# Brazil Decree 11.413 reverse logistics: three certificates packaging producers can use to prove targets

> Brazil Decree 11.413 reverse logistics rules, in force since 14 April 2023, do not set targets: they give manufacturers, importers, distributors and traders three voluntary certificates (the CCRLR recycling credit, the CERE structuring certificate and the future mass credit) to prove the recovery targets set under Law 12.305, backed only by audited electronic invoices of the current or previous year, with results for 2026 due to the Ministry of the Environment by 30 July 2027.

Publisher: Strategic Packaging Insights  
Published: 2026-11-02  
Last updated: 2026-11-02  
Page: https://www.strategicpackaginginsights.com/insights/brazil-decree-11413-reverse-logistics-recycling-credits-certificates/

**Brazil Decree 11.413 reverse logistics rules, in force since 14 April 2023, do not set targets: they give manufacturers, importers, distributors and traders three voluntary certificates (the CCRLR recycling credit, the CERE structuring certificate and the future mass credit) to prove the recovery targets set under Law 12.305, backed only by audited electronic invoices of the current or previous year, with results for 2026 due to the Ministry of the Environment by 30 July 2027.**

Strategic Packaging Insights (SPI) read the decree, the law and the decrees around it, the Ministry's 2024 to 2026 reporting communiqués and the São Paulo procedure to show how each certificate works, what evidence stands behind it and where the proof can fail. [Ledger 28](https://www.strategicpackaginginsights.com/insights/latin-america-packaging-epr-chile-colombia-brazil/) set Brazil beside Chile and Colombia; this piece goes inside the certificate system itself.

## Executive summary

Brazil's reverse logistics duty for packaging is old; its proof system is new. Law 12.305 of 2 August 2010, the National Solid Waste Policy (PNRS), obliges manufacturers, importers, distributors and traders to structure and run reverse logistics, and Article 33 §1 extends the duty to goods sold in plastic, metal or glass packaging. For more than a decade the question was not whether companies had to recover packaging but how they could show it. Decree 11.413 of 13 February 2023 is Brazil's answer, and it replaced the short-lived Recicla+ certificate of Decree 11.044 of 2022.

The decree creates three instruments. The CCRLR proves that a mass equal to the company's obligation has already gone back into production. The CERE rewards companies that fund structuring projects in which more than half of the packaging recovery target is met through partnerships of at least 12 months with waste pickers. The future mass credit lets a company book its target in advance against an investment in a new system that will recover packaging over up to five years. Using any of them is voluntary, but Article 26 accepts each as proof that a target has been met.

All three rest on the same evidence: electronic invoices from the sale of recyclables, checked by an accredited results auditor against Federal Revenue Service records, and, since the transition deadlines, a final destination certificate from the national manifest system (SINIR). Only invoices from the current or the immediately previous fiscal year count. Invoices from waste picker organisations must be used up before credits from other operators. Since 7 May 2025, no certificate may rest on imported waste.

The system is now producing results the Ministry can audit. For 2024, packaging in general recovered 1,063,006.33 tonnes, or 33.89% of 3,136,452.15 tonnes placed on the market, as summarised by the Minas Gerais industry federation (FIEMG) on 27 April 2026 from a Ministry communiqué. **SPI analysis:**  that is about 122,000 tonnes above the 30% the Ministry applied to 2024, by SPI's calculation, but the margin shrinks to about 28,000 tonnes at the 33% São Paulo now sets for 2026, and the national figure says nothing about any single company's certificate file.

For leaders, the work is in the file, not the headline. Confirm which management entity reports for each brand, check that every tonne behind a certificate sits on an eligible invoice in the right window, and be ready for 30 July 2027, when results for 2026 fall due.

## Key findings

1. Decree 11.413 was signed on 13 February 2023, published in an extra edition of the Diário Oficial da União the same day and took effect on 14 April 2023 (Art. 34); it revoked Decree 11.044 of 2022 (Art. 33). The Câmara dos Deputados record lists no amending act as of 2 November 2026.
2. Three certificates exist: the CCRLR, the CERE and the future mass credit (Art. 5 II to IV). Asking for or buying them is voluntary (Art. 2 §2), and each is accepted as proof of a reverse logistics target (Art. 26).
3. A CERE needs a project that meets five cumulative tests, including more than 50% of the recovery target met through partnerships of at least 12 months with waste pickers (Art. 9 §1).
4. Only electronic invoices from the current or the immediately previous fiscal year count (Art. 15 §4), so 2026 results can rest only on 2025 and 2026 invoices.
5. The final destination certificate became mandatory for companies on 14 April 2025 and becomes mandatory for waste pickers and their organisations on 14 April 2027, after a one-time extension by Portaria GM/MMA 1.037/2024 (MMA Comunicado 001/2026).
6. Decree 12.451 of 6 May 2025 bars all three certificates for operations related to imported solid waste (Art. 5), and Decree 12.688 of 21 October 2025 accepts them as proof in the new plastic packaging system (Art. 12).
7. **SPI calculation:**  a company that placed 10,000 tonnes of packaging in general on the Brazilian market needs 3,000 tonnes of proof at the 30% approval value used for 2024 and 2025, and more than 1,500 tonnes of that must come through waste picker partnerships if it wants a CERE (Exhibit 11).

