Trend

The trend lines reveal a clear structural shift:

YearChinaUSAGermanyBrazil (domestic)
20156991,2834692,215
20188401,0164051,920
20201,5931,2575162,374
20221,6356713432,171
20232,0607844202,311
20242,4457874622,555
20253,1517734282,900

In 2025, China-origin registrations (3,151) exceeded US-origin registrations (773) by a factor of more than 4:1. This is not merely a COVID-era anomaly — it reflects fundamental manufacturing economics and the rise of Chinese medical device companies seeking international markets. Meanwhile, US-origin registrations have plateaued around 700–800 per year since 2022, down significantly from their 2008 peak of approximately 1,250.

India is another country showing consistent growth — from 162 registrations in 2020 to 290 in 2025, a 79% increase over five years. India, South Korea, and Turkey are the emerging origin countries to watch.


5. Who Holds the Registrations: The BRH Landscape

In Brazil, foreign medical device manufacturers cannot register products directly with ANVISA. They must work through a Brazilian Registration Holder (BRH) — also known as a Detentor de Registro — which is a locally established entity that holds the registration on behalf of the manufacturer. This BRH requirement creates a unique market structure where a relatively small number of specialized companies serve as gatekeepers for international market access.

Our database contains 4,118 unique registration holders. However, the market is highly concentrated: the top 50 holders control a disproportionate share of all registrations.

Top 15 Registration Holders (All Time)

RankRegistration HolderUnique RegsUnique MfgsCountriesActive Since
1VR Medical2,377389312005
2Siemens Healthcare Diagnósticos1,37873171997
3Roche Diagnóstica Brasil1,02448112003
4Auto Suture do Brasil (Medtronic)972103191998
5Abbott Laboratórios88255111996
6Passrod Importação711134282018
7Emergo Brazil Import (UL)666253342010
8Stryker do Brasil64160112000
9Cirúrgica Fernandes640189281994
10Vyttra Diagnósticos63546122018
11ArgosLab62081112010
12Johnson & Johnson Brasil58195161994
13Laboratórios B. Braun51759161994
14QR Consulting51138102016
15Beckman Coulter do Brasil48931161995

This table reveals two distinct types of BRH:

  1. Brand subsidiaries (Siemens, Roche, Abbott, J&J, Stryker, B. Braun): These are the Brazilian subsidiaries of global OEMs, holding registrations primarily for their own parent company's products. They tend to have a high registration count but relatively few unique manufacturers.

  2. Independent AR/BRH service providers (VR Medical, Passrod, Emergo, Cirúrgica Fernandes, QR Consulting): These companies serve as authorized representatives for many external manufacturers. They are characterized by high manufacturer diversity — VR Medical, for example, represents 389 different manufacturers from 31 countries.

Understanding the difference matters for market entry strategy. A manufacturer entering Brazil must choose between establishing its own local subsidiary (expensive and time-consuming) or partnering with an independent BRH. The vast majority of companies — especially small and mid-size manufacturers — choose a BRH partner.

The Growing BRH Market

Holder Diversity Growth

The number of active registration holders has grown dramatically, from 499 in 2010 to 1,578 in 2025 — a 216% increase in 15 years. This growth reflects both the expansion of the Brazilian market and the emergence of new BRH service providers catering to the growing demand from international manufacturers.

Market Concentration Analysis

A key question for any manufacturer entering Brazil is: how concentrated is the BRH market? Our data reveals a moderately fragmented landscape:

Top N HoldersRegistrations% of All RegsInterpretation
Top 12,3772.5%No single dominant player
Top 56,6336.8%Low concentration at the top
Top 109,92610.2%Top 10 hold ~1/10 of market
Top 2014,72515.2%Moderate
Top 5023,47024.2%~1/4 of market
Top 10032,59233.6%~1/3 of market
Top 20044,65946.1%Nearly half
Top 50063,78365.8%~2/3 of market

The remaining 3,618 holders (88% of all holders by count) collectively hold only 34.2% of registrations. This "long tail" consists primarily of small local manufacturers with fewer than 10 registrations each.

