ANVISA has introduced a new petition structure for requests involving substances, functions, packaging and physical forms used in personal hygiene products, cosmetics and perfumes in Brazil.
Starting September 1, 2026, companies will no longer use the single petition code 2877 for these requests. Instead, four specific codes will apply depending on the type of change being requested.
Although the change is procedural, it is relevant for regulatory teams because the new structure also introduces specific petition forms and revised document requirements. Therefore, companies preparing new submissions should review not only the correct petition code, but also the supporting documentation expected for each type of request.
What changes on September 1, 2026?
Previously, companies used one general code:
2877 – Inclusion: Physical Form, Packaging, Formula Component and Function.
However, ANVISA will deactivate this code on September 1 and replace it with four separate petition codes.
| New code | Request |
| 2878 | Inclusion of a new substance |
| 2879 | Inclusion of a new function for a substance |
| 2880 | Inclusion of new packaging |
| 2881 | Inclusion of a new physical form |
As a result, companies must identify the nature of the request before initiating the petition in Sistema Solicita.
Why did ANVISA create separate petition codes?
According to ANVISA, the change is part of an effort by the General Management of Cosmetics and Sanitizing Products (GGCOS) to standardize internal analysis procedures, improve the efficiency of evaluations and reduce the backlog of petitions.
In addition, separating the requests makes it easier to identify the type of petition and allows each process to follow a more standardized technical assessment.
Importantly, ANVISA also states that the new procedures will follow the same structured workflow used for other petitions, including technical opinions and formal communication of final decisions to companies.
Therefore, the change should not be viewed simply as the creation of four new system codes. It also reflects a more structured approach to how these requests are documented and assessed.
New petition forms and documentation requirements
Together with the new codes, ANVISA published specific petition forms for each type of request.
The forms instruct companies to submit one petition for each request, rather than combining multiple requests in the same field. According to the Agency, combining requests may make the technical assessment more difficult.
Code 2878 – Inclusion of a new substance
For requests involving a new substance, the required information can be considerably more detailed.
For example, where a substance or intended function is not supported by the European CosIng database, the ANVISA checklist may require information concerning:
- substance identification;
- chemical and physicochemical characterization;
- intended use and concentration;
- safety rationale;
- toxicological information;
- efficacy data;
- scientific literature; and
- other information supporting the proposed use.
In addition, for innovative substances, the checklist identifies several toxicological endpoints that may need to be addressed.
This is particularly relevant because, in practice, the regulatory work may begin well before the petition itself. Companies may first need to determine whether the available technical and safety evidence is sufficient to support the requested inclusion.
Code 2879 – Inclusion of a new function for a substance
The new function request also requires a justification explaining the proposed function.
Furthermore, if the requested function is not supported by CosIng, companies may need to provide evidence related to safety, toxicology and efficacy under the proposed conditions of use.
Consequently, assigning a new function to an existing ingredient should not be treated only as an administrative change. The scientific basis supporting that function may become an important part of the regulatory assessment.
Codes 2880 and 2881 – Packaging and physical form
The forms for new packaging and new physical forms are comparatively straightforward.
However, companies must still clearly identify the current configuration, the proposed change and the justification for the request. For packaging changes, ANVISA also requests an image of the proposed packaging type.
What should regulatory teams review before filing?
Companies preparing these types of petitions should now verify at least three points.
First, confirm which of the four new codes applies to the request.
Second, review the corresponding ANVISA form before preparing the submission, since the documentation varies depending on the type of inclusion.
Finally, for new substances or new functions, evaluate early whether sufficient scientific, safety, toxicological and efficacy evidence is available to support the proposed use.
Therefore, reviewing the evidence before opening the petition can help identify documentation gaps and reduce the likelihood of questions or rework during the regulatory assessment.
Sobel Regulatory View
The introduction of separate petition codes may appear to be a relatively small administrative change. However, the new forms show that ANVISA is also placing greater structure around the information used to assess these requests.
This is particularly relevant for new substances and new functions, where the assessment can extend beyond administrative documentation into safety, toxicology and efficacy evidence.
For regulatory teams, the practical message is clear: the petition should be the final step of the preparation process, not the starting point.
Understanding the requested inclusion, identifying the applicable evidence and reviewing potential documentation gaps beforehand can make the submission more consistent with the new ANVISA workflow.
Preparing a cosmetic petition under ANVISA’s new procedures?
Talk to our regulatory team to review the applicable procedure and documentation before submission.
Official ANVISA references
Primary official source:
https://www.gov.br/anvisa/pt-br/assuntos/noticias-anvisa/2026/anvisa-cria-codigos-e-padroniza-procedimentos-para-inclusao-de-substancias-embalagens-e-formas-fisicas-em-cosmeticos
Code 2878 – New substance form:
https://www.gov.br/anvisa/pt-br/assuntos/noticias-anvisa/2026/anvisa-cria-codigos-e-padroniza-procedimentos-para-inclusao-de-substancias-embalagens-e-formas-fisicas-em-cosmeticos/formulario-de-peticao-de-solicitacao-de-inclusao-de-novas-substancias.pdf/@@display-file/file
Code 2880 – New packaging form:
https://www.gov.br/anvisa/pt-br/assuntos/noticias-anvisa/2026/anvisa-cria-codigos-e-padroniza-procedimentos-para-inclusao-de-substancias-embalagens-e-formas-fisicas-em-cosmeticos/formulario-de-peticao-de-solicitacao-de-inclusao-de-nova-embalagem.pdf/@@display-file/file
Code 2881 – New physical form:
https://www.gov.br/anvisa/pt-br/assuntos/noticias-anvisa/2026/anvisa-cria-codigos-e-padroniza-procedimentos-para-inclusao-de-substancias-embalagens-e-formas-fisicas-em-cosmeticos/formulario-de-peticao-de-solicitacao-de-inclusao-de-forma-fisica.pdf/@@display-file/file
