Mexico’s COFEPRIS
Medical Device/IVD
Pharmaceuticals
Cosmetics
Food Supplements
Medical Devices
Mexico’s Regulatory Health Authority:
Medical Devices are regulated by COFEPRIS (Comision Federal para la Proteccion contra Riesgos Sanitarios). All medical devices imported into or distributed within Mexico must first undergo registration with COFEPRIS.
Medical Device Registration in Mexico:
Registering a device or IVD in Mexico can be extremely difficult for non-Spanish speakers. COFEPRIS, the regulatory authority that oversees medical device and IVD registration , provides very limited information on their website in English, furthermore, they require all documentation and communication to take place in Spanish. GRP office located in Mexico City has a team of bilingual regulatory experts that can help you access Mexico’s medical device market.
Cofepris Medical Device Definition:
“A substance, mixture of substances, material, apparatus or instrument (including the computer program necessary for its appropriate use or application), used alone or in combination for the diagnosis, monitoring or prevention of diseases in humans or in the treatment of the same and of the disability, as well as those used in the replacement, correction, restoration or modification of the anatomy or human physiological processes.”
Authorized Local Representative
Mexican Health Authority (COFEPRIS) requires that any foreign pharmaceutical or biologic company, without a physical location in Mexico, to appoint a Mexican Registration Holder in Mexico before registering and selling any product in Mexico. In Mexico, GRP Mexico office is licensed by COFEPRIS to act as your Local Representative in Mexico.
Registering your medical device for sale in Mexico requires approval from the Comisiόn Federal para la Protecciόn contra Riesgos Sanitarios (COFEPRIS), a division of Mexico’s Ministry of Health. Some devices that have previously obtained market authorization in the US, Canada or Japan qualify for expedited review by COFEPRIS. However, registering a device or IVD in Mexico can be challenging. Little information on the registration process is available in English from COFEPRIS, the division of the Mexican Ministry of Health (Secretaría de Salud) responsible for medical device and IVD oversight.
COFEPRIS classifies medical devices into four categories based on risk to the patient. Table 1 summarizes the 4 Device Classes and their associated risk description. Table 2 summarizes various registration pathways for Medical Devices.
- GRP can determine the proper classification for your medical device and can provide an initial assessment on grouping acceptability, if necessary.
- Many manufacturers work with us on standard Third-Party Review submissions, as well as the equivalency route available to certain devices already approved by the US FDA, Health Canada, or Japan.
- Our in-depth knowledge of the Mexican medical device market ensures that we provide the most efficient and cost-effective regulatory approval strategy for your device.
- We can assist you in preparing medical device registration documents that demonstrate compliance with COFEPRIS.
- Our Mexico Registration Holder services allow us to submit devices for COFEPRIS approval on your behalf.
- Assistance with COFEPRIS inspection (if applicable to product)
- Adverse Effect Reporting ( Technovigilance in Mexico)
- Importation & Clearance in Mexico
- Warehouse and Storage in Mexico
- Distribution
- Organize and support COFEPRIS consultation meetings.
- Recall or incident report assistance
Clinical Trials in Mexico are known as Ensayos Clínicos. Clinical trials authorizations with the purpose of registering a pharmaceutical product are requested based on the type of research, the origin of the product or the research procedure. Applicants may submit the documents to gain authorization to perform Clinical Trials/Human Subjects Research Protocol directly to Cofepris or request a preliminary evaluation report to a UHAP (support units enabled to emit preliminary report).
UHAP Evaluations:
UHAP evaluations are voluntary. Contact method and costs are not standardized among UHAPs. The preliminary report attached to the file submitted to Cofepris may speed up the processing process. Applications including UHAP reports may be issued in up to 30 business days.
Clinical Trial Consulting Services
GRP will provide clinical trial consulting services, including consultations with all local government. We can help you develop an effective Clinical Investigation Plan with clinical trial strategy, clinical trial study design, and clinical trial protocol.