## The legal stack: one law, four decrees and a set of portarias

Decree 11.413 is the middle layer of a system that has been built in steps since 2010. Exhibit 2 sets the layers out in date order. SPI tracks the decree as rule [PR-BR-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/brazil/pr-br-001/) on the [Brazil page of the SPI Regulation Tracker](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/brazil/pr-br-001/).

Decree 10.936 of 12 January 2022, which regulates the PNRS and revoked the earlier Decree 7.404 of 2010, sets the frame Decree 11.413 works inside. Its Article 18 says reverse logistics systems are implemented through sectoral agreements, regulations issued by the government, or commitment terms, and its Article 12 creates a National Reverse Logistics Program coordinated by the Ministry. Article 15 required every system to be integrated into SINIR within 180 days of publication and created the electronic waste transport manifest on which Decree 11.413's final destination certificate later rests.

The information duty comes from the law itself, and it is what makes a certificate file worth keeping in order.

> "Com exceção dos consumidores, todos os participantes dos sistemas de logística reversa manterão atualizadas e disponíveis ao órgão municipal competente e a outras autoridades informações completas sobre a realização das ações sob sua responsabilidade."

In English: SPI's translation: "With the exception of consumers, all participants in reverse logistics systems shall keep complete information on the performance of the actions under their responsibility up to date and available to the competent municipal body and to other authorities."

***National Congress of Brazil** , Lei nº 12.305, Art. 33 §8, [Senado Federal, texto compilado](https://legis.senado.leg.br/norma/575947/publicacao/34618961), 2 August 2010*

SPI analysis

The certificate is a means of proof, not a source of obligation. The size of each company's target still comes from the sectoral agreement, decree or state rule that covers its packaging, which is why the same certificate can meet a 30% federal value and fall short of a higher state one.

## How Brazil Decree 11.413 reverse logistics proof works

The decree applies to public and private legal and natural persons with responsibilities in reverse logistics systems under Article 33 of the PNRS, and Article 3 lists ten aims. The first three are to improve physical and logistics infrastructure, to give scale to recycling, and to make reverse logistics and recycling systems work together; others give added value to the recycling chain, especially for waste pickers.

> "A solicitação de emissão e a aquisição do CCRLR, do CERE e do Certificado de Crédito de Massa Futura têm caráter voluntário."

In English: SPI's translation: "Requesting the issue of, and acquiring, the CCRLR, the CERE and the Future Mass Credit Certificate are voluntary."

***Presidency of the Republic** , Decreto nº 11.413, Art. 2 §2, [Câmara dos Deputados, Legislação Informatizada](https://www2.camara.leg.br/legin/fed/decret/2023/decreto-11413-13-fevereiro-2023-793768-publicacaooriginal-167057-pe.html), 13 February 2023*

Voluntary does not mean optional compliance. A company outside a collective model must run its own individual system (Art. 24), backed by the same audited invoices and manifests (Art. 24 §1). What the decree makes voluntary is the instrument: a company can prove its target through its own audited results, or it can hold a certificate that a management entity issues under its statute (Art. 23).

Three actors carry the system. Management entities (entidades gestoras) structure and run collective systems, must be legal entities registered in SINIR (Art. 21) and issue the certificates (Art. 23). Accredited results auditors check the evidence (Arts. 28 and 29). The Ministry of the Environment and Climate Change monitors each system, sets uniform criteria, publishes results and accredits the auditors through a public call (Art. 27). Exhibit 3 turns the choice between certificates into five questions.

## The CCRLR: credit for mass already recycled

The CCRLR is the workhorse. Article 5 II defines it as a document issued by the management entity that proves the return to the production cycle of a mass equal to the company's obligation, and Article 7 lets manufacturers, importers, distributors and traders acquire it to prove their targets. Article 8 makes it a single document per company adhering to the collective model, founded on the final destination certificate and on the electronic invoices of sales of products or packaging shown to have returned to the manufacturer or recycler.

That last clause matters. The CCRLR is not a credit for collection or for money spent. It is a claim on mass that a recycler has bought and received, and the invoice chain is the proof. A tonne collected by a cooperative but never sold to a recycler, or sold between two wholesalers, supports no credit. The Ministry made the second point explicit in Communiqué 005 of 16 October 2024: middle-of-chain invoices between wholesalers are generally not accepted because they cannot guarantee traceability and could be counted twice, with a one-time exception for the 2023 report.

