Brazil’s renewed focus on chemical policies

The regulatory landscape for chemicals is an ever-changing field, with constant updates and developments. Even consolidated regulations must undergo changes to keep up with the chemicals’ technological development, newly discovered uses, and the most up-to-date scientific discoveries on their safe use. 

As Brazil hosts the 30th United Nations Climate Change Conference of the Parties (COP30), the pressure to show the country’s commitment to sustainability and environmental matters has increased, including on the safe use of chemicals. 

Therefore, the Brazilian chemicals agenda is focused on two major topics:  

• the development of a REACH inspired regulation, namely the National Inventory of Chemical Substances (Inventário Nacional de Substâncias Químicas), established by Law 15.022 of 13 November 2024, and its upcoming regulating decree (waiting to be published); and 

• the National Policy on the Control of PFAS (per- and polyfluoroalkyl substances) (Política Nacional de Controle dos PFAS – PNCPFAS), which is pending approval in the National Congress through Law Proposal 2.726/2023. 

Both developments aim at providing a framework for the safe controlled use of chemicals in Brazil, with registration and reporting requirements, as well as a scheduled phase-out in certain cases, such as with PFAS. 

The Brazilian National Inventory of Chemical Substances

Federal Law 15.022/2024 entered into force on 14 November 2024, following a long decade of debate on the Brazilian chemical agenda. Inspired by the EU’s harmonized regulatory framework conceived by the REACH Regulation (EC) 1907/2006, the Brazilian National Inventory of Chemical Substances establishes, in a single act, the basic rules for the registration of chemical substances used, produced, or imported into Brazil, including new ones, along with the steps for their risk assessment and control.  

Similarly to the REACH regulation, the recently approved regulatory regime for chemical substances in Brazil seeks to foster innovation and competitiveness in its chemicals industry. Furthermore, by aligning the Brazilian regulatory landscape with that of the EU, companies operating in Brazil and trading with the EU market can benefit from simplified obligations and are able to better plan their corporate strategy to improve compliance through comparable processes.  

One year after it entered into force, the National Inventory of Chemical Substances is close to receiving the additional regulation necessary for its provisions and requirements to become effective for manufacturers and importers of chemical substances. Although Law 15.022/2024 establishes a legal basis and framework for assessing and controlling the risks associated with chemical substances, a decree drafted by the Brazilian government and awaiting approval will regulate its implementation, specifying procedures and technical details. The Decree regulating its implementation is expected to be published by the end of 2025. 

Key regulatory elements of the National Inventory of Chemical Substances

The first step established by Law 15.022/2024 is that manufacturers and importers of chemical substances will have to register their substances in the National Inventory of Chemical Substances within a 3-year period, which will be counted from the moment that the registering system becomes operational – the government has until 14 November 2027 to develop such a system. After this deadline, any unregistered substance will automatically be classified as “new” under the Brazilian framework. 

This registration requirement applies to companies manufacturing or importing chemical substances on their own or as components of mixtures in quantities of 1 ton (t) or more per year, considering the average of the last 3 years. The law sets out several exemptions, including radioactive substances, products subject to customs supervision without any type of treatment or transformation, and products subject to control under specific legislation (e.g., sanitizing products, narcotic, psychotropic, and immunosuppressive substances).  

After the registration phase is completed, the Federal Government will initiate a prioritization process for risk assessment based on the information provided by manufacturers and importers. Once this prioritization process is finished, a Deliberative Committee will define and periodically publish a schedule with the working plans for risk assessment of the registered and prioritized substances.  

Once the risk assessment phase is complete, the Deliberative Committee will issue risk management measures according to chemical substances, which importers, manufacturers, and downstream users will be required to implement in order to maintain regulatory compliance and continue operating in the Brazilian market. 

What obligations will the new regulating decree bring? 

If approved in its current form, the implementing Decree will operationalize and further regulate the details of the registration and risk assessment requirements, providing annual deadlines and required documents, among others.  

Under the Decree, companies manufacturing or importing chemical substances, or using them as ingredients in mixtures, in volumes equal to or exceeding 1 ton per year (based on a 3-year average) will be required to comply with several obligations, including:  

• Submission of complete registration data through the system of the National Register of Chemical Substances, covering identification of the manufacturer, importer, or exclusive representative or the foreign manufacturers (for importers); identification on the identification of chemical substances (such as Mercosur Common Nomenclature Codes – NCM and the Registration number in the Chemical Abstract Service – CAS); annual production or import ranges; and information on substances uses and applications;  

• Timely updates to registered information, with companies required to report any changes to substance data by 31 March of the year following such changes; 

• Provision of studies and data safety sheets of the chemical substances with complementary safety data regarding the registered substances for risk assessment purposes, whenever requested by authorities for risk-assessment purposes; and 

•  Payment of applicable fees, specifically the Registration, Evaluation and Inspection Fee for Chemical Substances regarding the registration of existing and new chemical substances and their risk assessment. 