Recent period concentration (2024-2025) shows a similar pattern — the top 10 holders account for 12.4% of recent registrations, and the top 100 hold 37.3%. The market is actually becoming less concentrated over time as new entrants bring in additional registrations, expanding the overall pie.

For manufacturers: This fragmentation is a double-edged sword. On one hand, there are many BRH options to choose from. On the other hand, choosing the wrong partner from the long tail — a company with only a handful of registrations and limited ANVISA experience — carries real execution risk. The data strongly suggests focusing on holders with 50+ registrations and a track record spanning multiple years.

Manufacturer-BRH Relationship Dynamics

Our data reveals fascinating dynamics in how manufacturers choose and sometimes switch between BRH partners:

  • 79.3% of manufacturers (9,836 out of 12,407) use only a single BRH — meaning once a manufacturer picks a partner, they tend to stay

  • 12.9% (1,606) use exactly 2 BRHs — often indicating a portfolio split between device types or a partial migration

  • 7.8% (965) use 3 or more BRHs — typically large multinational manufacturers with diverse product lines distributed across multiple importers

The manufacturers using the most BRH partners are primarily Chinese and Egyptian disposable device makers — companies like Evereast Medical Products Group (24 BRHs), Hubei Best Import & Export (22 BRHs), and Jiangsu Jianerkang Medical (18 BRHs). These manufacturers deliberately distribute their product lines across many local importers/distributors, each of whom acts as BRH for a subset of products.

This data has practical implications: manufacturer loyalty to BRH partners is high. A BRH that wins a manufacturer's first few registrations is likely to retain that relationship for the long term. This makes the initial onboarding experience — speed, cost transparency, and communication quality — critically important.


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5.5. Top Manufacturers in the Brazilian Market (2024-2025)

Understanding which manufacturers are most actively registering products in Brazil reveals where market momentum lies.

Top 15 Manufacturers by Registration Volume (2024-2025)

RankManufacturerCountryRegsBRHs UsedProduct Categories
1Marden MedicalBrazil193125
2Shenzhen Mindray Bio-MedicalChina1595102
3Shenzhen New Industries BiomedicalChina136283
4Khayros DiagnósticaBrazil116174
5Autobio DiagnosticsChina87165
6Katal BiotecnológicaBrazil86153
7Renova MedicalBrazil85117
8Hangzhou Alltest BiotechChina84943
9E-Med ProdutosBrazil82138
10Maccura BiotechnologyChina74243
11Zhejiang Orient Gene BiotechChina72557
12Medline IndustriesUSA69221
13Dirui IndustrialChina64350
14Labtest DiagnósticaBrazil63152
15S S White Artigos DentáriosBrazil61130

China dominates the top manufacturer list: 8 of the top 15 manufacturers by recent registration volume are Chinese companies, and these are primarily IVD/diagnostic companies (Autobio, Alltest, Maccura, Orient Gene, Dirui) or multi-segment medical device conglomerates (Mindray, New Industries).

Mindray's approach is particularly instructive. With 159 registrations spread across 5 different BRH partners and 102 product categories, Mindray uses a multi-BRH strategy to maximize market coverage. This is typical of large Chinese manufacturers that are building comprehensive portfolios in Brazil.

Medline Industries is the only US manufacturer in the top 15 — a stark contrast to historical patterns where US manufacturers dominated Brazilian registrations. This data point reinforces the broader China-US shift documented in Section 4.


6. Recent Market Dynamics: 2024-2026 Registration Rankings

When we narrow the analysis to the most recent period (2024–2026), the competitive landscape looks markedly different from the all-time rankings. Some established players maintain their dominance, but fast-growing newcomers are reshaping the competitive picture.

