Not necessarily. After September 1, 2026, a supplement without a notification number on its label should not be classified as irregular based on that omission alone. Anvisa kept transition situations in which a product may legally remain on the market without that information printed on the package. A proper check requires combining the official database with the manufacturing date, expiration date, manufacturer identification and, in some cases, the product’s earlier status with the local health surveillance authority.
Two different situations must be kept separate. The first is a product that has already been notified to Anvisa but is still using labels produced before the notification. The second is an older transition lot that may remain on the market even though it was not notified. Mixing up these two cases is the main reason for premature conclusions.
Short answer: a missing number is a reason to check, not a verdict
According to Anvisa guidance published in August and September 2026, the end of the transition deadline on September 1 did not automatically make every supplement reaching consumers without a notification number on the label irregular.
- If the product has already been notified: labels produced before the notification may be used for up to 180 days from the notification date, solely to use up existing packaging materials. In this situation, the product must be regularized, its composition and labeling cannot have other changes pending, and the only permitted omission is the statement “Alimento notificado na Anvisa” together with the process number.
- If the product has not been notified but is transition stock: supplements properly communicated to the local health surveillance authority by August 31, 2024 and manufactured by September 1, 2026 may continue to be sold until their expiration date, even without notification to Anvisa.
The practical question is therefore not only “is there a number on the label?”, but “what is the regulatory status of this product and this lot?”.
What should appear on the label of a notified supplement
For notified supplements, Anvisa says the package should carry the Portuguese wording “Alimento notificado na Anvisa”, followed by the notification process number. Products that still appear as registered should carry “Alimento registrado na Anvisa” and the corresponding registration number.
These identifiers can be used to locate the product in the Anvisa Food Consultation Portal. For a notified supplement, the official guidance is to use the advanced search and enter the process number. The portal shows the product’s status: “Ativo” means it is regularized, while “Inativo” means it is not regularized.
When the number is missing from the label, it is still worth trying to identify the product using other available details, such as its name or brand and manufacturer information. Anvisa’s general product-check guidance also allows searches by product name or brand, company tax ID (CNPJ), registration number or process number.
Verification flow: how to check without relying only on the label
- Photograph and record the product details. Note the exact name and brand, manufacturer or importer’s legal name, CNPJ if shown, lot number, manufacturing date, expiration date and manufacturer address. These details help distinguish similar products and determine which transition rule may apply to the lot.
- Open the Anvisa Consultation Portal. Go to consultas.anvisa.gov.br/#/alimentos/ and use the food search. If a process or registration number appears on the label, search for it. If it does not, try the other identifiers available.
- Open the result and make sure it matches the product. Finding a similar name is not enough. Compare the responsible company, product description and other displayed details. If the result is Ativo and matches the supplement you have, there is official evidence of regularization.
- If the product is active but the label lacks the number, check the labeling transition. The omission may be compatible with the use of a label produced before notification for up to 180 days from the notification date. This rule does not excuse other pending changes: according to Anvisa, in this situation the product cannot have composition or labeling changes other than the specific absence of the notification statement and process number.
- If the product does not appear in the portal, do not immediately conclude that the lot is irregular. It may still be transition stock: a product communicated to the local health surveillance authority by August 31, 2024 and manufactured by September 1, 2026. Anvisa allows that group to be sold until expiration even without central notification.
- To confirm an older-stock case, contact the local health surveillance authority. Anvisa states that there is no national database consolidating all older communications filed directly with states and municipalities. Use the manufacturer address on the label to identify the competent authority and provide the lot, manufacturing date, expiration date and traceability details.
- Also check products already identified as irregular by Anvisa. The “Consulte produtos irregulares” page allows searches of published alerts. Finding the supplement there is relevant evidence; not finding it, however, does not replace confirmation of regularization.
Two transition rules that look alike but are not the same
| Situation | What Anvisa allows | What to check |
|---|---|---|
| Product already notified, but label has no number | Use of labels produced before notification for up to 180 days from the notification date, to exhaust packaging materials, under Anvisa’s stated conditions. | Active result in the portal, correct product match and notification date; if uncertain, confirm with the company or health authority. |
| Older product still without notification | Sale until expiration if it was communicated to the local health authority by August 31, 2024 and the lot was manufactured by September 1, 2026. | Manufacturing date, expiration date, lot, manufacturer and confirmation of the earlier local communication by the competent health authority. |
| Lot manufactured after September 1, 2026 with no notification found | The older-stock exception described by Anvisa does not cover that lot. | Repeat the search with the correct identifiers and request clarification from the manufacturer or health authority before treating the product as regularized. |
If the supplement was manufactured after September 1, 2026
Anvisa described the exception for products without notification as applying to items communicated to the local health surveillance authority by August 31, 2024 and manufactured by September 1, 2026. A lot manufactured after that date therefore does not fall under this older-stock exception.
If a post-transition lot has no number on the label and also cannot be found as regularized in the Consultation Portal, the sound documentary approach is to treat its status as unconfirmed, repeat the search with the correct identifiers, and ask the manufacturer and competent health surveillance authority for clarification. Missing information should not be replaced with assumptions.
What an “Ativo” result confirms — and what it does not
An Ativo status in the Consultation Portal confirms the regulatory status of that product in Anvisa’s database. It is not the same as saying that the supplement is necessary, indicated or appropriate for a particular person.
When closing the transition, Anvisa also stressed that the September 1, 2026 deadline concerned regularization through notification and did not create a new grace period for other sanitary requirements. The technical rules that apply to supplements remain in force. In other words, regulatory regularization should not be used as a shortcut to infer individual clinical benefit.
Likewise, the absence of a product from the irregular-products list is not a certificate of compliance. The main verification remains the product’s status in the portal or, for older cases that were not centrally recorded, confirmation from the local health surveillance authority.
Checklist to keep if you need clarification
- Clear photos of every side of the label.
- Supplement name and brand.
- Manufacturer or importer legal name, CNPJ and address, when available.
- Lot number.
- Manufacturing date and expiration date.
- Place and date of purchase.
- The result, or lack of a result, in the Anvisa Consultation Portal.
These details allow the company and health authority to identify the lot and evaluate traceability, dates and transition eligibility. If there is a concrete suspicion of irregularity, Anvisa’s supplement pages also explain how to submit a report, including photos of the label.
In summary
After September 1, 2026, do not use the missing number on the label as the only criterion. Check Anvisa first. If the product is active, the missing number may be explained by the up-to-180-day labeling transition. If there is no result, determine whether it is an older lot that may be covered by the local-communication regime and manufacturing deadline of September 1, 2026. When the needed confirmation depends on information that is not on the label or in the portal, the health surveillance authority responsible for the manufacturer’s location is the appropriate source to close the check.
This article addresses regulatory verification and does not recommend any supplement, dose or individual use.