The same communiqué set the first operating rule for timing. Certificates could be issued only from April 2023, and certificates issued in 2024 did not count toward the 2023 report. For buyers that means the certificate's issue date, not only the invoice date, has to fit the reporting year.

In practice: the 2023 report cycle.

The first annual reports under the decree covered 1 January to 31 December 2023 and were due on 30 July 2024. The Ministry accepted invoices from 2022 and 2023 only, rejected 2024 invoices for that report, and admitted wholesaler invoices issued from January 2022 to 14 April 2023 once, if the results auditor's declaration stated the issue period (MMA Communiqué 005/2024). It also asked each program to hire a single results auditor, or to show an interoperable environment that stops one invoice from being counted twice.

## The CERE: rewarding structuring projects with waste pickers

The CERE certifies a company as the holder of a structuring project for recovering recyclable materials (Art. 5 III), and companies subject to reverse logistics that invest in such projects may ask the management entity to issue it (Art. 9). The bar is set in Article 9 §1, which counts a project as structuring only if it meets five conditions at once. Exhibit 4 lists them.

One flexibility is written in. Under Article 9 §2, structuring projects that receive material from the public separate collection system and operate in formal partnership with the municipalities responsible for urban cleaning may count quantitative targets regardless of the type of material recovered. **SPI analysis:**  that is the only place in the decree where material type stops mattering, so a project built with a municipality can cover a glass or metal shortfall with paper or plastic; a CCRLR bought on the open market cannot do the same.

The Ministry treats the five tests strictly. Its 2024 and 2026 communiqués both state that only programs that meet Article 9 §1 count as structuring, and the March 2026 version adds that every management entity must carry out structuring actions aimed at waste pickers and describe them in its report. That duty applies whether or not the entity issues CERE certificates.

## The future mass credit: booking the target in advance

The future mass credit lets a company claim its target in advance for recyclable mass that a new investment will recover (Art. 5 IV). Companies that implement a structuring reverse logistics system may ask for it (Art. 10), and the system must involve investment in new initiatives that produce real recovery and additional recovered mass in the medium term (Art. 11). The target behind it is set from three inputs in Article 12: packaging placed on the market by the partner companies in the previous year, a statistical projection of later volumes, and the general targets in the packaging reverse logistics rules. Implementation may last no more than five years (Art. 13).

The asset transfer rule is the feature most likely to surprise a finance team. Equipment bought under the project passes to the picker organisations, so the company books the recovery and the organisation keeps the balers, presses or trucks. **SPI analysis:**  the future mass credit is therefore closer to a grant with a recovery claim attached than to a forward purchase of recycled tonnes, and it should be approved as such in capital budgets.

## The invoice is the evidence

Everything above rests on Article 15. Electronic invoices issued by operators for the sale of recyclable material are accepted for issuing any of the three certificates once they are homologated, and homologation by the results auditor has two parts: confirming that the invoice is authentic, unique and does not conflict with others, and confirming that the final recipient received the declared mass, through a final destination certificate issued in SINIR's waste transport manifest system (Art. 15 §1). The auditor, paid by the management entity, also audits invoice traceability and the actual return of mass to the manufacturer or recycler every year (Art. 15 §2).

The decree then sets an order of priority. Invoices should preferably come from sales by individual waste pickers and by picker cooperatives and associations (Art. 15 §5), and management entities must exhaust results from those organisations before using recycling credits from other logistics operators (Art. 15 §6). For packaging in general, Article 17 says invoices must come from pickers and their organisations, and its sole paragraph allows credits from other operators only once those are exhausted. Exhibit 6 shows who may issue an eligible invoice and to whom.

Behind the invoices sits a second data layer. Article 18 requires the management entity of a collective model to run an anonymised electronic information system of the black box type, capturing the quantities of products and packaging placed on the market and returned, confidentially and integrated with the SINIR manifest. That is what lets an entity issue a certificate per company without each company seeing its competitors' tonnages.

## The invoice window: why timing decides which tonnes count

Article 15 §4 accepts only invoices issued in the current or the immediately previous fiscal year. The Ministry applies the rule report by report.

> "Para demonstração dos resultados de 2025 só serão aceitas massas lastreadas em notas fiscais de 2024 e 2025."

In English: SPI's translation: "To demonstrate the 2025 results, only masses backed by invoices from 2024 and 2025 will be accepted."

***Ministry of the Environment and Climate Change** , Department of Solid Waste Management, [Comunicado LR DGR/MMA nº 001/2026, retificado](https://portal-api.sinir.gov.br/wp-content/uploads/2026/05/controlador.php_.pdf), 8 May 2026*

Exhibit 7 applies the same rule to each report year since the decree took effect. Decree 12.688 copies the window for plastic packaging in its Article 8 §4.