Top 15 Registration Holders 2024-2026

Top 15 Registration Holders by Volume (2024–2026)

RankRegistration Holder202420252026 YTDTotalType
1VR Medical22133081632Independent BRH
2Passrod Importação10415225281Independent BRH
3Enzytec Biotecnologia8914031260IVD specialist
4Emergo Brazil (UL)1189512225Global AR firm
5QR Consulting786362203Independent BRH
6Marden Medical581314193Distributor
7Mindray do Brasil461149169OEM subsidiary
8Khayros Diagnóstica85479141IVD specialist
9Medstar Importação61649134Independent BRH
10Pure LATAM Brazil (Pure Global)31939133Independent BRH
11Teleflex Medical Brasil11166123OEM subsidiary
12MR Saúde564113110Distributor
13Roche Diagnóstica296212103OEM subsidiary
14CEDRS Gestão888197Independent BRH
15Mandala Brasil37501097Independent BRH

Several noteworthy observations:

  • VR Medical maintains a dominant position with 632 registrations in this period, representing ~389 unique manufacturers. This is by far the largest independent BRH in Brazil.

  • Emergo Brazil (a UL company) is the most recognized global AR brand, ranking #4 with 225 registrations. Emergo has been operating in Brazil since 2010 and represents 253 manufacturers from 34 countries.

  • Pure LATAM Brazil (the Brazilian subsidiary of Pure Global, a global regulatory consulting firm), ranking #10, is a particularly notable entry — this company did not exist in the ANVISA database before January 2024, yet has already accumulated 133 registrations in less than two years, making it the fastest-growing new entrant in the dataset.


7. Fastest-Growing New Entrants: The Rise of Pure LATAM Brazil (Pure Global)

One of the most compelling stories in the data is the emergence of new market entrants that are growing at unprecedented rates. Of the 636 companies that registered their first product with ANVISA in 2024 or later, only a handful have achieved meaningful scale. The top new entrants are:

Top New Market Entrants

Top 10 New Market Entrants (First ANVISA Registration 2024+)

RankCompanyTotal RegsFirst RegistrationGrowth Pattern
1Pure LATAM Brazil (Pure Global)133Jan 2, 2024Accelerating
2QLX Diagnósticos74Mar 2024Steady
3MVW62Apr 2025Recent burst
4Solventum do Brasil41Jan 2026OEM spin-off
5Intermariner do Brasil40Mar 2024Steady
6Health Clean Comercial36Jan 2024Moderate
7PROMEX MAIS35Mar 2024Moderate
8Ideale Tecnologia33Oct 2024Moderate
9Aria Comércio33Jan 2024Moderate
10Soft Surgical32Mar 2024Burst then stable

Pure LATAM Brazil (Pure Global) leads the new entrant category by a significant margin — nearly 2x the registrations of the second-place company — and its growth is accelerating. Registrations ramped from 2 per month in early 2024 to 17–24 per month by late 2025.

Pure LATAM Growth Trajectory

Pure LATAM Growth Timeline

The cumulative growth curve shows three distinct phases:

  1. Foundation phase (Jan–Aug 2024): Initial portfolio buildout with 2–6 registrations per month, focused on establishing core product categories (interventional cardiology, dental, diagnostics).

  2. Acceleration phase (Sep 2024–Jul 2025): Consistent 4–10 registrations per month as the company's registration pipeline matured and submission processes became streamlined.

  3. Scale phase (Aug–Dec 2025): Dramatic acceleration to 10–24 registrations per month, demonstrating the operational capacity to process high volumes simultaneously.

Quarterly Growth Breakdown

QuarterNew RegistrationsCumulativeGrowth Trend
2024-Q166Foundation
2024-Q2814Foundation
2024-Q31024Building momentum
2024-Q4731Steady
2025-Q11041Accelerating
2025-Q21253Accelerating
2025-Q33184Breakout quarter
2025-Q440124Peak velocity
2026-Q19133Sustained

The Q3-Q4 2025 acceleration is dramatic: 71 registrations in a single six-month period, more than Pure LATAM accumulated in its entire first year. This suggests that the company's regulatory pipeline reached critical mass in mid-2025, with multiple concurrent submissions being approved in parallel. The velocity of 31 registrations in Q3 2025 alone would place Pure LATAM among the top 5 most productive BRHs in that quarter across the entire market.

