Mexico asks for zero product filings, Brazil one per SKU

Mexico has no product-level filing at all

If a Mexico entry quote contains a line like "six months waiting for sanitary registration", delete it. Article 376 of the General Health Law enumerates the product classes that require a sanitary registration, and perfumery and beauty products are not on that list. There is no stage at which a cosmetic waits for product-by-product approval.

What disappears is the product file; the establishment obligations stay. Article 200 Bis requires a notice of operation to the health ministry or the state government within 10 days of starting operations, and the filing itself carries no fee. On the import side, Article 285 fixes the importer as a party domiciled in Mexico, and Article 286 Bis requires a sanitary certificate from the country of origin even where no prior import authorization applies, while allowing random sampling.

The exposure that remains is the label. Pre-packaged products must meet the applicable Mexican official standards under Articles 210 and 212, and cosmetic labeling falls to NOM-141-SSA1/SCFI-2012, which requires every element in Spanish. Labeling breaches are fined 6,000 to 12,000 UMA under Article 421, so in a market with no registration the money goes wrong at the print run, not at review.

Brazil files one per product, but registers only nine groups

Brazil sits at the other end. Every product carries one ANVISA procedure. Not every procedure is a registration, though. Article 34 of RDC 907/2024 fixes the groups subject to registration at nine, and Article 35 declares every group outside that list exempt from registration and subject instead to prior communication. The nine are sunscreens, children's sunscreens, tanning products, hand sanitiser gel, perming products, combined straightening-and-dyeing products, hair straighteners, insect repellents and children's repellents.

The column most often confused here is the grade. The Grade 1 and Grade 2 definitions in Article 3, items XVII and XVIII split products by how much surveillance they need, following the indicative lists in Annex I; they do not decide which procedure applies. A product classified as Grade 2 still goes through prior notification if it is absent from the Article 34 list. A plan that reads "Grade 2, so registration first" has reserved months of calendar for nothing.

Three lines carry the point. Mexico's product column is empty, and Brazil's is full but narrow where review is concerned.

Ten years applies to both routes

Plenty of brands still budget Brazil on a five-year cycle. The current rule says ten. Article 40 sets registration validity at 10 years from publication in the Federal Official Gazette, renewable for successive equal periods, with the renewal request due in the first half of the final year of the decade.

The notification route has no renewal step. Article 41 exempts registration-free products from revalidation and instead requires a declaration of interest every 10 years from the date of notification. The window is the last six months of that decade, and a dossier not declared in time is cancelled. Writing nothing in the calendar because the product was notified rather than registered is the most common failure here.

The paperwork does not belong to the Korean head office

A foreign company cannot obtain ANVISA approval directly. A company established in Brazil holds a valid AFE and becomes the legal holder and responsible party for the product, with imports and distribution flowing through that entity. Even the notification is filed online by the Brazilian company responsible for the product.

Mexico also ties the importer to a local domicile, but what gets tied differs. In Mexico the act of importing is local and the product itself has no holder; in Brazil the product acquires one. The gap shows up the day a distributor changes. So put transfer-of-holder and data-return clauses in the Brazilian contract, and responsibility for print plates and origin-country sanitary certificates in the Mexican one.

The lighter paperwork costs more at the border

Here the direction reverses. Mexico published an amendment to the General Import and Export Taxes Law on 29 December 2025 raising duty on 1,463 tariff codes, in force from 1 January 2026 with no transition period. It applies to goods originating in countries with no FTA in force, and Korea is one of them. On a sector reading, cosmetics moved from 10% to 25%.

The decree's transitory articles run these rates to 31 December 2026. Temporary measures of this kind have been renewed before, so budget 2027 shipments at 25% and treat any reduction as upside. On the Brazilian side the 18% is not the end of it, because ICMS is calculated inside its own base and lifts the effective burden, which is why comparing the two countries on headline duty alone goes wrong.

In short

• Mexico has zero product filings. The establishment notice is due within 10 days, and the label must meet NOM-141 in Spanish.
• Brazil files one per product, but registration covers only the nine groups in Article 34. Do not treat Grade 2 and registration as the same column.
• Both Brazilian routes run on ten years. Notified products need a declaration of interest each decade or the dossier is cancelled.
• The tariffs invert the picture: 25% in Mexico against 18% of CIF in Brazil, with no Korea FTA in either market.

Which ingredients are moving right now is on today's ingredient signal, and category price bands and cost structure sit in the product planner.

*Sources: Anvisa, Resolução RDC nº 907 of 19 September 2024 — Article 3 items XVII and XVIII, Articles 34, 35, 40, 41 and Annex I / Anvisa, Personal Hygiene Products, Cosmetics and Fragrances (English guidance) — AFE and Brazilian-entity requirement, 10-year validity / Ley General de Salud (Mexico), Articles 200 Bis, 210, 212, 285, 286 Bis, 376 and 421, as summarized by Rivenza, "Registro sanitario de cosméticos en México" / OMC Medical, "Mexico Cosmetic Product Compliance", 13 August 2026 — NOM-141-SSA1/SCFI-2012 labeling / Alvarez & Marsal, "Mexico 2026 Trade and Customs Updates" — decree of 29 December 2025, cosmetics 10% to 25% / Freightspot, "Aranceles Mexico paises sin TLC 2026" — 1,463 tariff codes and the non-FTA scope / dutiable.io, Brazil Import Duty Rates 2026 — HS 3304 MFN rate of 18%*