In order to work with substances subject to special control, it is necessary to comply with a series of requirements established in Ordinances SVS/MS n. 344/98 and n. 6/99 and other relevant regulations, including a special authorization.
Ordinance SVS/MS n. 344/98 is the Technical Regulation on substances and medicines subject to special control, while Ordinance SVS/MS n. 6/99 is the Normative Instruction of this regulation. RDC 367/2020 updates and establishes requirements for international trade for these substances.
In this sense, companies, including those that carry out research activities for commercial purposes, must apply for Special Authorization (EA), in accordance with the provisions of RDC 16/2014.
On the other hand, educational and research institutions that want to use medicines subject to special control should apply for the Simplified Special Authorization for an Educational and Research Institution - AEP, which authorizes educational and research institutions to acquire and use plants, analytical standards, substances and medicines subject to special control, to develop teaching and research activity, in accordance with the provisions of the RDC 367/2020.
It turns out that this Management of Controlled Products has received requests for Simplified Special Authorization for Educational and Research Institution - AEP requested by companies that carry out research activities for commercial purposes, which must request Special Authorization (AE), as provided by RDC 16/2014.
In the face of these requests for AEP, which were refused, the need to have the standard was verified, in order to clarify in which situations the AE applies.