Regulatory Support
We can assist with clinical trial applications (CTA) and clinical trial notifications (CTN) as required for clinical trial initiation in Mexico. Our on-the-ground teams consist of experienced professionals who will meet with the appropriate regulatory agencies on your behalf throughout the clinical study. We will provide guidance on meeting the Institutional Review Board (IRB) and Independent Ethics Committee (IEC) requirements.
Clinical Trials Management
We can comprehensively manage the clinical trials process by conducting the trials and completing the clinical trial reports. Our experts will evaluate clinical trial and non-clinical trial data; conduct gap analyses; and determine safety and efficacy, along with primary and secondary endpoints, as required for your specific product.
Quality Compliance and Audits
We can conduct on-site audits of your clinical trials and consult on the guidelines for Good Clinical Practice (GCP), Good Laboratory Practice (GLP), Good Pharmacovigilance Practices (GVP), Good Quality Practice (GQP), Good Manufacturing Practice (GMP), etc.
Adverse Events and Post Market Surveillance
We will report adverse events and implement suggestions on additional tests and required data. We can assist in post-approval and post-clearance clinical trials to maintain the safety, efficacy, and performance of the product through its life cycle.
Compliance with design control procedures.
The US Food and Drug Administration (FDA) and other market regulators including COFEPRIS require proof of compliance with established design control procedures for some device classifications. It is important to show ongoing compliance all the way from device conception through release to market.
To ensure ongoing compliance with quality system procedures, you should;
- evaluate your pre-production QMS using internal audits at least once a year.
- Conducting periodic internal audits also supports the evolution of the QMS when new processes are added to the system as the organization approaches launch of the product.
GRP QMS implementation Services:
- Document and records control
- Training on regulatory requirements and internal procedures
- Design and development
- Risk management
- Software development (if applicable)
- Supplier evaluation
- Control of measurement equipment
- Perform internal quality system audits
TABLE 1: MEDICAL DEVICES CLASSIFICATION
Device Class | Description |
---|---|
Class I | Lowest Risk |
Class IA | Low Risk |
Class II | Medium Risk |
Class III Devices | High Risk |
TABLE 2: GENERAL MEDICAL DEVICES SUBMISSION MATERIAL TO COFEPRIS
Module | Included Documents |
---|---|
I | Application Form and/or Escrito Libre (Detailed Cover Letter with Product Specifications) |
II | Proof of payment of COFPERIS Fee– Original and 2 copies |
III | Letter accepting research involvement and responsibilities of researcher(s)/sponsor(s) expressing also prevention measures of conflict of interests, especially if there is monetary compensation involved. Letter issued by the CRO/sponsor describing the human resources and materials to be destined in the research in all research sites. Letter from the sponsor with a monitoring/auditing plan |
IV | Research Protocol, Informed Consent Letters, Timeframe/Schedule |
V | Ethics Committee Certificate (Copy), Research Committee Certificate (Copy), Research and Ethics Committee Approval Report, Research Committee Approval Report |
VI | Other Documents requested by current health regulations in the field of research for human health |
VII | POA between GRP and Client |
GRP Experience & Case Studies
Case Study 35: Regulatory Strategy, Gap Analysis, Classification and Registration of Cosmetic medical devices in Mexico
The Client is a Canada based manufacturer of iontophoresis-based medical devices machine used to treat excessive sweating of underarms, hands and feet.
Case Study 36: Regulatory Support for Visual Electrodiagnostic Testing System in Mexico and Brazil
The Client is a leading US based manufacturer of visual electrophysiology products used for the diagnosis of retina and optic nerve disease.
Case Study 90 : Registration of COVID-19 Test Kits in Mexico
The client is a Korean medical company that developed COVID-19 test kits and was looking for a partner to help them enter the Mexican market.
Pharmaceuticals
Mexico’s Health Authority:
Pharmaceuticals in Mexico are regulated by COFEPRIS (Comision Federal para la Proteccion contra Riesgos Sanitarios).
