The dossier errors that stall ANVISA applications most

Most stalled dossiers have formal or consistency gaps, not serious errors. The five families of errors and how to keep your dossier from coming back.

Man at a office desk, looking one document. There is a pile of documents aside him.

The dossier took months to prepare. The team gathered the manufacturer’s documents, translated, reviewed and filed. Weeks later, the application came back with a finding about a document everyone was sure was there. The question at the next meeting was simple, and no one could answer it: “what exactly was wrong?”

Short answer: most dossiers that stall do not have a serious error, but formal or consistency gaps: a mandatory document missing at filing, versions that do not match, information that changes from one document to another. Some of these gaps lead to a technical requirement. Others, such as a document required at filing being missing, can lead straight to rejection.

Why does documentation make such a difference?

Because ANVISA reviews what is in the file, and only that. Under RDC 204/2005, a technical requirement serves to ask for information and clarification on the documentation submitted. When a required document was not in the filing, including proof of the fee when it is due, the rule does not provide for a requirement: insufficient documentation leads to rejection.

In practice, this means the filing is the most important moment of the dossier. What does not go in there rarely gets a second chance in the same application.

Is this you? Before filing, did someone check the dossier against the official list of documents for your type of application? Are the manufacturer’s documents in their latest versions, and the same across the whole dossier? Do the product name, models and presentations appear the same in every document?

Which errors appear most often?

In Sobel’s experience, they repeat in five families:

Error familyHow it usually shows up
Missing documentA mandatory item for the application type was not included in the filing, or the fee was not proven
Inconsistency between documentsName, models, codes, presentations or intended use change from one document to another
Outdated versionManufacturer certificates, reports or declarations expired or replaced by newer versions
Labeling and instructions for useTexts that do not follow the segment’s labeling rules or do not match the rest of the dossier
Evidence that does not support the claimThe document exists but does not prove what the application says about safety, performance or classification

The first three are formal errors and, when well identified, are usually the fastest to fix. The last two require technical knowledge of the product and of the segment’s rules.

How to keep the dossier from coming back

The review that works is not reading each document on its own. It is checking the dossier as a whole, against the segment’s rules and against itself.

  1. Check the official list of documents for the application type before filing.
  2. Cross-check the key information (name, models, codes, intended use) in every document.
  3. Check dates and versions of everything that comes from the manufacturer.
  4. Read the labeling together with the dossier, not as a separate piece.
  5. For each important claim, ask where the proof is.

If the dossier has already come back with a technical requirement, the way to answer is in the guide on technical requirements. If the application was rejected, start with the guide on rejection.

How Sobel can help

In the initial assessment, we look at your dossier and ANVISA’s finding and tell you what must be corrected, what can be reused and what the shortest path from here is. We work with medical devices, IVD and cosmetics, including dossiers prepared by the company itself or by another consultancy.

Send the dossier and ANVISA’s notice for an initial assessment. We reply within 1 business day. →

Frequently asked questions

Does a missing document always lead to a technical requirement? No. Under RDC 204/2005, applications filed without the required documentation are not eligible for a requirement, and insufficient documentation leads to rejection.

Can I complete the dossier after filing? The rule provides for an addendum (aditamento), a supplement not formally requested that only improves the understanding of the file. It does not replace a mandatory document that was missing at filing.

What is the most common error? In our experience, inconsistency between documents: information that changes from one document to another. It is easy to fix and hard to see from the inside.

Do you review the dossier before filing? Yes. A review before filing is usually when it saves the most time.

Official sources

For information only. This does not replace an assessment of your case.

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Maik Endler

Written by

Maik Endler

Mechanical engineer trained in Germany and former BSI auditor (Notified Body). Founder and CEO of Sobel, he leads regulatory strategy for medical devices, IVDs and cosmetics in Brazil, Europe, the UK, the US and Canada.

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