Brazil: Endocrine Disrupting Chemicals Subject of New Bill

Up to now, Latin American countries have not always tackled chemical groups that are on international agendas – like PFAS or endocrine disrupting chemicals (EDCs). In both cases, Brazil has some rules for certain small subsets of the chemicals: PFAS in pesticides under the Stockholm Convention or phthalates in children’s toys and some childcare products.

Now, though, a bill under consideration in Brazil’s Chamber of Deputies would require manufacturers to disclose the presence of EDCs – and later ban them – in products intended for babies, children, and pregnant women.

Notably, the Bill defines broadly as “substances with endocrine-disrupting potential” are those that, according to recognized scientific evidence, are capable of interfering with the functioning of the human endocrine system, producing adverse health effects. And it applies the precautionary principle, “particularly given the greater biological vulnerability of infants, children, and pregnant women to exposure to substances with endocrine-disrupting potential.”

The proposal covers a wide swath of product categories:

• Cosmetics and personal care items, including shampoos, soaps, sunscreens, repellents, lotions, and creams
• Food packaging, including containers used for infant food storage
• Toys and children’s items, including pacifiers, bottles, cups, plates, and plastic or rubber utensils
• Medications, subject to specific risk-benefit rules

The bill’s sponsor noted that manufacturers currently use technical abbreviations like DBP, DMP, or BPA rather than common names like phthalates and bisphenol, making identification difficult for consumers. The proposed labeling requirement would require clear disclosure of endocrine-disrupting substances by name.

In addition to the labeling, the bill calls for a prohibition: Five years after enactment, the manufacture, import, distribution, sale, and offer of covered products containing substances on ANVISA’s restriction list would be prohibited. For medications, prohibition would apply only where a safe and effective alternative treatment exists.

Non-compliance with labeling obligations would trigger penalties under Brazil’s Consumer Protection Code, while commercialization of prohibited products would be subject to federal health legislation sanctions.

The bill has been presented to the first of four Chamber Committees for review before a full Chamber and Senate vote. This bill is very early in the legislative process – and any prediction of its chances of passage would be inappropriate. However, it shows that chemicals of concern are on the minds of legislators – not just regulators. It remains one to watch.

Link to Bill 3169/2026:

https://www.camara.leg.br/proposicoesWeb/prop_mostrarintegra?codteor=3148499&filename=PL%203169/2026

Chile: EU Siloxane Restrictions Apply to Cosmetics — D4 Prohibited, D5 and D6 Limited

EU restrictions cross the pond faster and more often than ever before. We are seeing this particularly in the context of cosmetics. As we noted in a recent edition covering Panama, the EU’s cosmetic ingredient rules travel into Latin American markets that have built dynamic EU references into their own frameworks. Chile is another example of that phenomenon. The EU’s restrictions on cyclic siloxanes in cosmetics are not just a European compliance matter for companies selling into Chile. Chile’s cosmetic regulatory framework incorporates EU ingredient lists by reference, and the ISP — Chile’s Public Health Institute — has explicitly stated that EU deadlines must be respected for newly restricted substances.

The legal basis sits in Supreme Decree 239/2002, which governs Chile’s National Cosmetic Control System. Articles 31 and 42 of that decree establish that cosmetic ingredient approvals are based on ISP-published lists of authorized, limited, and prohibited ingredients, and that in the absence of ISP-specific lists, the EU Cosmetics Directive and its subsequent modifications serve as the reference. The ISP incorporates EU official ingredient lists into its GICONA ingredient database and updates them periodically. The ISP’s own restricted ingredients page confirms that going forward, the deadlines published by the European Community must be respected for ingredients with new restrictions.

What applies to D4, D5, and D6:

D4 (octamethylcyclotetrasiloxane) is prohibited outright in cosmetics in Chile. Because D4 carries a CMR classification (carcinogenic, mutagenic, or reprotoxic) it is not eligible for any transitional grace period.

D5 (decamethylcyclopentasiloxane) and D6 (dodecamethylcyclohexasiloxane) are restricted to a maximum concentration of 0.1% in cosmetic products. Following EU timelines, the restriction applies to rinse-off products from June 6, 2026, and to leave-on products from June 6, 2027. Chilean industry guidance interprets the local application as January 1, 2027 for manufacture and import, with non-compliant products to be withdrawn from the market by July 1, 2028.

