Public Consultation (Brazil) - Decree regulating Law No. 15,022/2024 on the National Inventory of Chemical Substances

The time has come to build the future of chemical regulation in Brazil!

The new public consultation on the Decree regulating Law No. 15,022/2024, which establishes the National Inventory of Chemical Substances and defines the bases for the assessment and risk control of chemical substances produced, used or imported in the national territory, has been published.

This is a fundamental opportunity for everyone who works in the production chains of the chemical, food, cosmetics, pesticides, plastics, fragrances and many other sectors impacted by chemical substances.

https://www.gov.br/participamaisbrasil/decreto-regulamentador-da-lei-15022-2024

🧩 Below, I highlight 10 key questions and what the draft decree proposes so far:

What changes for companies?

Companies that produce or import substances in quantities ≥1 t/year must notify the National Registry of Chemical Substances, providing technical and usage data.

How will the Inventory be structured?

Based on mandatory notifications, the Inventory will compile substances existing in the country, including volume, classification and use, serving as the basis for prioritization and risk assessment.

What is the role of the Exclusive Representative?

The law provides that the foreign manufacturer may provide information directly through an agreement with the importer. The draft decree does not detail this function, but alignment with international best practices (such as REACH) is expected.

What prioritization criteria will be adopted?

Hazards such as toxicity, persistence and bioaccumulation will be considered, in addition to volume and potential exposure.

How will confidentiality (CBI) be guaranteed?

The draft does not yet provide details on the protection of confidential data — a critical point to be addressed in technical contributions.

Will micro and small companies be given flexibility?

The draft does not differentiate obligations, but the Law provides for differentiated treatment in terms of deadlines and amounts of the regulatory fee, according to size.

Are the deadlines realistic?

A 3-year period is proposed for sending data from the system's availability — an important point for calibration with industrial reality.

Will there be international convergence?

The legal text allows for agreements with countries that have robust systems, but the decree does not yet specify harmonization mechanisms (e.g.: REACH, TSCA, K-REACH).

Are there any penalties foreseen?

The law imposes direct responsibility on chain agents regarding compliance with risk management measures — details on administrative sanctions are expected in the future.

How to participate in the public consultation?

Via Participa + Brasil. Technical participation is essential for building balanced, effective regulation aligned with national reality.

📣 Contributing now ensures predictability, legal certainty and a functional regulatory environment.

Let's work together to build a model that protects health and the environment, without compromising innovation and competitiveness.