Peru REACH: Learn the Timelines
Peru REACH compliance timelines are complex: two separate tracks, multiple deadlines, and a threshold that won’t be defined until mid-2027.
Here’s a summary of what we know so far to keep us all on track.
Brazil Moves Toward Mandatory Carbon Footprint Labeling on Consumer Products
A bill that would require carbon footprint information on all products sold in Brazil is advancing through the Chamber of Deputies — and for companies selling into one of the world’s largest consumer markets, it is worth watching carefully.
· What the Bill Would Require
PL 3,701/2021 would make it mandatory to display on product labels the quantity of CO₂-equivalent emissions generated across the full product lifecycle — from raw material extraction through to end-of-life disposal. Non-compliance would be subject to sanctions under Brazil’s Consumer Defense Code. The obligation would apply to all products commercialized in Brazilian territory.
The lifecycle scope is significant: this is not a manufacturing emissions label. It captures the full carbon cost of a product — including upstream supply chain, processing, distribution, and disposal — measured and communicated directly to the consumer at the point of sale.
· Where the Bill Stands
The bill is moving through three committees on a conclusive basis — no full floor vote required if all three approve.
- CMADS (Environment) — ✅ Approved with amendment, May 2024
- CDC (Consumer Defense) — Rapporteur Dep. Nilto Tatto recommends approval. Vote pending.
- CCJ (Constitution & Justice) — Still to come
The bill is at its midpoint. The trajectory is favorable, but constitutional review at the CCJ remains the final hurdle.
· The Regulatory Logic
The CDC rapporteur frames carbon labeling within Brazil’s existing consumer protection architecture — specifically the right to clear product information enshrined in Article 6 of the Consumer Defense Code, the same legal basis underpinning nutritional labeling on food. The analogy is explicit: just as front-of-pack warnings on sugar, fat, and sodium improved transparency in food choices, carbon labeling is the next step in informing Brazilian consumers. Lifecycle assessment (LCA) methodology provides the technical foundation, aligning the bill with the direction of travel in the EU and other major markets developing product-level carbon disclosure frameworks. The LCA foundation also connects to broader regional trends — Mexico’s new General Economy Law is the latest example of Latin American legislation reaching upstream into supply chains to assign environmental responsibility based on lifecycle impact.
· Why It Matters for Industry
Brazil is the largest consumer market in Latin America. If enacted, companies across virtually every product category — food and beverage, personal care, household products, electronics, apparel — would need to calculate, verify, and communicate full lifecycle carbon emissions on packaging. That is a significant compliance undertaking, particularly for international companies with complex supply chains. The bill is not law yet, but the regulatory logic is well-grounded and the committee trajectory is favorable. Companies without lifecycle emissions data infrastructure should treat this as a signal to take note.
Link to Relator Report:
Brazil: Focus on Cosmetovigilance
Brazil is not just the largest cosmetics market in Latin America — it is valued at over USD 7 billion in 2025 and projected to reach nearly USD 12 billion by 2034. Keeping that market safe after products reach consumers is precisely what Brazil’s Health Surveillance Agency (ANVISA) aims for in the new Technical Chamber of Cosmetovigilance (CTEC).
Established under Portaria 471/2026, the CTEC will operate in an advisory capacity with four core functions: evaluating safety signals, proposing regulatory and preventive measures, developing technical methodologies, and qualifying adverse event data from notification systems. It comprises ten members — five full and five alternates — drawn from universities and research institutions across Brazil, plus representation from the Ministry of Health.
The Chamber builds directly on RDC 894/2024, which marked a significant shift in Brazil’s approach to cosmetic safety — moving away from reactive oversight toward a proactive, systematic model of post-market monitoring. RDC 894/2024 went into effect in 2025 with Brazil’s new Good Cosmetovigilance Practices, requiring companies holding cosmetic registrations to operate their own internal safety monitoring systems. The CTEC now gives ANVISA the independent scientific advisory capacity to interpret that industry-generated data and translate safety signals into regulatory action.
Brazil is currently the only country in Latin America with cosmetovigilance obligations at this level of detail and enforceability. Chile is moving in the same direction, with a draft cosmetovigilance standard currently under development — but for now, Brazil stands alone in the region with a fully structured framework.
Why it matters
For companies operating in or exporting to Brazil, the direction is clear: post-market surveillance obligations are tightening, the quality of adverse event reporting will face greater scrutiny, and the path from safety signal to regulatory response may get shorter. Brazil is aligning with the more demanding oversight frameworks seen in the EU — and the CTEC is the institutional infrastructure that makes that credible.
Link to Portaria:
Ecuador: Cosmetics, Personal Care, and Household Cleaners Take Note
When ARCSA posted the draft of this instructive last year, we flagged it as one to watch. Version 2.0 is now final, and the changes that matter most are clear.
