On May 15, 2025, the Brazilian National Health Surveillance Agency (ANVISA) released Normative Instruction IN No. 361/2025, amending Normative Instruction IN No. 28/2018, which outlines the lists of components, limits of use, claims and complementary labeling of food supplements.
The amendments, which took immediate effect, primarily revise the annexes of IN No. 28/2018. However, a 24-month grace period has been granted to businesses for compliance and necessary adjustments.
Amendments to Annex 1
Annex I lists constituents authorized for use in food supplements, excluding those intended for infants (0–12 months) and young children (1–3 years). The updates include the addition of a new source of vitamin D and two new bioactive substances.
Nutrients | |
Vitamin D | CAS |
Calcidiol obtained from Saccharomyces cerevisiae xii | 63283-36-3 |
Bioactive Substances | |
Phenolic compounds of Opuntia ficus-indica | CAS |
Opuntia ficus-indica extract | / |
Xylooligosaccharides | CAS |
Xylooligosaccharides | / |
xii Constituent allowed only for food supplements indicated for individuals over 11 years of age, including pregnant and breastfeeding women.
Amendments to Annex 3
Annex 3 establishes minimum limits for constituents in food supplements, based on daily consumption recommendations and target population groups. The amendments introduce the minimum intake limits for two bioactive substances and revise footnote iii.
Bioactive substances | Units | Population groups | |||||||
0-6 months | 7-11 months | 1-3 years | 4-8 years | 9-18 yeas | ≥ 19 years | Pregnant | Lactating | ||
Phenolic compounds of Opuntia ficus-indica | mg | NA | NA | NA | NA | NA | NE (as niacin equivalent) | NA | NA |
Xylooligosaccharides | mg | NA | NA | NA | NA | NA | NE (as niacin equivalent) | NA | NA |
iii As Cholecalciferol. 1 μg cholecalciferol = 40 IU Vitamin D = 0.3333 μg calcidiol.
Amendments to Annex 4
Annex 4 defines maximum limits for constituents in food supplements by daily recommended intake and population group. The amendments add upper limits for the same two bioactive substances and update footnote iii.
Bioactive substances | Units | Population groups | |||||||
0-6 months | 7-11 months | 1-3 years | 4-8 years | 9-18 yeas | ≥ 19 years | Pregnant | Lactating | ||
Phenolic compounds of Opuntia ficus-indica | mg | NA | NA | NA | NA | NA | 54.6 | NA | NA |
Xylooligosaccharides | mg | NA | NA | NA | NA | NA | 2 | NA | NA |
iii As Cholecalciferol. 1 μg cholecalciferol = 40 IU Vitamin D = 0.3333 μg calcidiol.
Amendments to Annex 5
Annex 5 lists authorized claims for food supplements, along with required conditions for use. The amendments add three authorized health claims for astaxanthin.
Constituents | Authorized claims | Specific composition and labelling requirements |
Astaxanthin | Astaxanthin is an antioxidant that can help protect against free radical damage. | The claim is restricted to food supplements whose minimum amount of astaxanthin provided in the daily consumption recommendation of the product is 2 mg. |
Astaxanthin may aid in visual accommodation. | The claim is restricted to food supplements whose minimum amount of astaxanthin provided in the daily consumption recommendation of the product is 4 mg. | |
Astaxanthin can help reduce eye strain. | The claim is restricted to food supplements whose minimum amount of astaxanthin provided in the daily consumption recommendation of the product is 5 mg. |
Amendments to Annex 6
Annex 6 outlines additional labeling requirements. The amendments introduce warnings for the following constituents:
Constituents | Additional labeling requirements |
Calcidiol obtained from Saccharomyces cerevisiae | The warning "This product should not be consumed by children under 11 years of age." should appear on the product labeling. |
Phenolic compounds of Opuntia ficus-indica | The warning "This product should not be consumed by pregnant women, breastfeeding women and children." must appear on the product labeling. |
Xylooligosaccharides |
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