The emergence of biotechnology is one of the most important changes in the health innovation systems. This paper discusses the rationale that has supported the public policies oriented to boost health biotechnology development in Brazil during 2004 and 2014. Based on a thorough revision of policy documents and on an extensive fieldwork, the study highlights the accumulative path followed by the Brazilian public policies. This research shows how these policies followed an uneven accumulative path were several rationales cohabited integrating explicit and implicit policies. Finally, the boundaries of policy action are discussed, stressing two critical dimensions that delimit the scope of policy action: i) the change of policy orientation and rationale, ii) that pose new governance’s challenges, which, in turn require new coordination with other implicit policies.