The implementing Decree, therefore, introduces a more robust compliance framework, detailing how companies across the chemical industry and value chain will have to maintain accurate and up-to-date data and support the Brazilian Federal Government in assessing the risks of chemical substances throughout their entire lifecycle.  

Legislative roadmap of the decree

A public consultation on the draft of the Decree regulating the National Inventory of Chemical Substances was launched in May 2025. The public consultation was cancelled shortly after, and the draft Decree was submitted to the members of the World Trade Organization (WTO) on 18 July 2025 and has been pending approval ever since.  

Upcoming National Policy on the Control of PFAS

Alongside the efforts of the National Inventory of Chemical Substances in determining the risks and control measures for chemicals produced, imported, or used in Brazil to minimize health and environmental impacts, the Brazilian government has been pushing forward a Law Proposal on the control of PFAS. 

On 22 May 2023, Law Proposal 2.726/2023 (the Proposal) was introduced to the Deputies Chamber of the National Congress, aiming to establish the National Policy on the Control of PFAS (PNCPFAS). After years of anticipation, the legislative process is advancing, with the Commission for Environmental and Sustainable Development (CMADS) approving a Substitute Version on 15 October 2025. 

The PNCPFAS seeks to prevent and mitigate environmental, social, and health impacts linked to PFAS use. However, full implementation will depend on additional regulations by public authorities, such as for setting progressive thresholds for PFAS concentrations in water, soil, air, and food; and establishing rules for PFAS production, use, and disposal monitoring. 

If approved, the PNCPFAS will enter into force 180 calendar days after its publication in the Official Journal. 

What does the proposal cover?

If enacted in its current form, the PNCPFAS will impose significant obligations on companies that use PFAS in their production processes or products. Key requirements include: 

• Annual Reporting: Submission of a yearly report detailing PFAS consumption and disposal; 

• Reduction and Phase-Out Measures: Implementation of strategies to progressively reduce and eliminate PFAS use; 

• Occupational Risk Assessment: Identification and evaluation of workplace risks related to PFAS exposure; 

• Preventive Measures in Health Programs: Integration of PFAS-related preventive actions into occupational health and safety programs, such as the company’s occupational health and safety program (Programa de Controle Médico de Saúde Ocupacional – PCMSO); and 

• Health Monitoring: Regular health surveillance of workers exposed to PFAS. 

Next legislative steps

The Proposal is currently under analysis of the Commission for Urban Development (CDU), after which it will follow for analysis by the Commission for Health, and the Commission for Constitution, Justice, and Citizenship (CCJ). If approved by the Chamber of Deputies, the Proposal will follow to the Federal Senate for analysis.  

There is no information on whether or when the Substitutive or the Proposal will be adopted, but given the high relevance of this subject, proceedings have been faster than usual. 

What does it mean for companies?

Brazil’s focus on chemical regulations marks a decisive step toward strengthening environmental protection, aligning with global best practices, and requiring companies to adapt their operations to a more sustainable future. With the Brazilian National Inventory of Chemical Substances and the advancement of the PNCPFAS, companies operating in Brazil (either directly or via supply chains) can expect more robust reporting, registration, and risk assessment and management obligations. 

Although this new framework still depends on implementing legislation, there is a clear direction towards greater transparency, stricter oversight, and increased accountability. Companies that begin mapping their chemical footprint will have an advantage, being best positioned to adapt smoothly once new rules enter into force.  

Chemicals inventory

Brazil’s alignment with globally accepted control and monitoring measures of chemical substances use is definitely a step towards strengthening its relationships with international partners and creating a safer future for the chemicals industry.  

Companies must start to prepare for the upcoming registration and risk assessment deadlines by: 

• Structuring technical data for compliance with technical requirements and audit purposes, such as the registration of chemical substances within 3 years from the start of the National Register of Chemical Substances platform; and 

• Assessing and planning the allocation of resources for implementing these requirements. For example, if a chemical substance becomes prioritized and subject to restrictions, plan a new replacement strategy and the future costs.   

PFAS preparations

PFAS is a global challenge. In line with this, Brazil is setting out what businesses must do in relation to PFAS. Companies operating in Brazil must start preparing for future (not too distant) compliance by: 

• Mapping PFAS use in their processes and products. 

• Reviewing occupational health programs for PFAS-related risks. 

• Anticipating reporting and monitoring of chemical substances. 

• Strengthening chemical risk management and regulatory transparency. 

Brazil’s evolving chemical regulations signal stricter oversight, greater transparency, and heightened accountability. Companies that proactively map substances, strengthen risk management, and prepare data systems now will transition more smoothly into this emerging compliance landscape.