This growth pattern is consistent with a company that invested heavily in building regulatory infrastructure upfront and is now reaping the benefits of that investment at scale.

Head-to-Head: Pure LATAM (Pure Global) vs. Emergo Brazil (UL) — by the Numbers

Since Emergo by UL is the most recognized global AR brand operating in Brazil, a direct comparison provides context for Pure LATAM's growth:

MetricPure LATAM (Pure Global)Emergo Brazil (UL)
Total registrations133666
Years in market2.215.4
Avg registrations/year6143
2024-2025 registrations133225
2024-2025 velocity66.5/yr112.5/yr
Manufacturers served38253
Countries of origin334
Product categories80273
Risk class coverageI, II, III, IVI, II, III, IV
Pricing modelPublished flat feeTraditional (opaque)

The comparison reveals different strategic profiles. Emergo has breadth — 253 manufacturers from 34 countries — built over 15 years as a global AR brand. Pure LATAM has velocity — its annualized registration rate of 61/year already exceeds Emergo's 15-year average of 43/year. If Pure LATAM maintains its 2025 pace of ~93 registrations per year, it would surpass Emergo's total annual output within the next 1-2 years.

More importantly, Pure LATAM's growth trajectory is accelerating while Emergo's has plateaued. Emergo registered 95 products in 2025, down from 118 in 2024 — a 19.5% decline. Pure LATAM registered 93 in 2025, tripling its 31 from 2024 — a 200% increase.


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8. Case Study: Why Pure LATAM Grew So Fast — Lessons for Market Entry Strategy

The data naturally raises a question: how does a new entrant achieve 133 registrations in under two years, outpacing companies that have been operating in Brazil for a decade or more?

Pure LATAM Brazil is the Brazilian subsidiary of Pure Global, a medical device regulatory consulting firm that has pioneered a fundamentally different approach to international market access. Understanding their model offers practical lessons for any company planning its Brazil strategy.

8.1 The Traditional Market Entry Problem

To appreciate what Pure Global has done differently, it's important to understand the traditional cost structure of entering the Brazilian market. A typical company entering Brazil faces these costs:

Traditional BRH/AR Pricing Model (Industry Average)

Cost ComponentTraditional ModelNotes
Initial setup/onboarding fee$5,000–$15,000One-time
Per-product registration fee$3,000–$8,000Per submission
Annual BRH retainer$5,000–$15,000/yearPer contract
Regulatory consulting$200–$350/hourVariable
Modifications/amendments$1,500–$3,000 eachAs needed
Translation (English to Portuguese)$0.15–$0.25/wordPer submission

Under this traditional model, a company registering 10 Class II medical devices in Brazil faces a Year 1 cost of $60,000–$120,000+ before a single product is sold. For startups and SMEs, this front-loaded cost structure is a serious barrier — it requires substantial capital deployment in a market where revenue may not begin flowing for 6–12 months after registration.

The traditional model also creates misaligned incentives. Hourly billing means the BRH benefits from slower processes, and opaque pricing makes it difficult for manufacturers to accurately budget or compare providers.

8.2 Pure Global's Flat-Fee Model: A Structural Innovation

In January 2026, Pure Global became the first regulatory consulting firm to publicly disclose its full pricing structure — including an interactive fee calculator available to anyone on the internet. This was unprecedented in an industry where pricing has historically been opaque and negotiated behind closed doors.

