The 1st Public Meeting of the Collegiate Board (DICOL) of 2026, held on January 28, was consolidated as a watershed moment for the national pharmaceutical sector. The approval of the revision of RDC No. 327/2019 and of the new regulations for the cultivation of Cannabis sativa L. in Brazil complies with a determination of the Superior Court of Justice (STJ) and establishes an unprecedented environment of regulatory predictability. According to specialists, this milestone is not only a regulatory update, but the implementation of a verticalized production chain that aims to reduce external dependence on inputs and foster national innovation. Below is our assessment of the technical details of this new scenario.

 Publication of RDC 1015/2026: new routes and clinical rigor

The revision of RDC No. 327, established in RDC 1015/2026, maintains the transitional nature of the Sanitary Authorization (AS) but introduces refinements that expand therapeutic possibilities and scientific rigor. The updates take effect 90 days after official publication (i.e. May 4^th, 2026).

Pharmaceutical Form Expansion: the inhalation, oral, buccal, sublingual, and dermatological routes are now permitted. However, modified-release, nanotechnological, and pegylated forms remain prohibited.

Link with Clinical Development: the AS remains valid for 5 years, but its renewal is now strictly conditioned to the submission of a Clinical Development Plan and evidence of progress in studies toward definitive registration as a medicinal product.

Therapeutic Access: the use of products with THC > 0.2% has been expanded to patients with serious debilitating diseases, overcoming the previous restriction that limited such concentrations exclusively to palliative care in terminal situations.

Labeling: the secondary packaging lables of Cannabis products with THC content less than or equal to 0.2% must contain a red band on the front face, while those with THC concentrations above this limit must display a black band. In addition, for products based on Cannabis extract, the qualitative and quantitative relationship of cannabinoids—beyond CBD and THC—present in the finished product in concentrations above 1.0% must be indicated on the label.

The New Regulatory Framework for Cultivation: Control and Security

In compliance with STJ IAC (Competence Assumption Incident) 16, ANVISA approved three new RDCs regulating cultivation for medicinal, research, and associative purposes:

RDC 1012/2026 – Scientific Research: Educational institutions, research centers (ICTs), and pharmaceutical industries may obtain an AE (Special Sanitary Permit) for research with strict security requirements, including 24-hour surveillance and physical protection barriers. The RDC enters into force on August 4^th, 2026.

RDC 1013/2026 – Cultivation for Medicinal Production: restricted to legal entities, with a THC limit of ≤ 0.3%. The regulation requires full traceability, compliance with Good Practices (GSP and GMP – Storage and Manufacturing) and WHO guidelines, and prohibits commercial export of the vegetal specimen and its seeds. The RDC enters into force on August 4^th, 2026.

 RDC 1014/2026 – Sandbox Model (Patient Associations): an experimental and temporary instrument (maximum of 5 years) for patient associations, aimed at generating regulatory evidence under direct oversight by the Agency. Although it has been in force since its publication, a call for project proposals is expected to be published.

 Critical Concepts: reliance and International Harmonization

The new framework reinforces the trend toward Regulatory Reliance. ANVISA will accept equivalent documents from Health Authorities of PIC/S member countries to demonstrate Good Manufacturing Practices (GMP) during a transitional period, facilitating the internalization of global technologies.

In addition, the requirement that imported products be regularized in their countries of origin and the focus on traceability through SNGPC (Brazilian National System for Management of Controlled Medicinal Products) and GTIN codes align Brazil with the best international practices for controlling substances under special regulation.

Strategic and Operational Impact

For industry, the risk of non-compliance is high: failure to meet the adaptation deadlines (ranging from 6 to 12 months) may result in immediate cancellation of the Sanitary Authorization. Strategically, companies should focus on:

• Verticalization: RDC 1015/2026 now explicitly allows the use of APIs and botanical APIs produced in Brazil.
• Post-Market Compliance: Annual preparation of the Periodic Benefit–Risk Assessment Report (PBRER) and maintenance of robust pharmacovigilance systems are mandatory.

The recent publications by ANVISA mark the beginning of a new phase for medicinal Cannabis production and clinical development in Brazil.

At Vita, we have experience with Cannabis Products and can help your company understand and comply with the new resolutions. Contact us