In Peru the sanitary-registration holder must be a DIGEMID-authorized pharmaceutical establishment (droguería) with a BPA warehouse and a químico farmacéutico as director técnico. “Independent holder” here means a droguería that will file and import without locking the manufacturer to its own commercial catalog. Pharma Consulting publishes that product at pharmaconsulting.pe/es/holder-de-registro-sanitario-en-peru/ (indexed holder URL as of 23 August 2026; the page is often Cloudflare-walled to automated fetch). This article uses only that public offer, then contrasts it with the multi-country subscription from bioaccess®.
What Pharma Consulting publishes
Public positioning, from the indexed holder page and on-SERP extract: they act as holder de registro sanitario in Peru through their own DIGEMID droguería, warehouse, and full-time director técnico. They file to DIGEMID. Site navigation lists devices, IVD, and prostheses among the product types they address. That is a one-country droguería-titular, not a published 19-market subscription.
Peru’s current rule set (Decreto Supremo N° 001-2024-SA, as summarized on the bioaccess® IOR guide) permits an independent Peru Registration Holder; additional droguerías can obtain their own CRS. So the manufacturer can keep a neutral titular and still authorize more than one import path — if the first titular is not also the exclusive seller. Giving the droguería-titular role to the first commercial partner recreates the leverage problem under a different noun.
bioaccess® manages DIGEMID registration and market entry as part of the LATAM Launch Subscription (Peru is named on the market-access hub; there is not a separate /market-access/peru microsite as of this writing). Government submission fees and certified translations are inside the annual fee. The holder is bioaccess®’s in-country structure, not the distributor.
Pharma Consulting vs bioaccess®
| Dimension | Pharma Consulting (Peru) | bioaccess® |
|---|---|---|
| Public product | DIGEMID droguería titular + warehouse + DT | LATAM Launch Subscription; own entities as holder/IOR |
| Who must hold | A licensed droguería (their establishment) | Same legal constraint; bioaccess® supplies the in-country establishment |
| Devices | Devices / IVD / prostheses listed in nav | Already FDA-cleared or CE-marked devices |
| Geography | Peru | 19 LATAM markets including DIGEMID |
| Bundle / bridge | Country holder (no published all-in LATAM fee or FIH bridge) | Gov fees + certified translations included; Trial-to-Market Bridge 20% |
The LATAM Launch Subscription from bioaccess® is a different product. bioaccess® registers already FDA-cleared (510(k)/PMA) or CE-marked devices and holds them through its own in-country entities — sanitary registration, registration holder / importer of record, certified Spanish or Portuguese translations (sworn where Brazil and Argentina require it), and government submission fees, inside one annual subscription per country and device family. Public coverage is described as 19 LATAM markets. The registration is held for the manufacturer’s benefit, with defined transfer provisions; it is not leverage. Clinical-trial clients of bioaccess® receive the published Trial-to-Market Bridge (20% off). Specific rates are under review; contact bioaccess® for a quote.
Pharma Consulting is a fair Peru droguería titular. bioaccess® is the operator when Peru is one market next to COFEPRIS, ANVISA, INVIMA, or ANMAT, and the manufacturer wants one holder doctrine in all of them.
If the plan is one country and a homegrown titular is enough, hire the shop that actually publishes that job. If the plan is several LATAM labels under one holder who is not the distributor, start at bioaccess® market access or request a registration quote.
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