Cofepris Drug Definition:
According to Article 221, Section I of the General Health Law a drug is defines as;
“Any substance or mixture of substances of natural or synthetic origin that has a therapeutic, preventive or rehabilitative effect, that is presented in a pharmaceutical form and is identified as such by its pharmacological activity, physical, chemical and biological characteristics. When a product contains nutrients, it will be considered a medicine, as long as it is a preparation that contains individually or in association: vitamins, minerals, electrolytes, amino acids or fatty acids, in concentrations higher than those of natural foods and it is also present in some defined pharmaceutical form and the indication of use contemplates therapeutic, preventive or rehabilitative effects.”
New Molecule Definition:
“Active Principle of a medication, of natural or synthetic origin, not previously used in the country and whose efficacy, safety and therapeutic purposes have not yet been completely reported in the scientific literature.
GRP Pharmaceutical Services:
Through our local office in Mexico, GRP can act as your local authorized agent in Mexico and our regulatory team can support your company throughout the whole products’ lifecycle, ensuring compliance with local regulations and providing vital scientific and strategic advice from products’ development till commercialization.
Authorized Local Representative (Mexico)
Mexican Health Authority (COFEPRIS) requires that any foreign pharmaceutical or biologic company, without a physical location in Mexico, to appoint a Mexican Registration Holder in Mexico before registering and selling any product in Mexico.
GRP- Mexico office is licensed by COFEPRIS to act as your Local Representative in Mexico.
Registering your product for sale in Mexico requires approval from the Comisiόn Federal para la Protecciόn contra Riesgos Sanitarios (COFEPRIS), a division of Mexico’s Ministry of Health. Some devices that have previously obtained market authorization in the US, Canada or Japan qualify for expedited review by COFEPRIS.
Registering a product in Mexico can be challenging process. GRP’s consultants know how to combine the classification and grouping documents with years of practical experience working with COFEPRIS to help you find the optimal and most cost-effective registration strategy, based on your company’s needs and goals for the market.
Application Process:
The formal application process starts when a pharmaceutical company takes the compilation of documents known as the application dossier to the COFEPRIS office.
If your product falls into the category of ‘new molecule’, you have to request a meeting with the New Molecule Committee before submitting the application.
Cases Considered as a “New Molecule”
- New drug substances (new in the world or new for Mexico)
- New combinations of drug substances (for Mexico)
- New indications
- Other special cases (e.g. similar biotherapeutic products)
Up until recently, the average application could take anything between 1 and 4 years to be reviewed and approved. With some key changes implemented lately, such as the pre-revision process by Third Authorized Parties, or the Agreement for Innovation, timelines are decreasing dramatically, to just some months to a year.
- Regulatory Strategy & Regulatory Intelligence for Mexico
- Support Communication with COFEPRIS
- Product Dossier Preparation
- Product Registration
- Pharmacovigilance
- Importation & Clearance
- Warehousing & Storage
- Distribution
- Product Life-cycle maintenance
- Adverse Effect Reporting to COFEPRIS
- Recall or incident report assistance
An understanding of the regulatory requirements in Mexico and experience in dealing with the local regulatory authorities (Cofepris) is essential in administering a smooth, successful clinical trial in Mexico. Global Regulatory Partners, Inc. (GRP) can act as your contract research organization (CRO) or help you identify a qualified CROs in Mexico. Our local teams and affiliated partners located in Mexico and all-around LATAM are highly experienced with the related regulatory affairs and can locally manage the full clinical trial process to ensure that it is conducted effectively and successfully.
The primary legislation for conducting clinical trials in Mexico is the Health Law Regulations for Health Research (Reglamento de la Ley General de Salud en Materia de Investigación para la Salud) (RLGSMIS) and the NOM for Health Research in Human Beings.
Clinical Trial Consulting Services
GRP will provide clinical trial consulting services, including consultations with all local government. We can help you develop an effective Clinical Investigation Plan with clinical trial strategy, clinical trial study design, and clinical trial protocol.
Regulatory Support
We can assist with clinical trial applications (CTA) and clinical trial notifications (CTN) as required for clinical trial initiation in Mexico. Our on-the-ground teams consist of experienced professionals who will meet with the appropriate regulatory agencies on your behalf throughout the clinical study. We will provide guidance on meeting the Institutional Review Board (IRB) and Independent Ethics Committee (IEC) requirements.