**SPI calculation:**  an invoice dated January 2025 can still back the 2026 report filed on 30 July 2027, about 30 months later. An invoice of December 2024 cannot, and has already expired. Each invoice can be used once, so a 2025 tonne already sold into a 2025 certificate is no longer available for 2026, which is why stock held by a management entity matters at year end.

The manifest layer is tightening on a fixed calendar. Under Article 31, companies had 12 months and pickers and their organisations 24 months to adopt the manifest tool, with proof by invoice alone until then and one extension allowed. The Ministry's 2026 communiqué records that Portaria GM/MMA 1.037/2024 moved the company deadline from 14 April 2024 to 14 April 2025 and the picker deadline from 14 April 2025 to 14 April 2027. From that date, 163 days after this piece's publication by SPI's count, picker mass will also need a final destination certificate.

## Results auditors and management entities

The results auditor is a private legal entity, accredited and supervised by the Ministry, that stands between the invoice and the certificate. Article 29 lists its duties, and Exhibit 8 sets them out. The decree also builds in a firewall: an auditor may not trade results or issue, buy or sell certificates, and a certificate issued in breach is void (Art. 29 §§1 and 2).

The Ministry has filled in the accreditation rules by portaria. Portaria GM/MMA 1.117/2024 sets criteria for results auditors and opened the first public call; according to a Mayer Brown summary of 9 August 2024, auditors must not be manufacturers, importers, distributors or traders linked to the system, and must not hold business relationships that give them an interest in their decisions. Portaria GM/MMA 1.102/2024 sets criteria for management entities of national packaging in general systems, including national scope; the Ministry's 2026 communiqué says national coverage must reach every state within 36 months of that portaria. Portaria GM/MMA 1.561 of 2 January 2026 then amended both and fixed yearly windows: 1 to 31 March for management entities and 1 to 30 April for auditors, with no filings outside them, according to a FIEMG note.

The management entity's duties are in Article 22: run the system, publish its results, run a communication plan, and file a results report with the Ministry by 30 July each year covering 1 January to 31 December of the previous year (Art. 22 IV). By the same date it must send the list of adhering companies, with their tax numbers and main activity, and proof that each met its target for the previous year (Art. 22 §4). The Ministry may cancel an entity's SINIR registration for non-compliance, after a letter that lets it cure the irregularity (Art. 25 §§2 and 3), and late reports can suspend an entity's accreditation under Annex V of Portaria 1.102/2024, according to the 2026 communiqué.

In practice: the 2025 report rules.

For the 2025 reference year, the Ministry required reports by 30 July 2026 through its electronic filing system, in one PDF of up to 100 MB plus the spreadsheet set by Portaria 1.011/2024. It analysed only reports from accredited management entities and declarations from accredited auditors on the model in Portaria GM/MMA 1.394/2025, and where report and declaration differed, the declaration prevailed. Each report gets at most two reviews, ending in approved, approved with reservations, or rejected (MMA Comunicado 001/2026).

## Brazil's 2024 results against the targets

The certificates prove a share of a national target, and that target has risen in steps. The Ministry applied 22% to the 2023 performance year and 30% to 2024 for packaging in general, aligned with the National Solid Waste Plan (Planares), according to its Communiqué 001/2024 as recorded in SPI's Brazil note. For 2025 its March 2026 communiqué gave a national figure of 31.25%, by linear interpolation between 2024 and 2028, but the corrected version of 8 May 2026 says reports for 2025 will be approved or rejected on the 2024 values, with 31.25% only as a reference.

The 2024 figure comes from FIEMG's 27 April 2026 summary of a Ministry communiqué on results, which describes the recovery level as still moderate against the aims of the PNRS. SPI has not yet confirmed the tonnages against the Ministry's own text. For comparison, the Ministry reported 25% and 985.7 thousand tonnes for 2022; the two bases differ, so SPI does not read the change as growth in tonnes.

Targets are regional too. The national value is split across five regions, and the Ministry's figures show how far the North and Northeast start below the Southeast (Exhibit 10).

In practice: São Paulo's licence-linked proof.

CETESB, São Paulo's environmental agency, ties reverse logistics to the operating licence: proof is a condition for issuing or renewing it (DD 051/2024/A, item 1.1). Its consolidated procedure sets packaging in general at 30% for 2024, 32% for 2025, 33% for 2026, 34% for 2027 and 35% for 2028, requires results reports to carry an auditor's declaration, and lets shortfalls of up to 10% of a missed target roll into the next year while larger gaps face sanctions. It accepts its own state certificate only where the issuing system has signed a commitment term with CETESB that provides for it, valid for up to one year; SPI has not yet confirmed how CETESB treats CCRLR, CERE or future mass certificates by name.