Key Takeaway: Companies formulating or importing cosmetics into Chile that contain D5 or D6 should review concentrations against the 0.1% limit and confirm compliance timelines for both rinse-off and leave-on product lines. D4 should already be absent from any product in the Chilean market.

Links:

ISP, Restricted Cosmetic Ingredients: https://www.ispch.gob.cl/anamed/cosmeticos/ingredientes-cosmeticos/ingredientes-restringidos/

ISP, Prohibited Cosmetic Ingredients: https://www.ispch.gob.cl/anamed/cosmeticos/ingredientes-cosmeticos/ingredientes-prohibidos/

Supreme Decree 239/2002: https://www.bcn.cl/leychile/Navegar?idNorma=211455

Brazil: Cosmetic Adverse Event Notifications Surge 130% Under New Cosmetovigilance Rules

One year into the implementation of Brazil’s Good Practices in Cosmetovigilance regulation (RDC 894/2024), ANVISA has published results showing a sharp increase in adverse event reporting for personal care products, cosmetics, and perfumes. The numbers tell a compliance culture story as much as a safety one.

Between August 2025 and July 2026, 592 adverse event notifications related to cosmetics were recorded in ANVISA’s Notivisa system, compared to 257 in the prior period — an increase of approximately 130%. The growth among companies was even more dramatic: industry-reported notifications jumped from 115 to 536, a 366% increase, with companies moving from approximately 45% to over 90% of total notifications filed.

ANVISA frames the increase as a sign of stronger monitoring systems and reporting culture rather than an increase in product problems. That framing signals that companies are building the internal surveillance infrastructure the regulation requires.

The regulation also expanded the scope of what must be monitored. Beyond adverse reactions, cosmetovigilance now covers product inefficacy, intoxications, occupational exposures, and technical complaints with health impact. ANVISA also completed its first pilot inspection on cosmetovigilance good practices during the period and trained over 400 professionals across state and municipal health surveillance agencies.

Key Takeaway: For cosmetics companies selling in Brazil, the data sends a clear signal: ANVISA is actively building enforcement capacity in this area, and the expectation of robust internal adverse event monitoring and reporting is real.

Brazil: Critical Minerals Policy Approved, Heads to Presidential Signature

Latin America has a crucial role to play in AI and emerging technologies – and the energy transition. Latin America is the world’s leading source of key materials needed for the technology driving today’s data centers and more. The lithium from the Lithium Triangle, the copper from Chile and Peru, the rare earth minerals from Brazil. And based on a recent press article, Mexico is also the leading producer of the tech needed for the U.S. AI infrastructure.

Into this critical juncture, as we recently reported, different countries are taking varying approaches to their critical mineral policies and determinations of sovereignty. Brazil just took a major step toward asserting control over its critical minerals supply chain. The Senate approved Bill 2780/2024 on September 2, 2026, establishing a National Policy on Critical and Strategic Minerals (PNMCE). The bill goes directly to presidential signature since the Senate made no changes to the Chamber’s May 2026 text.

Brazil holds significant reserves of lithium, nickel, and rare earths which are materials essential for batteries, solar panels, electric vehicles, and high-technology manufacturing. The new policy creates the institutional and financial framework to develop those reserves domestically rather than export them as raw materials.

The headline for companies with mineral assets or supply chain exposure: the law introduces a government approval mechanism for certain transactions involving critical mineral rights, including changes in corporate control, foreign access to strategic geological information, international supply contracts that could affect Brazil’s economic or geopolitical security, and transfer of mineral titles. The procedure, timelines, and transition rules will be defined by regulation, which means meaningful uncertainty until that regulation arrives.

Other key instruments: a R$2 billion Mineral Activity Guarantee Fund, tax credits of up to 20% on industrial costs (capped at R$1 billion per year from 2030 to 2034), and a mandatory supply chain traceability system. The Executive Branch has 90 days from enactment to install the new council and publish implementing rules.

