Overview
Brazil has had Extended Producer Responsibility (EPR) in place for various products and end-of-life waste for some time, largely through its progressive national waste law of 2010. Implementing these provisions has been complex. Recently, the federal government, specifically the Ministry of Environment (MMA), opened a public consultation on a significant Draft Norm that outlines criteria for qualifying management entities and parameters for their operation in the reverse logistics systems for "general" packaging.
Key Points
Management Entities
The responsibility of structuring, implementing, and operating reverse logistics systems for products and packaging falls on management entities. These entities are also required to disclose the implementation of the reverse logistics system and submit an annual report to the MMA.
Draft Norm
The draft norm is a crucial step in defining the qualifications and operational guidelines for these management entities. Given the scope of waste involved, particularly in the realm of general packaging, this development has significant implications for numerous companies.
Public Consultation Period
The public consultation on this draft norm began on December 25th, 2023, and is scheduled to conclude on January 25th, 2024. During this period, stakeholders have the opportunity to provide feedback and insights on the proposed regulations.
Verifiers' Role
According to the proposal, "verifiers" would be tasked with storing information and verifying the results of product or packaging recovery. They would approve electronic invoices issued by operators in the marketing of recyclable products and packaging, facilitating credit issuance by management entities. Verifiers would also conduct an annual audit on the traceability of electronic invoices and confirm the effective return of recyclable materials to the manufacturing or recycling company, among other obligations.
It is crucial for companies operating in Brazil, particularly those involved in the production and management of packaging, to actively participate in this consultation and provide valuable input. The public consultation period now extends until February 2nd, 2024.