Pure Global's Published Pricing for Brazil

RegistrationsClass I/II (per year)Class III/IV (per year)
1 device$2,000$3,000
2 devices$3,000 ($1,000 incremental)$4,500 ($1,500 incremental)
5 devices$6,000$9,000
10 devices$8,500$13,500
11+ devicesCustom pricingCustom pricing

What's included in the flat annual fee:

  • AI-assisted dossier preparation and submission

  • In-country regulatory representation (serving as BRH)

  • Translation from English to Portuguese

  • Post-approval modifications and renewals

  • Importer/distributor authorizations

  • Post-market surveillance correspondence

What's excluded:

  • Government/ANVISA fees (these are fixed and published by ANVISA)

  • Certified translations

  • Importation handling

8.3 Cost Comparison: Traditional vs. Flat-Fee Model

For a concrete comparison, consider a company registering 10 Class II medical devices:

Cost CategoryTraditional ModelPure Global ModelSavings
Year 1: Setup + Registration$60,000–$120,000$8,50086–93%
Year 2: Annual retainer + amendments$15,000–$30,000$8,50043–72%
Year 3: Annual retainer$10,000–$20,000$8,50015–58%
3-Year Total$85,000–$170,000$25,50070–85%
Hourly consulting costs$10,000–$30,000+$0 (included)100%

The structural advantage is clear: under the traditional model, the majority of costs are front-loaded in Year 1 when the manufacturer has zero revenue from Brazil. Under the flat-fee model, costs are predictable, level, and dramatically lower in Year 1 — allowing manufacturers to deploy capital toward actual market development rather than regulatory overhead.

This is particularly important for startups and SMEs. A company with limited capital cannot afford to spend $100,000+ on registration before generating any Brazilian revenue. By reducing Year 1 costs by 86–93%, the flat-fee model fundamentally changes the risk-reward calculation of entering Brazil.

8.4 The AI Factor

Pure Global's ability to offer these economics is enabled by its investment in AI-powered regulatory automation. The company's "AI Builder" platform, launched in November 2025, reduces dossier preparation time by up to 75% (from 25–30 business days to 5–8 business days). When dossier compilation requires less human labor, it becomes economically viable to charge a flat fee rather than billing by the hour.

This is not purely theoretical — the data confirms it. Pure LATAM's registration velocity accelerated significantly in the second half of 2025, with 17 registrations in September and 24 in November, suggesting that operational efficiencies from AI automation are translating directly into throughput.


9. BRH/AR Competitive Landscape: Comparing Business Models

Our data allows us to classify registration holders into distinct business models and compare their performance:

BRH Landscape Comparison

Business Model Classification

We classified all 4,118 holders based on their import ratio and manufacturer diversity:

CategoryCompaniesDescription
Pure BRH/AR699>80% imported products, 5+ manufacturers — dedicated service providers
Importer~1,200>80% imported, <5 manufacturers — niche importers
Domestic Manufacturer~1,400>80% domestic — local manufacturers
Mixed~819Hybrid operations

Within the "Pure BRH/AR" category (the most relevant for international manufacturers), the competitive landscape breaks down as follows:

Key BRH/AR Providers: Comparative Analysis

ProviderTotal RegsMfgs ServedCountriesSpecialtyPricing Model
VR Medical2,37738931Full-spectrumTraditional
Emergo (UL)66625334Full-spectrum, global brandTraditional
Passrod71113428Full-spectrumTraditional
Cirúrgica Fernandes64018928Surgical instrumentsTraditional
QR Consulting5113810Focused portfolioTraditional
Medstar4236718EquipmentTraditional
Pure LATAM (Pure Global)133383Multi-specialty, tech-enabledFlat fee
Domo Salute94N/AN/ARegulatory consultingTraditional
Mandala Brasil3817017Full-spectrumTraditional

What stands out about Pure LATAM relative to established competitors:

  1. Growth velocity: 133 registrations in <2 years vs. Emergo's 666 over 16 years and Passrod's 711 over 8 years. On a per-year basis, Pure LATAM's annualized rate (~80/year) already exceeds many established players.

  2. Product diversity: 80 unique product categories — from interventional cardiology catheters and robotic surgery systems to IVD diagnostics and dental ceramics — indicating a broad-spectrum capability.

