Brazil’s Sustainable Taxonomy: What you need to know now
On November 3, 2025, Brazil adopted its innovative SUSTAINABLE TAXONOMY via Decree 12.705/2025.
Brazil’s taxonomy sets out clear guidelines for whether a specific economic activity can call itself “sustainable.”
Brazil’s taxonomy is groundbreaking for adopting social goals – like racial and gender equality – along with the environmental and economy objectives.
It broke with EU precedent by including parameters for agriculture – and moved ahead with mining criteria before the EU has finalized its own.
Although use of the taxonomy is voluntary, industry active in Brazil needs to get familiar with this it – future access to financing and government sales may be driven by how an activity performs in comparison to the parameters in the taxonomy for its sector.
Sector-Specific Sustainability Standards
The details of what it means for a specific activity to be “sustainable” are found in the Cadernos. These sector-based documents, set out below, contain the criteria that define which activities are considered sustainable based on their environmental, social, and climatic impacts:
Agriculture, Livestock, Forestry Production, Fishing, and Aquaculture (CNAE A)
Extractive Industries (CNAE B)
Manufacturing Industry (CNAE C)
Water, Sewage, Waste Management and Decontamination Activities (CNAE E)
Transport, Storage and Mail (CNAE H)
Supertaxonomy?
Brazil is hosting COP30 in the Amazon this month – and taking the story of its new Brazilian Sustainable Taxonomy with it.
And it’s not stopping there.
The country is now pushing the concept of a “Super Taxonomy” – an idea it floated at a meeting of the BRICS countries earlier this year.
In Brazil’s vision, this “supertaxonomy” would be a set of principles that allow different national taxonomies to be compared and harmonized. It would allow investors – and others – to compare the sustainability thresholds across borders.
Check out Brazil’s Sustainable Taxonomy
Colombia “REACH”: First National Inventory of Hazardous Industrial Substances
Colombia reached another important milestone in implementation of its modern chemical management system by the release of its first inventory of hazardous industrial substances. Under its REACH-inspired Decree 1630/2021, all hazardous industrial substances imported into or manufactured in the country in quantities over 100 kilograms per year were required to register by May of this year unless otherwise exempt.
Now, the government has had time to load all that information – and create the first inventory of registered substances, of sorts.
Unlike Chile, Colombia will not issue a static list of the substances in the first inventory via resolution or publication. Instead, the country has opted to post innovative public dashboards that act as the de facto inventory – and provide more information.
There are 4 dashboards:
- Dashboard on Principal and Secondary Uses for the Registered Substances
- Dashboard on Headquarters for the Registrants
- Dashboard of Hazards Reported for Registered Substances
- Dashboard of Users (i.e., Registrant Companies)
The dashboards can be used to sort the 4,473 registered substances into a list that provides CAS number and IUPAC names. This view would most resemble the type of inventory shared by Chile in its first published inventory list from last year.
At a recent regional meeting, Colombian officials explained that the information in these dashboards has not been revised or scrubbed by the government. Instead, the agency opted to post the information reported by the companies registering the substances in the official platform known by the acronym “INSQUI” on an “as is” basis.
What is the significance?
Now that we have a first national inventory, it is possible to know whether a substance is “new” or not. Decree 1630/2021 defines “new chemical substance” as a substance imported or manufactured in the country after the May 2025 deadline and which is not included in the National Inventory of Chemical Substances for Industrial Use. Then, the Decree states that for new industrial chemicals that meet the criteria and conditions to be considered a priority or of interest to health or the environment, in accordance with the upcoming regulation on prioritization, the importer or manufacturer will need to carry out an environmental or health risk assessment to determine the risk associated with uses in Colombia.
In other words, new substances that meet the criteria for prioritization will need a risk assessment.
Government officials have intimated that the future prioritization regulation should shed more light on how this requirement of prior risk assessment for so-called “new chemicals” will be handled.
For now, the new dashboards that act as a national inventory allow us to know what hazardous industrial substances have been registered in Colombia – and the ones not on that list should be considered “new.”
Next Steps
The country is working on a prioritization regulation that should come online next year. After that, a second regulation on risk assessments is in the works.
Key Insights:
- Colombia has posted its first “national inventory” of hazardous industrial substances through a series of dynamic informational dashboards that are now publicly available on the INSQUI platform at the following link: https://insqui.sical.gov.co/BI/tableros_insqui.html
- Companies should check to see whether substances of interest have been registered – or not.