Clinical Trials Management
We can comprehensively manage the clinical trials process by conducting the trials and completing the clinical trial reports. Our experts will evaluate clinical trial and non-clinical trial data; conduct gap analyses; and determine safety and efficacy, along with primary and secondary endpoints, as required for your specific product.
Quality Compliance and Audits
We can conduct on-site audits of your clinical trials and consult on the guidelines for Good Clinical Practice (GCP), Good Laboratory Practice (GLP), Good Pharmacovigilance Practices (GVP), Good Quality Practice (GQP), Good Manufacturing Practice (GMP), etc.
Adverse Events and Post Market Surveillance
We will report adverse events and implement suggestions on additional tests and required data. We can assist in post-approval and post-clearance clinical trials to maintain the safety, efficacy, and performance of the product through its life cycle.
Table 1: Pharmaceutical Registration Pathway
Registration Pathway | Description | Application Requirements | Timelines |
---|---|---|---|
Equivalency Review Process |
If your device has been approved in the US, Canada or Japan, you may qualify for an equivalency review Equivalency reviews require the submission of a Summary Dossier with less detailed technical information, and initial registration may be faster than the standard review process |
US, Canada Equivalency: Application Form, plus: – Proof of payment, based on COFEPRIS classification – MRH documentation – Proof that device meets equivalency requirements – Product information, including: • Materials information • Manufacturing process • Testing completed • Sterility information, if applicable • Expiration date, stability studies, if applicable • Clinical data, if applicable • Compliant labeling with instructions for use. |
APPLICATION US 3-8 months CANADA 3-8 months —— VALIDITY PERIOD 5 Years |
Japan Equivalency: Application Form, plus: – Proof of payment, based on COFEPRIS classification – MRH documentation – Proof that device meets equivalency requirements • Notification of Exportation • Original Certificate of Free Sale with codes; no older than one year • Certification issued by the Registered Certification Body or MHLW: – Description – Indications for use – Formula and/or composition, if applicable – Stability information, if applicable – Sterility period, if applicable – Primary and secondary packaging information, if applicable – Compliant labeling, instructions for use. |
APPLICATION Japan 3-8 months —— VALIDITY PERIOD 5 Years |
||
Standard Review |
to register through the standard review process, you must prepare a detailed Registration Dossier that includes full product technical information and applicable testing results. Applications going through the standard review process are also eligible for Third Party Review, which has the potential to expedite the approval process, and incurs additional cost to pay for the third-party reviewer. |
Application Form, plus: – Proof of payment, based on COFEPRIS classification – MRH documentation – Proof of home country approval – Detailed product information, including: • Materials information • Manufacturing process • Testing completed • Sterility information, if applicable • Expiration date, stability studies, if applicable • Clinical data, if applicable • Compliant labeling, instructions for use |
APPLICATION Standard Review 3-6 months —— VALIDITY PERIOD 5 Years |
Case Study 57: Registration of Vaccines (Biologic) in Mexico
European drug manufacturer is a fully integrated vaccines company focused on the development, manufacture and commercialization of life-saving vaccines. The Client wanted to market their product in Mexico and was looking for a local partner with experience with vaccines and biologics, that can represent them in Mexico.
Case Study 53: License Transfer of Women Health Product in Mexico
The Client is a UK based specialty pharmaceutical company that had acquired global license for a women health products (contraceptives products). Client did not have a presence in Mexico and was seeking a trusted partner to initiate license transfer in Mexico and to act as legal representative for the company in Mexico. Client did not have any experience with Cofepris drugs regulations
Cosmetics
Mexico’s Regulatory Health Authority:
Cosmetics are regulated by COFEPRIS (Comision Federal para la Proteccion contra Riesgos Sanitarios).