## SPI scenario: how many tonnes of proof a portfolio needs

The useful number for a company is not the rate but the tonnes, and the share of them that must come from picker organisations. Exhibit 11 applies the published rates to a portfolio of 10,000 tonnes of packaging in general placed on the market in the previous year.

The national picture in Exhibit 9 sets the scarcity. If placed-on-market tonnage held at the 2024 level, the national surplus over the requirement would fall from about 122,000 tonnes at 30% to about 83,000 tonnes at 31.25% and about 28,000 tonnes at 33%, by SPI's calculation, and would turn into a gap of about 35,000 tonnes at 35%. **SPI analysis:**  eligible tonnes become scarcer as rates rise, and the priority rule means the scarcest part is picker-sourced mass. A company that relies on CERE status, or on a management entity that does, should test whether picker partnerships of 12 months or more can grow as fast as its target.

The same arithmetic runs in a second currency-free direction. A company that reduces its packaging by 1,000 tonnes lowers next year's proof need by 300 tonnes at the 30% value, because each year's target is set on the previous year's placed-on-market quantity. That is the link between design work and the certificate budget.

## Where the proof can fail

Decree 11.413 sets no fines. The exposure sits with the underlying duty: Decree 10.936 added to Article 62 of Decree 6.514 of 2008 an infraction for failing to meet the obligations of a reverse logistics system (item XII) and another for failing to keep reverse logistics information up to date (item XV). Exhibit 12 shows the ranges.

The import bar came from a different policy track. Decree 12.451 of 6 May 2025 regulates the exceptions to the PNRS ban on importing solid waste: it limits imports to the transformation of strategic materials and minerals in industrial processes (Art. 3) and asks industry to prefer domestic waste that benefits picker cooperatives (Art. 7). Its Article 5 then closes the certificate route.

> "Fica vedada a concessão dos Certificados de Crédito de Reciclagem de Logística Reversa, dos Certificados de Estruturação e Reciclagem de Embalagens em Geral e dos Certificados de Crédito de Massa Futura, previstos no Decreto nº 11.413, de 13 de fevereiro de 2023, para operações relacionadas à importação de resíduos sólidos."

In English: SPI's translation: "The granting of Reverse Logistics Recycling Credit Certificates, Packaging in General Structuring and Recycling Certificates and Future Mass Credit Certificates, provided for in Decree No. 11,413 of 13 February 2023, is prohibited for operations related to the import of solid waste."

***Presidency of the Republic** , Decreto nº 12.451, Art. 5, [Câmara dos Deputados, Legislação Informatizada](https://www2.camara.leg.br/legin/fed/decret/2025/decreto-12451-6-maio-2025-797414-publicacaooriginal-175294-pe.html), 6 May 2025*

Decree 12.451 does not amend Decree 11.413; it bars a use of its certificates. SPI's tracker record originally described it as an amendment, and the corrections file already rewords that.

## The plastic decree builds on the certificates

Decree 12.688 of 21 October 2025, which creates the national plastic packaging system and its regional targets, is covered in [Ledger 28](https://www.strategicpackaginginsights.com/insights/latin-america-packaging-epr-chile-colombia-brazil/). What matters here is how it uses Decree 11.413. It adopts the earlier decree's definitions where they fit (Art. 3), accepts the CCRLR, the CERE and the future mass credit as proof for participants in the collective model (Art. 12), requires invoices to be homologated by a results auditor under Article 15 of Decree 11.413 (Art. 8 §1), keeps the same two-year invoice window (Art. 8 §4), and ties plastic results to invoices and manifests drawn first from picker organisations, citing Article 15 §6 of Decree 11.413 (Art. 16 §2). It also points cooperative service contracts to Decrees 11.413 and 11.414 (Art. 10 VI).

Decree 12.688 adds one rule the 2023 decree lacks. For mass from picker cooperatives and associations, it accepts entry invoices issued by recycling industries or by wholesale waste traders (Art. 8 §5), which helps organisations that cannot issue sales invoices themselves. **SPI analysis:**  a brand with both plastic and other packaging now works to one evidence standard with two target sets, and Portaria 1.561/2026, as summarised by FIEMG, lists paper and board, metals and glass for the packaging in general accreditation rules without naming plastic. SPI has not yet confirmed why plastic is absent from that list.

