Changes after Food Registration in Nicaragua
For the commercialization of food products for human consumption in Nicaragua, it is necessary to obtain a sanitary registration beforehand and, of course, that the manufacture of the product has the proper sanitary license of operation. Once the registration process has been completed before the Ministry of Health, a registration number is assigned, with a validity of five renewable years.
It is common that in the course of these five years the products, manufacturers or title holders, have technical or legal changes. When we say technical changes we refer to changes in the product, its formulation, presentation, labeling, trademark, among others, as long as they do not alter the nature of this. Legal changes are related to the title holder of the registration or the manufacturer, his name, address or even the transfer of the rights of the registration on the product.
The aforementioned changes must be notified to the Ministry of Health as post-registration changes. However, not every change requires notification, for example the inclusion of temporary advertising material in the labeling of the products related to a temporary promotion, or inclusion of allusive stickers or information related to promotions. In this case the notification is not necessary, because it is about changes in the temporary labeling and it will not affect the nature of the product or even its presentation.
On the other hand, the manufacturer or owner must take into account that when it comes to legal changes such as company name, holder of the registration by transfer, distributor, or any information that is mandatory content in the product labeling, should not only be notified with backing of the legal documents that certify the change, but also that the authority must request a reasonable time for the exhaustion of products with the previous labeling in the commerce, so as not to have problems with the importation or commercialization.
García & Bodán has a regulatory team able to visualize the strategies to follow for this type of change notification, anticipating requirements, times and avoiding inconveniences.
Mayra Navarrete Crovetto
Senior Associate
García & Bodán
Nicaragua