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2018 YEARBOOK TECHNICAL AND REGULATORY AFFAIRS 57

discussion on this subject, as well as establishing ABIHPEC SOUGHT IN 2017 – AND IS
agile and effective mechanisms for post-regis- CONTINUOUSLY SEEKING – TO SIMPLIFY
tration alteration of the products already avail-
able in the market; but in a definition deviation THE ADMINISTRATIVE PROCEDURES
it was ruled that a same product that received OF ANVISA
minor changes in the packaging (such as color,
font size, among others) would be subjected to Renata Amaral
a new technical analysis, which implies delay manager of Technical and Regulatory Affairs at
in launching.
ABIHPEC
There is a great deal of instability against the
deadlines established by Anvisa's Personal Care,
Fragrances and Cosmetics Product Management
Technicians, which has a drastic impact on up-
dates of labeling requirements and labels on prod-
ucts already available in the market and make it
difficult for consumers to access such products.

“ABIHPEC sought in 2017 – and is continuously
seeking – to simplify the administrative procedures of
Anvisa”, said Renata Amaral, manager of Tech-
nical and Regulatory Affairs at the Association.

The industry proposes the adoption of the pri-
or consent procedure previously established by
Anvisa for some requests for post-registration al-
terations of low sanitary risk, which would dras-
tically reduce the current post-registration queue;
or to establish the immediate implementation
already adopted by other sectors of the Agency.

DISPOSABLE PRODUCTS the label, something impossible due to the for-
mulation of the product, as well as the request of
In March 2017, the update of the legislation on identification of the INCI composition (Interna-
disposable products such as wet towels, tooth- tional Nomenclature of Cosmetic Products) for
brushes, cotton swabs and dental floss was also products such as toothbrushes - whose base can-
published. In 2013, when the plea was created be- not be identified by this classification. In Octo-
fore Mercosur, the request was for the non-man- ber 2017, the Association succeeded in republish-
datory animal testing for diapers and wet towels, ing the laws and eliminating these requirements.
but the new regulations came with some non-
conformities, such as the obligation to include a ORGANIC PRODUCTS
process number on the packaging. Other requests
were for inclusion of the dental floss thickness on Another achievement in this sector occurred in
the organic products matters, with the publi-