The design differs from Asia's. India's plastic EPR certificates are generated on a central government portal, as [SPI's India piece](https://www.strategicpackaginginsights.com/insights/india-plastic-packaging-rules-2026/) sets out, and the Philippines relies on notarised diversion certificates per company and a third-party audit, as the [Philippines EPR Act piece](https://www.strategicpackaginginsights.com/insights/philippines-epr-act-ra-11898-plastic-footprint-obliged-enterprises/) shows. Brazil sits between them: private management entities issue the certificates, but accredited auditors check every invoice against federal tax records. None of the three sets a per-tonne fee of the European kind priced in [Ledger 04](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/).

In practice: SPI Buyers Database profiles.

Four of the profiles in the [SPI Buyers Database](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/) record Brazilian exposure under [PR-BR-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/brazil/pr-br-001/). Nestlé's records CHF 3,983 million of 2025 sales in Brazil and names Reciclar pelo Brasil among its partners; Colgate-Palmolive's notes Colgate-Palmolive Comercial Ltda. and Latin America as its largest region at USD 4,776 million in FY2025; Kimberly-Clark's notes the Brazilian subsidiary Bacraft Industria de Papel; and Reckitt's notes a packaging facility investment in Brazil. The figures are size measures only, in each company's own currency, and are not compared.

## Industry reaction

The industry federations have treated the decree as an operating manual rather than a policy debate. FIEMG's notes to members in January and April 2026 focus on the Ministry's application windows and on the 2024 results, and describe the national recovery level as still moderate. The Ministry's own communiqués read as responses to questions from management entities: Communiqué 005/2024 opens by clarifying the treatment of invoice years and wholesaler invoices raised in the 2023 cycle.

Law firm commentary has followed each portaria. Mayer Brown's August 2024 note set out the independence rule for results auditors, the sharpest change for companies used to choosing their own checkers. The Ministry's recommendation of a single auditor per recovery period, repeated in 2026, points the same way.

## What leaders should do now

1. **Brazil compliance lead, by 31 December 2026:**  confirm which single management entity reports each brand's results to the Ministry, as the 2026 communiqué asks, and remove any double reporting across entities.
2. **Procurement, by 31 January 2027:**  ask each management entity for the invoice dates behind every 2026 certificate and reject any tonne invoiced before 1 January 2025 or traded between wholesalers.
3. **Sustainability team, by 14 April 2027:**  check that picker organisations in your system can issue final destination certificates in SINIR from that date, and budget support for those that cannot.
4. **Finance, in the 2027 budget:**  price proof at your own placed-on-market tonnage times 30% federally and at each state's own rate, as in Exhibit 11, and treat future mass projects as grants with a recovery claim, since their assets pass to the cooperatives.
5. **Legal, by 30 June 2027:**  obtain written confirmation from each entity that no certificate rests on imported waste under Decree 12.451, and check the reading with counsel.
6. **Country management, by 30 July 2027:**  make sure the entity's annual list of adhering companies names your tax numbers and shows your target as met for 2026.
7. **Packaging development, through 2027:**  log reductions in placed-on-market tonnage by SKU, since each tonne removed lowers next year's proof need by 300 kilograms at the 30% value.

## Questions for your board

- Which management entity reports our Brazilian results, and have we confirmed it is accredited for 2026?
- How many tonnes of proof do we need for 2026 under federal and state rules, and how much is already contracted on eligible invoices?
- What share of our proof comes from picker organisations, and could it carry a CERE?
- Do any of our certificates rest on wholesaler-to-wholesaler invoices or imported material?
- Are any future mass commitments on our books, and who owns the assets they fund?
- Can we produce, within days, the invoices, manifests and auditor declaration behind our 2025 report?

## What to watch

- **31 Dec 2026:**  the 2026 performance year closes; only 2025 and 2026 invoices can back it (Decree 11.413, Art. 15 §4).
- **1 to 31 Mar 2027:**  yearly application window for management entities under Portaria GM/MMA 1.561/2026.
- **1 to 30 Apr 2027:**  yearly application window for results auditors under the same portaria.
- **14 Apr 2027:**  final destination certificates become mandatory for picker mass, after the one-time extension (MMA Comunicado 001/2026).
- **30 Jul 2027:**  management entities file 2026 results and lists of adhering companies with the Ministry (Decree 11.413, Art. 22 IV and §4).
- **30 Jul 2028:**  2027 results due, on 2026 and 2027 invoices.

