The regulatory landscape for medical cannabis in Brazil is on the brink of a landmark modernization, driven by the Brazilian Health Regulatory Agency’s (ANVISA) ongoing overhaul of Resolution RDC 327/2019. As of March 28, 2025, Public Consultation No. 1,316/2025 launched a nationwide feedback process that closed June 2, 2025, collecting crucial input from patients, healthcare professionals, domestic manufacturers, exporters, and pharmacies. With final regulatory amendments anticipated by late 2025, stakeholders must now start preparing for a fundamentally different compliance environment—one that puts Brazil on track to become Latin America’s most sophisticated medical cannabis market.
What’s Driving the Regulatory Overhaul?
The modernized framework’s urgency reflects both judicial pressure and Brazil’s vision to harmonize cannabis rules with international public health standards. Brazilian courts have pressed ANVISA to deliver more robust, adaptable guidance that matches the sector’s rapid evolution and patient demand. As a result, the agency’s 2024-2025 regulatory agenda (see CGM Law) set cannabis among its top priorities, mandating deeper scrutiny of product safety, quality, and pharmaceutical oversight.
Key elements under revision address everything from Good Manufacturing Practice (GMP) standards to prescription protocols, labeling requirements, pharmacovigilance, and the transition toward a more accessible, supervised domestic market.
Major Proposed Changes: What Will the New Rules Cover?
The upcoming revisions to RDC 327/2019 envision alignment with stricter international GMP standards, raising the bar for both foreign exporters and Brazilian producers. Key highlights include:
- Mandatory GMP Certification: All manufacturers (domestic and international) supplying medical cannabis must prove GMP compliance, subject to ANVISA’s inspection or recognized international certifications.
- Stability Data Requirements: Comprehensive stability studies, mirroring pharmaceutical product standards, will be needed for registration dossiers. Shelf life, storage, and transport data must be validated.
- Impurity and Contaminant Limits: New, lower thresholds on heavy metals, pesticides, microbial contamination, and residual solvents—applies to both high-CBD and THC-containing products.
- Batch Testing and COAs: Products must include validated Certificates of Analysis (COAs), with full batch traceability and quality documentation.
For exporters: These updates mean preemptive auditing of manufacturing facilities and translation of all documents (including COAs) into Portuguese are essential. Hiring an authorized local representative is expected to become mandatory for registration and post-market procedures.
2. Local Pharmacies: Dispensing, Traceability, and Recordkeeping
One of the most profound changes will empower pharmacies—especially compounding pharmacies—to dispense cannabis-based medications. New obligations will likely include:
- Pharmaceutical Supervision: Only pharmacies and dispensaries with licensed pharmacists may handle and dispense cannabis products.
- Detailed Sales Records: Pharmacies will be mandated to digitally record each transaction, linking prescriptions to patients and enabling ANVISA to monitor product flow—critical for post-market surveillance.
- Compounding Permissions: The overhaul may broaden the scope for compounding pharmacies to prepare cannabis medicines from registered bulk ingredients, under strict quality controls (see Souto Correa Advogados).
Best practices: Pharmacies should start developing robust QMS processes and staff training for cannabis-specific workflows. Prepare now to upgrade digital systems to enable required traceability and reporting.
3. Prescription Categories—Opening to General Practitioners?
The original RDC 327/2019 rules restricted prescription rights for cannabis products almost exclusively to specialist medical doctors. Under the new draft:
- Potential Expansion: Prescription authority may be formally extended to general practitioners, subject to training requirements. This would increase access for patients in rural and underserved regions.
- Clear Categorization by Formulation: Specific prescription criteria based on CBD or THC content, formulation type (oral solutions, capsules, etc.), and intended medical indication.
Key impact for prescribers: Physicians, regardless of specialty, must update their knowledge of cannabis pharmacology and adhere to new documentation standards.
4. Domestic Supply vs. RDC 660: The Future of Patient-Specific Imports
For years, RDC 660 has provided a patient-specific route for importing unregistered cannabis products from abroad. The emerging regulations will aim to harmonize and eventually phase out this ad-hoc pathway as the domestic supply chain matures.
- Transition Period: There will be a regulatory grace period during which both patient-specific imports and domestic dispensing will coexist, but expect increasing restrictions on new import authorizations.
- Stricter Documentation: More rigorous dossier review for imported products, including proof of foreign GMP, validated COAs in Portuguese, and linkage to an authorized local agent.
- Long-term goal: Shift most patients to locally regulated, pharmacy-dispensed cannabis products, boosting domestic traceability and quality assurance.
5. Labeling, Advertising, and Packaging—Now in Focus
Labeling and advertising are major targets for harmonization and consumer safety:
- Portuguese Labeling Required: All products must feature labeling—ingredients, dosage, warnings—fully translated into Portuguese and reviewed by ANVISA.
- Package Standardization: Clear guidance on tamper-evident packaging, child resistance, and patient information leaflets.
- Advertising Restrictions: Promotion of cannabis products will be tightly restricted to scientific, prescriber-focused communications. Public targeting or broad consumer advertising remains prohibited (Mattos Filho).
6. Price Controls and Post-Market Surveillance
- Pricing: ANVISA may maintain or tighten oversight of retail and wholesale prices, factoring in cost-effectiveness in Brazil’s public health context.
- Pharmacovigilance Systems: Distributors and pharmacies will face strong obligations for adverse effects reporting and market surveillance—the requirements will mirror those for conventional pharmaceuticals.
Compliance Checklist: How Businesses Should Prepare
For Exporters and Overseas Manufacturers
- Audit your facility’s GMP readiness (ideally to EU or ANVISA-recognized standards).
- Translate all technical, quality, and labeling documents into Portuguese.
- Appoint a registered local representative—required for communications and issue resolution.
- Prepare complete, validated Certificates of Analysis (COAs) for each batch, ensuring impurity and contaminant limits meet new Brazilian thresholds.
- Track proposed timelines: Final regulations expected in late 2025; anticipate a transition window of 6–12 months for legacy products to update dossiers and labeling.
For Pharmacies and Local Distributors
- Upgrade digital traceability systems to handle ANVISA reporting requirements.
- Train pharmacy staff in cannabis dispensing protocols and patient counseling.
- Review product portfolios for GMP, labeling, and prescription compliance.
- Implement robust pharmacovigilance and post-market surveillance systems.
For Healthcare Professionals and Prescribers
- Keep abreast of new prescription categories and clinical documentation duties.
- Participate in ANVISA or professional training sessions to maintain compliance and optimize patient care.
Anticipated Enforcement Priorities
As Brazil harmonizes its regulatory regime, expect intensified scrutiny in these areas:
- Compliance with GMP and quality standards for all imports and domestically produced goods
- Proper labeling, packaging, and advertising controls
- Monitoring of product claims, especially around intoxicating THC content or synthetic derivatives
- Enforcement against unauthorized online promotion or sales
Timelines and Next Steps
- Final Regulation Publication: Late 2025 expected
- Transition/Grace Periods: 6–12 months for existing products and authorizations
- Stakeholder Audits & Training: Recommended throughout 2025 as new rules approach
For more in-depth documentation, visit ANVISA’s official portal and follow the latest advisories from experienced local counsel.
Key Takeaway: Brazil’s regulatory transformation is set to elevate patient safety, product consistency, and commercial clarity—for both domestic innovators and international suppliers. The next six months are pivotal: now is the time to audit compliance frameworks, build partnerships with local representatives, and realign internal processes for the new ANVISA standards.
For real-time updates, compliance resources, and expert insights on the evolving Brazilian cannabis market, tap into CannabisRegulations.ai—your partners in cannabis compliance.