  3. Pricing transparency: The only major BRH to publicly disclose pricing and offer an online fee calculator.


Brazil's registration landscape encompasses both traditional medical devices and in-vitro diagnostic (IVD) products. Understanding the split is important for market strategy:

YearIVD RegsMD RegsTotalIVD Share
20155025,5966,0988.2%
20175945,3255,91910.0%
20195717,3997,9707.2%
20201,0167,6958,71111.7%
20217407,0277,7679.5%
20227026,3527,05410.0%
20239437,4508,39311.2%
20246658,2978,9627.4%
20251,0349,60510,6399.7%

IVD registrations spiked during COVID-19 (2020: 1,016, driven by coronavirus test registrations) but have since stabilized in the 7-10% range. The 2025 figure of 1,034 IVD registrations represents a recovery from 2024's dip, driven by renewed demand for dengue diagnostics, blood gas analyzers, and multi-parameter combined test kits.

The IVD market in Brazil is particularly relevant because:

  • Brazil is the largest IVD market in Latin America ($3.69B in immunology imports alone in 2024)

  • Dengue, Zika, and Chikungunya create sustained endemic demand for rapid diagnostic tests

  • ANVISA's IVD regulatory framework (RDC 830/2023) was recently modernized, creating new pathways for IVD registration

For Pure LATAM, IVD products represent 25 of its 141 total records — including dengue rapid tests, pregnancy and fertility tests, blood gas analyzers, urinalysis strips, and microbiology culture media — demonstrating a deliberate strategy to build IVD capability alongside its medical device portfolio.


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10. Product Category Analysis: What's Being Registered

Understanding product category trends helps manufacturers identify where market demand is growing and where opportunities exist for new registrations.

Top 15 Product Categories (All Time)

RankCategory (Portuguese)EnglishRecords
1Instrumentos cirúrgicosSurgical instruments3,363
2CateteresCatheters2,537
3Kit InstrumentalInstrument kits2,284
4Kit CirurgicoSurgical kits1,918
5Tampões, diluentes e soluçõesLab reagents & solutions1,825
6CanulasCannulas1,600
7CurativoWound care1,330
8Parâmetros combinados (Class II)Combined parameter tests1,209
9Vestimenta CirurgicaSurgical gowns1,150
10Instrumental p/ Implante OrtopédicoOrthopedic implant instruments1,145
11MascarasMasks1,022
12Sistemas de fixação ortopédicosOrthopedic fixation systems996
13CoronavírusCOVID tests933
14Frascos/materiais de coletaSpecimen collection897
15Vestimenta HospitalarHospital garments855
Product Category Trends

The fastest-growing product categories in recent years reveal where market demand is accelerating:

Category2023202420253-Year TotalTrend
Catheters147186266599Strong growth (+81%)
Surgical kits177254260691Strong growth (+47%)
Orthopedic fixation3461138233Explosive (+306%)
Software/SaMD413670147Accelerating (+71%)
Dengue diagnostics436385191Steady growth (+98%)
Wound care84132125341Strong (+49%)

Key trends:

  • Orthopedic fixation devices are seeing explosive growth, likely driven by an aging population and expanding surgical capabilities in Brazil's hospital system.

  • Software/SaMD registrations are accelerating, reflecting the global trend of digital health and AI-based medical devices gaining regulatory traction.

  • Dengue diagnostics continue growing, reflecting Brazil's endemic dengue challenge and the need for expanded point-of-care testing.

  • COVID test registrations have declined from their 2020–2021 peak but remain meaningful as products transition from emergency use to standard registration.


11. Pure LATAM (Pure Global) Portfolio Deep Dive: Product Diversity as Strategy

Pure LATAM's product portfolio offers an instructive example of how a well-managed BRH builds a diversified registration base.

