Reaching Brazil

Finally REACH has reached Brazil!

It has been published by the Brazilian Congress and the Presidential Office the law 15.022 from November 13th, 2024, establishing the parameters for the Brazilian inventory of chemical products known under the acronym INSQ.

This stood for Inventário Nacional de Substâncias Químicas which can be translated directly to National Inventory of Chemical Substances. It’s also being called as “Brazil REACH” or “Brazilian REACH” which it seems this is how everyone will refer to this new inventory here in Brazil and globally.

Brazilian REACH will establish the assessment and risk control of chemical substances used, produced or imported into the Brazilian territory, with the aim of minimizing adverse impacts on health and the environment.

The regulation of the law must be done within 180 days and the Public Authority will have up to 03 years to develop and implement the registration platform which will be the database for the chemical substances inventory.

Must be registered into the platform chemical substances which complies to this new regulation, in themselves or when used as ingredients in a mixture, that individually reach a quantity equal to or greater than 1 ton of production or importation per year considering the average of the last 03 years. As per the European REACH, foreign chemical producers can have local representatives to assume the imposed tasks and responsibilities.

The registration of a chemical substance in the inventory must include the following information, according to the regulation:

  1. a) identification data of the producer or importer of the chemical substance;
  2. b) the range of annual production or importation quantities of the chemical substance;
  3. c) the exact identification of the chemical substance, including the registration number in the Chemical Abstracts Service (CAS) or the International Union of Pure and Applied Chemistry (IUPAC), by its acronym in English, when applicable;
  4. d) the hazard classification according to the Globally Harmonized System of Classification and Labeling of Chemicals, in accordance with the current Brazilian standard;
  5. e) the recommended uses of the chemical substance.

 

Regarding risk assessment a committee will select the chemical substances to be prioritized based on the following criteria:

  1. a) persistence and toxicity to the environment;
  2. b) bioaccumulation and toxicity to the environment;
  3. c) persistence, bioaccumulation and toxicity to the environment;
  4. d) carcinogenicity, mutagenicity or toxicity to reproduction;
  5. e) characteristics of endocrine disruptors, based on scientific evidence;
  6. f) relevant potential for human or environmental exposure;
  7. g) forecast in alert, agreement or international convention to which Brazil is a signatory.

In total there are 44 articles which can be checked at:

https://www2.camara.leg.br/legin/fed/lei/2024/lei-15022-13-novembro-2024-796548-publicacaooriginal-173526-pl.html

My personal view: Brazil has a unique opportunity to be at the same level of recognized international chemical regulations. We have under our umbrella a huge diversity of forests and water resources. Taking care of how we handle chemicals is also taking care of the environment.

Some people can say that costs will increase but I say that costs will decrease. Due to climate changes tons of money are being spent due issues caused by floods, fire, heavy storms and so on. It’s clear that something is wrong. Taking joint actions such as REACH is the first step towards reversing this situation.

Sergio Medeiros
RadTech South America Board Member (www.radtech.org.br)
Founder and Director of BRCHEMICAL (www.brchemical.com)