Reverse Logistics and Recycled Content in Plastic Packaging + National Ocean Without Plastic Strategy (Part 2)

Over the past few months, the packaging landscape in Brazil has gained new layers — almost like when a series drops an entire new season at once and everyone rushes to understand what changed in the storyline. Between new decrees, targets, and emerging terminology in industry conversations, one thing is clear: the regulatory environment is evolving quickly, and anyone working with packaging, sustainability, or compliance needs to follow each plot twist closely.

With the publication of Decrees 12.688/2025 and 12.644/2025, discussions around waste, recycled content, and material substitution are no longer predictable. Companies now face a more complex — and more strategic — map. Below, I provide a clear and direct analysis of what is actually changing, how this affects B2B operations, and why the movement to replace plastics has already begun behind the scenes.

• Decree 12.688/2025, focused on municipal solid waste and post-consumer recycled content;

• Decree 12.644/2025, which establishes the National Ocean Without Plastic Strategy and sets forth the gradual — and eventual — elimination of single-use plastics.

Both are directly shaping the future of packaging, especially for industrial and B2B operations.

1. Packaging and Decree 12.688/2025

This decree reinforces that its scope is centered on post-consumer materials — including packaging that, even within B2B operations, ultimately enters the municipal waste stream or ends up in landfills. There is no automatic exclusion for companies selling exclusively to other businesses.

For packaging manufacturers, two main obligations emerge:

• demonstrating reverse logistics, and

• incorporating post-consumer recycled content (PCR) — with post-industrial material explicitly excluded.

Exceptions remain valid for:

• packaging governed by its own specific legislation, and

• packaging used in direct food contact, which is not required to use PCR.

In practice, this mainly affects:

• secondary and tertiary packaging, and

• packaging materials, which must use PCR to meet regulatory requirements.

2. Gradual Plastic Phase-Out and Decree 12.644/2025

Decree 12.644 launches a new national agenda: the progressive elimination of single-use plastics between 2025 and 2030.

According to information circulating in the sector, many companies are already:

• evaluating alternatives to plastic packaging, and

• transitioning to paper, alternative materials, or hybrid structures — understanding that these materials do not fall under the same PCR requirements established by Decree 12.688.

This gives rise to a natural market shift:➡️ replacing plastics subject to targets and PCR obligations with materials that, today, are not under the same regulatory pressure.

This does not mean an absence of responsibility — reverse logistics and waste management remain transversal themes — but it does represent a shift in the regulatory and economic calculus behind material selection.

3. The Connecting Factor: Reporting and Supply Chain Synergy

With these overlapping decrees, reporting becomes even more strategic. Building data-sharing mechanisms with customers will be essential, especially because:

• many already report their own packaging data,

• they will require methodological alignment, and

• they will seek to avoid duplicated costs across different decrees and targets.

Once again, as in the most complex cooperative games, the “endgame” cannot be won individually — data consistency becomes a regulatory asset.

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