Cofepris Cosmetic Definition:
In Mexico, cosmetics are defined as:
“Products intended to be brought into contact with the parts of the human body to clean, perfume, help and with the principal purpose of cleaning, perfuming, helping to modify their appearance, protecting, keeping in good condition, correcting body odors or reducing alterations in the functioning of healthy skin.”
GRP Cosmetic Services:
Global Regulatory Partners Inc. (GRP) office in Mexico City provides end-to-end regulatory affairs services for cosmetics that include: regulatory intelligence, regulatory strategy, product classification, formulation review, claim assessments and labeling assessment in compliance with COFEPRIS requirements.
Through our local office in Mexico, GRP can act as your local authorized agent in Mexico and our regulatory team can support your company throughout the whole products’ lifecycle, ensuring compliance with local regulations and providing strategic advice concerning product classification from products’ development till commercialization.
Authorized Local Representative
Global Regulatory Partners Mexico (GRP-Mexico) has local offices in Mexico and is licensed by the COFEPRIS to act as your authorized local agent for your Cosmetic and Personal Care Products.
GRP- Mexico team of professionals are experts in worldwide supply, registration, manufacturing and labeling of Cosmetics and PCPs. GRP-Mexico helps manufacturers, distributors, and marketers of cosmetics in Market Access into Mexico.
Foreign Clients that will need Notification of their Cosmetics in Mexico without investing in opening a local subsidiary can use GRP license, experience and local resources for the submission and importation of their products.
Registration with Cofepris:
In Mexico, a cosmetic company must register with the SSA (Secretariat of Health) for a physical and chemical analysis, complete with a Spanish translation and / or a free sale certificate and consular legalization.
The Ministry of Health in Mexico, through the Federal Commission for the Protection against Sanitary Risks (COFEPRIS) standardized the regulation that applies to the cosmetics products industry in order to meet International best practices that compare them with those of developed countries.
With the recent change in the regulations is no longer mandatory to apply for product classification or sanitary license to COFEPRIS for cosmetic products. As the process isn’t as stringent anymore so cosmetics can just be notified to COFEPRIS by including the product in the business license and importation permit application in order to import the product.
The Ministry has laid down a fixed set of requirements and recommendations to ensure that each product enters the market meeting regulatory standards, providing that cosmetic companies follow the new labeling procedures stringently. This standard is mandatory in the national territory to persons or entities engaged in the process or importation of cosmetic products.
- Quali-quantitative Formula
- INCI of all cosmetic ingredients
- GRP Business License
- PoA of Representation (between GRP and Client)
Final Label must be developed and completed prior Submission of to Cofepris.
The company must check that the ingredients included in the cosmetic product are not listed in the forbidden or restricted list of ingredients as defined in Articles 234 and 245 of the General Health Law, drugs, prepared drugs and the following may not be used in the preparation of perfume and beauty products.
Global Regulatory Partners Inc. (GRP) provides a comprehensive range of Regulatory Services related to the analysis of the list of cosmetic and PCP ingredients, the review of their formulation and labeling. GRP-Mexico can review your products and make sure they comply with the COFEPRIS regulations.
The Mexico’s Ministry of Health has published a labeling standard for pre-packaged cosmetics to clear up instances where a product might be misinterpreted or even misbranded. The standard PROY‑NOM‑141‑SSA1/SCFI‑2010 ‘Labeling of pre‑packaged cosmetic products, Health and commercial labeling,’ is published in the administration’s official journal (Diario Oficial de la Federación).
Mexico’s General Label Requirements:
- All the labeling content should be in Spanish.
Include generic and specific name of the product
Include identification of the person responsible for the product.
Include the batch number
Include the Instructions or mode of use
Not include prohibited property statements
GRP-Mexico Food Supplement Services:
- Authorized Local Representative
- Ingredient Compliance Review
- Label Compliance & Development
- Regulatory affairs
- Product Registration with Cofepris
- Importation & Customs
- Distribution
- Commercialization
Article : Notification of Cosmetics in Mexico
Cosmetics Regulations in Mexico, the important items to consider when seeking to enter the market.