The Instructive governs the Mandatory Sanitary Notification (NSO), Ecuador’s market authorization mechanism for three product categories:
✔️ Cosmetics
✔️ Household cleaning products
✔️ Personal hygiene absorbent products
It consolidates requirements across five regulatory pathways — new NSO, parallel importation, renewal, recognition, and modification — each with its own detailed annex.
What Changed from Draft to Final
Two targeted but significant updates distinguish Version 2.0 from the draft:
Renewal timelines updated. The deadline for submitting cosmetic NSO renewal requests has been revised to align with Article 18 of Andean Decision 833. Companies with products approaching renewal should verify their timelines against the new provisions immediately.
Apostille requirement eliminated for parallel importers. The manufacturer authorization document required under the parallel importation pathway no longer requires apostille — reducing administrative burden and processing time for distributors and market entrants operating as parallel importers.
Two Provisions Worth Flagging Across All Pathways
Cannabis-derived ingredients. Products containing non-psychoactive cannabis or its derivatives must comply with Resolution ARCSA-DE-2022-014-AKRG across all three product categories. With such ingredients increasingly present in modern formulations, this belongs on every product review checklist for the Ecuadorian market.
Electronic signatures now mandatory. All documents requiring the signature of the legal or technical representative must be executed with a verified electronic signature and submitted in PDF via ARCSA’s designated platforms. Mixed signature documents are explicitly flagged as carrying significant limitations on legal validity. The practical message: standardize on electronic signatures now.
Why It Matters
Ecuador operates within the Andean Community (CAN) framework — Decision 833 for cosmetics, Decision 706 for household and absorbent personal hygiene products — the same harmonized rules governing Colombia, Peru, and Bolivia. How Ecuador implements that framework in practice matters beyond its borders. For teams managing multi-market Andean portfolios, the apostille elimination and electronic signature rules directly affect filing workflows and document preparation timelines.
If you market these products in Ecuador, update your processes now.
Link to Instructives:
Chile: Recycled Plastics in Food Contact Materials Subject of Emerging Requirements
Chile is in the final stages of approving a landmark update to its Food Health Regulations (RSA) that will, for the first time, establish a clear framework for the use of recycled plastics in food contact materials.
· The Gap Being Closed
The current RSA covers food contact materials in general terms but contains no specific provisions for recycled plastics — a silence that has actively discouraged industry from incorporating recycled content into food-contact packaging despite the technical and safety case for doing so. The amendment changes that. Modeled on EU and MERCOSUR frameworks, it establishes responsibilities for manufacturers, importers, and distributors; defines requirements and restrictions including labeling rules; and creates a specific regulatory pathway for recycled plastics in food-contact applications.
· Where the Process Stands
After a multidisciplinary public-private process led by the Chilean Plastics Pact and the Ministry of Health (MINSAL), including a public consultation extended through October 2025, a final adjusted version was presented to stakeholders on April 17, 2026. The regulation now moves through its remaining procedural steps toward publication in the official gazette, at which point it becomes binding.
Why It Matters
This amendment is the enabling piece for broader circular economy targets. Chile’s REP and Single-Use Plastics Laws both set recycled content targets for plastic packaging — but without food-contact-grade safety rules, those targets are hard to meet in practice. Around 30% of Chile’s installed plastics recycling capacity currently sits idle in part for this reason. The Chilean Plastics Pact’s own 2030 goal calls for 25% recycled content across plastic packaging — this regulation directly unlocks that pathway. For food exporters, it also aligns Chilean standards with EU and MERCOSUR markets where packaging compliance requirements are tightening fast.
Brazil REACH: Mystery Substances
A pattern is emerging across companies beginning to look at Brazil REACH.
In these conversations, one issue keeps surfacing:
Headquarters often assumes it has a clear picture of substances entering Brazil. Then the questions start.
Custom substances being produced locally that are not fully visible centrally.
Internal affiliate shipments treated as logistics rather than imports.
Substance data sitting across different systems that do not speak to each other.
Existing inventories that do not map to what Brazil REACH will require.
Multiple importers each potentially carrying obligations with no coordination.
No single function that actually owns the Brazil REACH question internally.
The regulation itself is not usually the hard part.
The hard part is getting a clear picture of what is actually happening inside your own organization.
That internal visibility exercise is what preparation actually looks like.
And in most companies, it takes longer than expected.s, Costa Rica’s system prevents it — creating a digital trail before the product ever reaches the field.
Chile & Colombia REACH
If your company sells chemicals into Latin America, this question always comes up:“Do we need to do anything for Chile or Colombia REACH?”
The problem isn’t the answer — it’s the time it takes to figure out what the question even means.
Most teams end up digging through scattered guidance, PDFs, and half-explained summaries just to understand how these systems work.
So I built something simpler:
Step-by-step explanations (videos + downloadable report) that walk you through Chile and Colombia REACH from start to finish — so you can understand the full picture in one sitting. No piecing it together. No guesswork.
➡️ Chile REACH course:https://lnkd.in/gfyjGWxJ
➡️ Colombia REACH course: https://lnkd.in/gAqyNNHbRG3
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