Link to PL 2780/2024: https://www25.senado.leg.br/web/atividade/materias/-/materia/174060

Brazil: EV Battery Recycling Policy Advances to Chamber

As electric vehicles (EV), especially from China, hit the streets in record numbers in Latin America, the question of what to do with their used batteries becomes a more pressing concern. In the region, only a few countries have EV-battery specific standards (like Uruguay and the emerging EPR decree in Chile). Now, Brazil’s Senate Environment Committee approved a bill on September 1, 2026, establishing a National Policy on the Circularity of Vehicle Batteries, covering the full lifecycle of batteries used in electric and hybrid vehicles from manufacturing through final disposal. The bill now heads to the Chamber of Deputies.

The policy establishes EPR as a central instrument, along with reverse logistics, traceability, recovery of secondary raw materials, and a national monitoring platform. Manufacturers would be required to disclose the materials and quantities used in battery production and comply with best practices on material safety and efficiency across the full lifecycle including remanufacturing and reuse stages.

Notably, the approved text flexibilizes the reverse logistics framework. Rather than imposing rigid mandatory requirements, implementation of reverse logistics systems will be established through sector agreements, commitment terms, or specific regulation — an approach designed to avoid creating barriers to Brazil’s still-developing electric vehicle industry. A battery passport and other certifiable traceability instruments may be adopted by regulation.

A Battery Circularity Management Committee will coordinate implementation across federal, state, and municipal levels with private sector participation.

The bill still needs Chamber approval before heading to presidential signature.

Link to PL 2132/2025: https://www25.senado.leg.br/web/atividade/materias/-/materia/168417

Brazil: New Fertilizer Program Requires Mandatory Blending in 2027

Brazil enacted Law 15.496/2026 establishing the Fertilizer Industry Development Program (Profert). The law addresses a longstanding vulnerability: Brazil currently imports more than 85% of the fertilizers it consumes, with Russia as its primary supplier. Recent geopolitical disruptions like the Strait of Hormuz restrictions in 2026 that constrained ammonia and urea flows have repeatedly translated into sharp input cost increases for Brazilian agriculture.

The most operationally significant provision for companies in the fertilizer supply chain is a mandatory blending obligation. Starting July 1, 2027, all fertilizers commercialized, distributed, and sold in Brazil must contain a minimum of 2% domestically produced synthetic or mineral fertilizer by volume. That threshold rises to 10% by January 1, 2037, with the possibility of further increases up to 30% after 2038, subject to regulatory review by the National Fertilizer and Plant Nutrition Council (Confert). Non-compliance is subject to penalties under existing mining legislation, with the Executive Branch responsible for enforcement.

The Profert program separately creates BNDES financing lines for domestic fertilizer producers, covering plant construction and modernization, research and development, logistics infrastructure, and price stabilization mechanisms. Financing conditions will be set by the National Monetary Council. Domestic producers participating in Profert must meet sustainability requirements including GHG mitigation measures and energy efficiency commitments.

Implementing regulations are still pending. Key details like the specific substances subject to the blending obligation, project qualification criteria, and financing conditions all depend on Executive Branch action. Companies importing, distributing, or selling fertilizers in Brazil should monitor the regulatory process closely, as the July 2027 blending deadline is less than a year away.

Link to Law 15.496/2026:

https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2026/lei/l15496.htm

Mexico: Revised Rules on Mining Wastes

Mexico’s Ministry of Environment and Natural Resources (SEMARNAT) published Official Mexican Standard NOM-157-SEMARNAT-2026 with new rules on management of mining waste. The new standard replaces NOM-157-SEMARNAT-2009 and enters into force 180 days after publication — in early March 2027.

The standard is mandatory for all entities that generate or possess mining waste. Key updates include the incorporation of a comprehensive characterization study as a compliance pathway, designed to generate information on waste properties and guide selection of appropriate management measures. The standard prioritizes prevention, valorization, and treatment through new processes, methods, and technologies over final disposal, which is positioned as a last resort. The updated waste list reflects current mining practices and materials.

Mining companies and their chemical and materials suppliers operating in Mexico should review their waste management programs against the new standard before the March 2027 entry into force date.

Link to NOM:

https://dof.gob.mx/normasOficiales/9575/semarnat/semarnat.html

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Tracking Brazil’s new chemical management law? Visit www.BrazilREACH.comfor plain-English guidance on Law 15.022/2024, including what an Only Representative structure means in practice.

Questions about how any of this applies to your business? Reach out directly at mowen@ambientelegal.comto talk about how we can help your business succeed in Latin America.

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