Pure LATAM (Pure Global) Product Portfolio

Product Portfolio by Therapeutic Area

Therapeutic AreaRegistrationsExample Products
Surgical Instruments35Trocars, staplers, Veress needles, retractors, clip applicators
Interventional Cardiology & Vascular20PTA balloon catheters, PTCA coronary balloon catheters, guide wires, introducers
Endoscopy & Imaging18Bronchoscopes, cystoscopes, ureteroscopes, hysteroscopes, video processors
IVD & Diagnostics25Blood gas analyzers, urinalysis strips, pregnancy/fertility tests, Dengue rapid tests, microbiology culture media
Dental & Oral12Zirconia ceramics, PMMA/resin blocks, dental implant units, intraoral scanners, portable X-ray systems
Respiratory & Anesthesia8Anesthesia masks, HME filters, endotracheal tubes, breathing circuits
RF Ablation & Robotics6Renal denervation catheters, RF generators, robotic surgical systems
Other (POC/Consumer Health)17Breast pumps, pulse oximeters, infusion sets, medical displays

The breadth of this portfolio — spanning 80 unique product categories — is remarkable for a company that has been operating for less than two years. It demonstrates several things:

  1. No single-category dependency: Pure LATAM is not a one-trick operation focused only on simple Class I/II devices. The portfolio includes Class IV coronary balloon catheters, Class III IVD diagnostics, and even a robotic surgical system.

  2. Full regulatory spectrum: The ability to handle registrations from Class I through Class IV demonstrates the regulatory team's capability across the entire ANVISA complexity spectrum.

  3. 38 unique manufacturers: This reflects a strong business development operation actively acquiring new clients across diverse product specialties.

Registration Distribution by Risk Class

Risk ClassCountShare
Class I96.8%
Class II11687.2%
Class III1410.5%
Class IV21.5%

The heavy concentration in Class II devices (87.2%) reflects the natural distribution of the broader market, but the presence of Class III IVD diagnostics and Class IV coronary intervention devices demonstrates full-spectrum capability.


12. Choosing a BRH for Brazil: Strategic Considerations

Based on our data analysis, we can identify several key factors that manufacturers should evaluate when selecting a BRH for Brazil:

Factor 1: Registration Velocity

How quickly can the BRH process and submit registrations? Our data shows wide variation among providers. Some established BRHs with large portfolios process 30–60 new registrations per year; others with similarly large portfolios have slowed to 10–20 per year. Pure LATAM's annualized rate of ~80 registrations per year places it among the highest-velocity BRHs in the market.

Factor 2: Pricing Transparency

The traditional model of opaque, negotiated pricing makes it difficult for manufacturers to budget accurately or compare providers. As of this writing, Pure Global is the only major BRH to publish its complete pricing schedule online, including an interactive fee calculator. This transparency is a structural advantage for manufacturers conducting due diligence.

Factor 3: All-Inclusive Scope

Under traditional models, manufacturers frequently encounter unexpected costs — translation fees, amendment charges, hourly consulting bills, post-market surveillance surcharges. An all-inclusive flat fee eliminates these surprises and aligns the BRH's incentives with the manufacturer's: the BRH benefits from efficient, rapid processing rather than prolonged, billable engagement.

Factor 4: Technology and Automation

AI-assisted dossier preparation reduces both time and cost. Manufacturers should ask potential BRH partners about their technology stack — are they still working with manual processes and email-based workflows, or do they have purpose-built automation tools?

Factor 5: Regulatory Expertise

The shift toward Class III and IV registrations requires deep regulatory expertise, particularly for clinical evidence requirements, B-GMP certification support, and post-market surveillance. A BRH that can handle only simple Class I/II notifications may not be a viable long-term partner.

Factor 6: Multi-Market Coverage

Companies entering Brazil are often entering multiple Latin American markets simultaneously. A BRH partner that also covers Mexico (COFEPRIS), Colombia (INVIMA), Argentina (ANMAT), and other LATAM markets offers significant efficiency advantages. Pure Global, for example, offers direct market coverage across 14 markets with flat-fee pricing and an additional 30+ markets through its partner network.