Case Study 85: Notification of Cosmetics in Mexico
The client is a large European Cosmetic company that develops and manufactures cosmetics in Europe and commercializes them in Europe and USA. The company wanted to extend its business to Latin America, starting by Mexico and was looking for a local partner that can act as their local representative in Mexico, register their products with Cofepris and help them importing the products to Mexico.to facilitate its market access.
Food Supplements
Regulatory Health Authority:
The Federal Commission for Protection again health risks (COFEPRIS) is the main body in charge of Nutraceutical regulation in Mexico.
Food Supplement Definition:
Article 215 of the General Health Act defines dietary supplements as “herbal products, plant extracts, traditional foods, dehydrated or concentrated fruit added or not, vitamins or minerals that may arise in a pharmaceutical form and intended use is to increase total dietary intake, supplement it or replace some component of one’s diet.”
GRP Mexico Supplement Services:
Global Regulatory Partners, Inc. (GRP), has a team of experts in Mexico who can help Nutraceutical and food supplements companies in Mexico during their products’ development. The team reviews the list of ingredients to make sure that they are safe for consumers and are within the daily dose limits allowed by local regulations.
The team also reviews and validate the content of the products labeling and packaging and makes sure that nutrient content claims and health claims made by the manufacturer are validated and supported by scientific data before any products’ commercialization.
Authorized Local Representative ( Mexico)
A marketing authorization issued by the Federal Commission for Protection against Sanitary Risk (COFEPRIS) is required to sell herbal, homeopathic and vitamin medicines manufactured in other jurisdictions. A recordal (clave alfanumérica), a type of approval, with COFEPRIS is required to sell herbal remedies.
Selling Supplements without a marketing authorization can be prosecuted as a criminal offence. Global Regulatory Partners, Mexico (GRP-Mexico), team of experts in Mexico support food supplements companies in Mexico during their products’ development, Product Registration, Importation and Distibution.
Food Supplements are a regulated Health Product in Mexico.
Supplements does not require license (registration in Cofepris), however, they need to be notified to COFEPRIS known as a “consultation of product classification” It is a free procedure, through which the health authority, based on the formulation and labeling of the products, corroborates whether or not they comply with the legal framework of food supplements and, in case of refusal, indicates the corresponding regulatory figure.
There are 3 Possible answers to the classification:
- It is a Food supplement
- It is NOT a Food supplement
- Request for more information
Failure to obtain a positive approval from Cofepris will lead to your products being held at customs.
- Quali-quantitative Formula
- Developed Packaging and Labeling for Mexico
- Name of the ingredient, scientific name and monographs for any uncommon substances.
- GRP Business License
- PoA of Representation (between GRP and Client)
GRP Mexico team has the expertise in reviewing and support Development of Label Development in Mexico. COFEPRIS has many strict standards for Food Supplements such as Article 215 of the General Health Act. GRP-Mexico can review your products and make sure they comply with Article 215 of the General Health Act and other requirements.
In addition, the regulations have certain rules governing the provision of voluntary nutrition information, particularly for the front of pack labeling, the nutritional labeling of non-pre-packaged foods and the energy labeling of alcoholic drinks. Some nutrients are now prohibited to be declared. A nutrient content claim expressly or by implication characterizes the level of a nutrient in a dietary supplement.
GRP-Mexico can review your products and make sure they comply with COFEPRIS regulated under Article 215 of the General Health Act
GRP-Mexico Food Supplement Services:
- Authorized Local Representative
- Ingredient Compliance Review
- Label Compliance & Development
- Regulatory affairs
- Product Registration with CofeprisImportation & Customs
- Distribution
- Commercialization
All food supplements, prior to their advertising permission process, importation and distribution must have a positive response to the classification query.
Video: Registration of Food Supplements in Mexico
Food Supplements are regulated products in Mexico. And must be registered with COFEPRIS, Mexico’s Health Authority, prior importation. Check out our video to understand the registration requirements.
Case study 058: Registration of food supplement in Mexico
The Client is a USA based nutrition supplement manufacturer that manufactures and sells innovative range of health supplements in USA and other countries.