Argentina: Crop and plant protection products get even more reforms
Argentina enacted a major liberalization of how it will register and regulate crop protection products earlier this year when it adopted Resolution 458/2025 (see earlier editions for coverage). Some of those changes have been so big that the government has decided it is necessary to make many revisions and clarifications to Resolution 458 (including all of the annexes) – while keeping the bulk of the liberalization to the process and the adoption of GHS (Rev. 9) for plant protection products – via the publication of Resolution 843/2025 on November 4, 2025.
Key Updates to Resolution 458/2025:
- Clarification of procedures Changes to improve clarity in the procedures and processes.
- Simplification and streamlining Incorporation of adjustments aligned with national policies on deregulation and administrative simplification, making procedures more efficient than those originally set.
- Specific requirements for certain product categories Adds or revises requirements for coadjuvants, semiochemicals, and bioinputs, recognizing their distinct characteristics and risks, which were not fully addressed in earlier version.
- Establishment of a public and dynamic procedural guide Mandates the creation of an accessible, regularly updated guide to provide transparency and facilitate compliance, expanding on the procedural framework.
- Incorporation of “Línea Jardín” (Law & Garden) products into the new system Updates the regulatory framework to bring lawn and garden products under the scope of the National Registry of Plant Protection Products created by Resolution 458/2025, replacing or harmonizing prior rules from Resolution 871/2010.
- Adjustments to registration, importation, experimentation, and labeling processes While 458/2025 defined these requirements following the GHS, Resolution 843 revises the associated processes and requirements to improve their applicability and implementation.
- Improved alignment with resource-efficiency goals Restructures certain procedural requirements to allow SENASA to manage its responsibilities with greater efficiency.
- Extends implementation deadline Originally should have gone into effect by end of September 2025 – pushed out to January 5, 2026.
Companies active in plant and crop protection in Argentina need to review these changes in detail.
Link to Revised Res 458 2025
GHS in Argentina
Argentina adopted the GHS as a workplace standard in 2015. Since Resolution SRT 801/2015, the country has applied GHS Rev 5 to employers and workplaces. Now, via Resolution 458/2025 as amended by Resolution 843/2025, the country has expanded the use of GHS to plant protection products (including crop protection). Interestingly, the crop and plant protection products sector will instead use GHS Rev 9 – several versions ahead of the GHS used in the workplace. It is not yet clear if this will create situations where the two versions may be in conflict on labeling or SDS for a specific product. For more on the GHS for plant protection products, see the revised version of Resolution 458/2025 and in particular Annex III.
Link to Revised Res 458 2025
Brazil: Extended Producer Responsibility, Compliance, and Reputational Risk
Clients often ask me not only about regulations in Latin America – but how they are enforced. Reporting on enforcement is always more challenging since governments don’t always make that information public. When they do, it’s always important to dig in and see what lessons we can take from it.
Brazil has expansive obligations that apply to all kinds of companies that place packaged goods on the market. The federal government – and many states – require EPR for “general packaging.” This broad category is defined at the federal level as any packaging that makes up the dry fraction of municipal solid waste or equivalent, generated after use by the consumer, except those classified as hazardous by Brazilian legislation and technical standards. (Federal Decree 11.413/2023, Art. 5(VI))
Companies that place those products on the market need to belong to (or create) a producer responsibility system (a management system). In some states, the authorities require companies to show annually that they have implemented a reverse logistics system (or belong to one) for packaging waste in that state.
Mato Grosso do Sul has gone a step further by “naming and shaming.” The state publishes an annual list of the companies that are in compliance with their packaging EPR obligations – and then another list of those that are not. The state recently published this year’s list of manufacturers and importers who were summoned to prove they had implemented a Reverse Logistics System for Packaging in General in Mato Grosso do Sul and failed to do so. The measure goes on to state that these companies are in default with their obligations and subject to the penalties under state and federal laws.
Government agencies in Latin America are often underfunded and understaffed. Publication of such “name and shame” lists – threatening sanctions but already inflicting reputational risk – are low-budget way to prod companies to comply with their obligations.
Key Insight:
- Enforcement in Latin America can look like public outing of non-compliant players, and companies should be aware of the reputational risks that entails.
Link to Mato Grosso do Sul lists of compliant and non-compliant companies:
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