🚨 Colombia REACH – Don’t miss a key deadline: Sept. 30 is coming fast
If you registered chemical substances in 2025, you are required to report your 2024 annual volumes in the national INSQUI platform by September 30.
Foreign companies that used the Foreign Representative option (REE) to protect Confidential Business Information must also enter their substance volumes by September 30.
We are actively supporting clients with this process — and ready to support you as well.
Contact us: mowen@ambientelegal.com – more information at www.ambientelegal.com
Carbon is becoming a cost — and an asset – in Brazil.
In September 2025, Brazil’s Securities and Exchange Commission (CVM) released a FAQ on the Brazilian Greenhouse Gas Emissions Trading System (known by Portuguese acronym SBCE), created by Law 15.042/2024. The FAQ translates the new law into practical guidance for companies, regulators, and investors.
What’s New
- Coverage & Timing:
Companies emitting >10,000 tons CO₂e/year will be included. Those above 25,000 tons/year will face mandatory reduction targets. The SBCE is not yet fully operational; obligations will be phased in gradually over the coming years.
- Governance:
The SBCE’s managing authority, Interministerial Committee on Climate Change (CIM), will set caps, allocate allowances, and verify reductions. The CVM will regulate Cotas Brasileiras de Emissão (CBEs, Brazilian Emission Allowances) and Certificados de Redução ou Remoção Verificada de Emissões (CRVEs, Verified Emission Reduction or Removal Certificates) when traded in financial markets as securities.
Voluntary Credits: The FAQ confirms that credits from voluntary carbon market will gain legal certainty when recognized as CRVEs inside the SBCE.
Business Impact
- Compliance costs: Large emitters will soon face binding caps and reduction requirements.
- Opportunities: Companies that reduce emissions efficiently can monetize surplus CBEs/CRVEs.
- Sector exposure: Energy, transport, and heavy industry will be most affected early.
- Strategic alignment: The SBCE anchors Brazil’s Paris Agreement target of a 59–67% cut in emissions by 2035 (vs. 2005 levels), giving business a clear long-term policy signal.
👉 Key Takeaway: The FAQ gives the first concrete roadmap for Brazil’s regulated carbon market. Companies above the 10,000-ton threshold should begin preparing for phased obligations now to manage costs and capitalize on trading opportunities.
Link to FAQ:
🚨 New Regulatory Guidance for Cosmetics & Hygiene Products in Ecuador 🚨
The National Health Regulation Agency (ARCSA) has released an updated instructive detailing the requirements for the Mandatory Sanitary Notification (NSO) of:
✔️ Cosmetics ✔️ Household hygiene products ✔️ Personal hygiene absorbent products
This DRAFT is really big – setting out five annexes based on Andean Community legislation that covers:
- Guide to requirements for obtaining NSO for cosmetic products, household hygiene products, and absorbent personal hygiene products (check out the new guidance on cannabis-derived ingredients and electronic signatures).
- Guide to requirements for joining an existing NSO (as a parallel importer).
- Guide to requirements for renewing NSO for cosmetic products, household hygiene products, and absorbent personal hygiene products.
- Guide to requirements for recognition of the NSO for cosmetic products, household hygiene products, and absorbent personal hygiene products.
- Guide to requirements for modifying the information in the NSO for cosmetic products, household hygiene products, and absorbent personal hygiene products.
Comments may be submitted until OCTOBER 8, 2025.
Link to Proposal:
What to Expect in Environmental Regulations in Mexico
Mexico’s federal environmental agency released its latest Sectoral Program for Environment and Natural Resources (Programa Sectorial de Medio Ambiente y Recursos Naturales or PROMARNAT). This long policy document – last issued in 2020 – sets out the agency focus and vision for protecting the environment in Mexico over the next five years based on the following six core objectives:
- Conservation and sustainable use of ecosystems and biodiversity).
- Restoration of priority ecosystems
- Guarantee of the human right to water
- Climate action and pollution prevention
- Humanist ecological policy and environmental justice
- Institutional strengthening and intersectoral coordination
The PROMARNAT is NOT an action plan – it does not set out specific new regulations or NOMs or any timeline for agency action. Instead, it serves as a guide to the agencies priorities over the coming five years.
📌Key Take-Away for Business:
- Companies should expect new regulations and increased enfocement emission controls (especially wastewater), hazardous waste, and energy efficiency.
- Companies should be on the lookout for new site remediation obligations and updated NOMs on hazardous waste, remediation of contaminated sites, high-risk activities, and extractive activities.
- Equally notable is what was NOT mentioned:
- ❌ No mention of any new chemical law or regulation like “REACH”-inspired schemes taking off in South America
- ➡️ Nothing about mandatory carbon or sustainability reporting – probably because the latter is covered by the requirements as of 2025 set by the National Banking and Securities Commission of Mexico (CNBV).
Link to PROMARNAT:
https://www.dof.gob.mx/nota_detalle.php?codigo=5767440&fecha=08/09/2025#gsc.tab=0
