Reverse Logistics and Recycled Content in Plastic Packaging - Decree No. 12,688, of October 21, 2025 (EPR Regulation Brazil)
- Working Heroes
- Nov 7
- 2 min read
Overview
The decree establishes the National Plastic Packaging Reverse Logistics System, regulating §§1º of Articles 32 and 33 of Law nº 12,305/2010 (National Solid Waste Policy). It aims to strengthen circular economy practices and shared responsibility across the entire packaging lifecycle.
Key Provisions
Scope: Applies to primary, secondary, and tertiary plastic packaging, as well as equivalent plastic products. Excludes packaging already regulated by other decrees (e.g., pharmaceuticals, agrochemicals, lubricants) and mixed-material packaging with paper.
Responsibility: Manufacturers, importers, distributors, and retailers must structure, finance, and operate reverse logistics systems, either:
Individually (own system), or
Collectively (via an accredited entity).
Social Inclusion: Prioritizes cooperatives and associations of waste pickers in collection and sorting stages.
Targets and Deadlines
Recovery of Packaging:
32% by 2026, rising to 50% by 2040.
The understanding is that it is centered on the reverse logistics of plastic packaging, which, after being introduced into the market and consumed, subsequently becomes part of the Municipal Solid Waste (MSW) stream.
Recycled Content in Packaging:
Minimum 22% by 2026, reaching 40% by 2040.
(Excludes food-contact packaging)
Article 33, § 3 The recycled content targets do not apply to packaging that has specific regulations, including food packaging.
Infrastructure:
Install Voluntary Delivery Points (PEVs):
1 per municipality up to 10,000 inhabitants;
1 per 10,000 inhabitants in larger municipalities, within 4 years.
Compliance and Reporting
Annual Reports: Submit results to SINIR by July 30 each year.
Traceability: Demonstrate compliance via tax documents and digital platforms within 90 days of publication.
Sanctions: Non-compliance may lead to fines and cancellation of entity accreditation.
Strategic Implications
Encourages integration with credit instruments (CCRLR, CERE) for environmental compensation.
Requires investment in recycling capacity, partnerships with cooperatives, and robust data transparency
Additional details:
The understanding is that Decree 12.688/2025 is centered on the reverse logistics of plastic packaging, which, after being introduced into the market and consumed, subsequently becomes part of the Municipal Solid Waste (MSW) stream.
This packaging consists of the dry fraction of urban waste, that is, recyclable materials such as plastics, paper, metal and glass, but the decree is specific to primary, secondary and tertiary plastic packaging (with approaches for already regulated sectors, such as pharmaceuticals and agrochemicals).
The objective is to ensure that this packaging is collected, sorted and reintroduced into the production chain, prioritizing cooperatives and structured reverse logistics systems.
Municipal Solid Waste %
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