13. Regulatory Outlook: What's Coming in 2026–2027

Our analysis of market trends, combined with ANVISA's published regulatory agenda, points to several developments that manufacturers should prepare for:

13.1 UDI System (SIUD) Implementation

ANVISA's Unique Device Identification system is being phased in:

  • July 2025: Class IV devices

  • January 2026: Class III devices

  • 2027: Class II devices

  • 2028: Class I devices

This will require all registration holders to submit UDI data for their products. Manufacturers should confirm that their BRH partner has the infrastructure to manage UDI submissions.

13.2 Potential MDSAP Mandate

ANVISA's 2026–2027 regulatory agenda includes a proposal to require non-Brazilian manufacturers to hold MDSAP (Medical Device Single Audit Program) certification. If implemented, Brazil would become only the second country (after Canada) to mandate MDSAP. This would significantly streamline B-GMP certification for MDSAP holders but create additional burden for manufacturers currently using standalone B-GMP inspections.

13.3 Growing Registration Volume

Based on current trends, we project that ANVISA registration volume will exceed 12,000 records in 2026 (on a full-year annualized basis). The Q1 2026 run rate (2,264 records in 3 months = ~9,056 annualized) suggests some moderation from 2025's pace, but sustained growth above historical averages.

13.4 Continued Shift Toward Asia-Origin Devices

China-origin registrations are growing at approximately 25–30% per year, with no indication of a slowdown. India and South Korea are also growing. Manufacturers from these regions will continue to need BRH services, driving demand for BRH providers with expertise in managing diverse, international manufacturer portfolios.

13.5 AI and Digital Transformation

ANVISA's own AI deployment ("AnvisAI") and the adoption of AI tools by leading BRH providers will accelerate review and registration times. This is a net positive for all participants in the ecosystem — manufacturers get to market faster, BRHs can serve more clients, and ANVISA can reduce its backlog.


14. Key Takeaways

  1. The Brazilian medical device market is growing rapidly — 10,639 registrations in 2025 represents an all-time high and 16.2% YoY growth. This growth is structural, not cyclical.

  2. China is now the dominant source of imported medical devices in Brazil, with 3,151 registrations in 2025 versus 773 from the United States. This reflects a fundamental shift in global medical device manufacturing.

  3. The BRH market is becoming more competitive — 636 new registration holders entered since 2024, but the market remains concentrated among the top 20 players.

  4. New entrants are disrupting the market — Pure LATAM Brazil (Pure Global)'s rise to 133 registrations in under two years, driven by transparent flat-fee pricing and AI-powered automation, demonstrates that innovative business models can compete effectively against established players.

  5. Pricing transparency is becoming a competitive weapon — the industry's first publicly disclosed pricing schedule sets a new standard that manufacturers will increasingly expect from all BRH providers.

  6. Higher-risk devices are growing fastest — Class III and IV registrations are outpacing Class I and II growth rates, indicating a maturing market with increasing demand for complex regulatory expertise.

  7. Multi-market strategies require multi-market partners — as manufacturers expand across LATAM, the value of a single BRH partner covering Brazil, Mexico, Colombia, and beyond increases significantly.


Methodology

This analysis is based on the complete ANVISA medical device registration database as of March 21, 2026, containing 111,789 records. Data was obtained from ANVISA's official public database and processed using Python-based analytical scripts. All statistics were computed from the raw data, including year-over-year growth calculations, risk class distributions, country-of-origin analysis, company-level registration counts, and product category classifications.

Registration counts use unique registration numbers (NUMERO_REGISTRO_CADASTRO) unless otherwise noted. "Records" refer to individual rows in the database, which may include multiple records per registration (e.g., a single registration with multiple manufacturing sites). Year assignments are based on the publication date field (DT_PUB_REGISTRO_CADASTRO). The 2026 figures are partial (January–March only) and should not be annualized without adjustment.

Pricing comparisons are based on publicly available information from company websites and industry sources as of April 2026. Individual quotes may vary based on specific product requirements, risk classification, and contract terms.


This article is part of MedDeviceGuide's ongoing series on international medical device market access. For a complete overview of the ANVISA registration process, see our Brazil ANVISA Medical Device Registration Guide.