## Methodology

- **Data used:**  Decree 11.413 from the Câmara dos Deputados and Senado Federal legislative databases, which reproduce the Diário Oficial publication of 13 February 2023; Lei 12.305 from the Senado Federal compiled text; Decrees 10.936, 12.451 and 12.688 from the Câmara dos Deputados copies; Ministry communiqués 005/2024 and 001/2026 (original of 30 March and corrected of 8 May 2026) from SINIR; CETESB DD 051/2024/A as consolidated with DD 079/2025/A; FIEMG notes on Portaria 1.561/2026 and on the 2024 results; Mayer Brown's August 2024 note; SPI tracker record [PR-BR-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/brazil/pr-br-001/) and the Brazil note (14 October 2026), which used the Planalto texts. Consulted 2 November 2026 unless stated. See also [SPI methodology](https://www.strategicpackaginginsights.com/methodology/).
- **Primary sources first:**  quotes from Portuguese texts are given in Portuguese only where copied exactly, with an English rendering labelled as SPI's translation. SPI has not yet compared the Câmara and Senado copies line by line with the compiled Planalto text; the Câmara record lists no amending act for Decree 11.413.
- **Counting rules:**  tonnes only in the scenario; BRL only in the fines table; no conversion and no comparison across currencies. Requirement tonnages are SPI's calculation from the 2024 placed-on-market figure.
- **Terms:**  SPI uses "results auditor" for the accredited third party that the decree names, and "management entity" for the entidade gestora.
- **Limitations:**  SPI has not yet confirmed the 2024 national tonnages against the Ministry's own text, the Diário Oficial text of Portarias 1.037/2024, 1.102/2024, 1.117/2024, 1.394/2025 and 1.561/2026, the published list of accredited entities and auditors, or how CETESB treats federal certificates by name. This is business analysis, not legal advice; check with counsel.

## Sources

1. Planalto, Decreto nº 11.413, de 13 de fevereiro de 2023, [https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2023/decreto/d11413.htm](https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2023/decreto/d11413.htm), consulted 2026-10-14.
2. Câmara dos Deputados, Legislação Informatizada, Decreto nº 11.413, de 13 de fevereiro de 2023, publicação original, [https://www2.camara.leg.br/legin/fed/decret/2023/decreto-11413-13-fevereiro-2023-793768-publicacaooriginal-167057-pe.html](https://www2.camara.leg.br/legin/fed/decret/2023/decreto-11413-13-fevereiro-2023-793768-publicacaooriginal-167057-pe.html), consulted 2026-11-02.
3. Câmara dos Deputados, Legislação Informatizada, Decreto nº 11.413, dados da norma, [https://www2.camara.leg.br/legin/fed/decret/2023/decreto-11413-13-fevereiro-2023-793768-norma-pe.html](https://www2.camara.leg.br/legin/fed/decret/2023/decreto-11413-13-fevereiro-2023-793768-norma-pe.html), consulted 2026-11-02.
4. Senado Federal, Decreto nº 11.413, de 13 de fevereiro de 2023, [https://legis.senado.leg.br/norma/36837750/publicacao/36837861](https://legis.senado.leg.br/norma/36837750/publicacao/36837861), consulted 2026-11-02.
5. Senado Federal, Lei nº 12.305, de 2 de agosto de 2010, texto compilado, [https://legis.senado.leg.br/norma/575947/publicacao/34618961](https://legis.senado.leg.br/norma/575947/publicacao/34618961), consulted 2026-11-02.
6. Planalto, Lei nº 12.305, de 2 de agosto de 2010, [https://www.planalto.gov.br/ccivil_03/_ato2007-2010/2010/lei/l12305.htm](https://www.planalto.gov.br/ccivil_03/_ato2007-2010/2010/lei/l12305.htm), consulted 2026-10-14.
7. Câmara dos Deputados, Decreto nº 10.936, de 12 de janeiro de 2022, publicação original, [https://www2.camara.leg.br/legin/fed/decret/2022/decreto-10936-12-janeiro-2022-792233-publicacaooriginal-164412-pe.html](https://www2.camara.leg.br/legin/fed/decret/2022/decreto-10936-12-janeiro-2022-792233-publicacaooriginal-164412-pe.html), consulted 2026-11-02.
8. Câmara dos Deputados, Decreto nº 12.451, de 6 de maio de 2025, publicação original, [https://www2.camara.leg.br/legin/fed/decret/2025/decreto-12451-6-maio-2025-797414-publicacaooriginal-175294-pe.html](https://www2.camara.leg.br/legin/fed/decret/2025/decreto-12451-6-maio-2025-797414-publicacaooriginal-175294-pe.html), consulted 2026-11-02.
9. Planalto, Decreto nº 12.451, de 6 de maio de 2025, [https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2025/decreto/D12451.htm](https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2025/decreto/D12451.htm), consulted 2026-10-14.
10. Câmara dos Deputados, Decreto nº 12.688, de 21 de outubro de 2025, publicação original, [https://www2.camara.leg.br/legin/fed/decret/2025/decreto-12688-21-outubro-2025-798174-publicacaooriginal-176787-pe.html](https://www2.camara.leg.br/legin/fed/decret/2025/decreto-12688-21-outubro-2025-798174-publicacaooriginal-176787-pe.html), consulted 2026-11-02.
11. Planalto, Decreto nº 6.514, de 22 de julho de 2008, texto compilado, [https://www.planalto.gov.br/ccivil_03/_ato2007-2010/2008/decreto/d6514compilado.htm](https://www.planalto.gov.br/ccivil_03/_ato2007-2010/2008/decreto/d6514compilado.htm), consulted 2026-10-14.
12. Ministério do Meio Ambiente e Mudança do Clima (SINIR), Comunicado LR DGR/MMA nº 001/2026, retificado, 8 May 2026, [https://portal-api.sinir.gov.br/wp-content/uploads/2026/05/controlador.php_.pdf](https://portal-api.sinir.gov.br/wp-content/uploads/2026/05/controlador.php_.pdf), consulted 2026-11-02.
13. Ministério do Meio Ambiente e Mudança do Clima (SINIR), Comunicado LR DGR/MMA nº 001/2026, 30 March 2026, [https://portal-api.sinir.gov.br/wp-content/uploads/2026/04/COMUNICADO_LR__DGR_MMA_N_o_001_2026.pdf](https://portal-api.sinir.gov.br/wp-content/uploads/2026/04/COMUNICADO_LR__DGR_MMA_N_o_001_2026.pdf), consulted 2026-11-02.
14. Ministério do Meio Ambiente e Mudança do Clima (SINIR), Comunicado 005/2024, 16 October 2024, [https://portal-api.sinir.gov.br/wp-content/uploads/2024/10/COMUNICADO-005-16.10.2024.pdf](https://portal-api.sinir.gov.br/wp-content/uploads/2024/10/COMUNICADO-005-16.10.2024.pdf), consulted 2026-11-02.
15. Ministério do Meio Ambiente e Mudança do Clima (SINIR), Comunicado 001/2024-DGR/MMA, 21 May 2024, [https://portal-api.sinir.gov.br/wp-content/uploads/2026/07/Comunicado-1_2024_DGR-22.05.2024-Defeso.pdf](https://portal-api.sinir.gov.br/wp-content/uploads/2026/07/Comunicado-1_2024_DGR-22.05.2024-Defeso.pdf), consulted 2026-10-14.
16. CETESB, Decisão de Diretoria 051/2024/A, consolidated with DD 079/2025/A, [https://cetesb.sp.gov.br/wp-content/uploads/2026/01/DD-051-2024-A-Procedimentos-para-demonstracao-da-Logistica-Reversa-CONSOLIDADA-com-a-DD-079-2025-A.pdf](https://cetesb.sp.gov.br/wp-content/uploads/2026/01/DD-051-2024-A-Procedimentos-para-demonstracao-da-Logistica-Reversa-CONSOLIDADA-com-a-DD-079-2025-A.pdf), consulted 2026-11-02.
17. FIEMG, Portaria GM/MMA nº 1.561/2026: atualização na logística reversa de embalagens, January 2026, [https://www.fiemg.com.br/fiemg/wp-content/uploads/sites/10/2026/01/IE-PORTARIA-GM-MMA-No1561-2026-ATUALIZACAO-NA-LOGISTICA-REVERSA-DE-EMBALAGENS-VF.pdf](https://www.fiemg.com.br/fiemg/wp-content/uploads/sites/10/2026/01/IE-PORTARIA-GM-MMA-No1561-2026-ATUALIZACAO-NA-LOGISTICA-REVERSA-DE-EMBALAGENS-VF.pdf), consulted 2026-11-02.
18. FIEMG, Comunicado LR: resultados dos sistemas de logística reversa de embalagens em geral, 27 April 2026, [https://www.fiemg.com.br/wp-content/uploads/2026/04/IE_COMUNICADO-RESULTADOS-LR_Meio-Ambiente.pdf](https://www.fiemg.com.br/wp-content/uploads/2026/04/IE_COMUNICADO-RESULTADOS-LR_Meio-Ambiente.pdf), consulted 2026-11-02.
19. Mayer Brown, New regulations on solid waste and reverse logistics management entities, auditors of results and other developments, 9 August 2024, [https://www.mayerbrown.com/pt/insights/publications/2024/08/new-regulations-on-solid-waste-and-reverse-logistics-management-entities-auditors-of-results-for-reverse-logistics-and-other-developments](https://www.mayerbrown.com/pt/insights/publications/2024/08/new-regulations-on-solid-waste-and-reverse-logistics-management-entities-auditors-of-results-for-reverse-logistics-and-other-developments), consulted 2026-11-02.
20. SPI Regulation Tracker and Buyers Database, rule PR-BR-001, the Brazil note and the Nestlé, Colgate-Palmolive, Kimberly-Clark and Reckitt profiles, /data/packaging-regulation-tracker/brazil/pr-br-001/ and /data/packaging-buyers-database/, consulted 2026-10-14.