Dangerous Goods Transport: Draft Limited Quantity Rules for Mexico
Mexico continues work on a revised standard on conditions for the transport of dangerous goods packaged/contained in limited quantities. The first draft was published in 2021, but it was never adopted. Now, a re-formulated version has been posted within the CONAMER for public comment (prior to the official public comment period once published in the Official Gazette). The new version – PROY-NOM-011-SICT2/2025 – aligns with the 22nd edition of the UN Model Regulations on the Transport of Dangerous Goods. It also would authorize parcel and courier companies to transport these goods in limited quantities if the new standard were followed.
- Link to Notice in CONAMER:
https://www.cofemersimir.gob.mx/expedientes/31978
- Link to Draft:
Brazil’s New Benchmark for Assessment of Pesticide Exposure Risk
Anvisa has issued RDC 998/2025, establishing— for the first time in Brazil— clear rules to assess non-dietary exposure risks to pesticides, covering not only consumers but also operators, workers, residents, and bystanders. The regulation implements the New Pesticides Law (Law 14.785/2023).
Key highlights include mandatory non-dietary risk assessments for new and existing products, harmonized technical parameters, creation of the DAROC exposure dossier, compulsory use of the national avaliAR calculator, and more realistic risk-mitigation measures (including PPE requirements). A phased transition and a technical guidance document open to public consultation further support implementation.
Anvisa has also launched a dedicated webpage consolidating the regulation, technical guide, FAQs, and the avaliAR tool, reinforcing transparency and access to guidance (link below).
Expected impacts: stronger protection for rural workers and nearby communities, more robust product registration and re-evaluation criteria, clearer label instructions, and incentives for safer technologies. RDC 998/2025 was published in late November 2025, but it does not go into effect until June 1, 2026. Brazil is aligning with international best practices in pesticide risk management.
- Link to RDC:
- Link to ANVISA Website for New System:
https://www.gov.br/anvisa/pt-br/assuntos/agrotoxicos/risco-ocupacional
Colombia: Ban on Animal Testing in Cosmetics
The trend in Latin America is clear: ban on animal testing for cosmetics. Brazil implemented its ban recently via law. Colombia actually adopted a law several years ago – Law 2047/2020 – that prohibits animal testing for cosmetics and cosmetics ingredients. However, as is often the case, the law requires more regulatory infrasture. Now, Ministry of Health has released a draft resolution to implement the law. The proposal establishes a practical compliance mechanism: companies would submit a first-party declaration confirming no animal testing in the cosmetics or their ingredients as part of Mandatory Sanitary Notification (NSO) process before INVIMA (Colombia’s FDA analog).
If adopted, the rule would provide greater legal certainty for industry, strengthen enforcement, and align Colombia with international cruelty-free regulatory trends. Companies active in cosmetics in Colombia should take note.
Link to Draft:
Brazil: New Rules on Cosmetics Packaging Proposed
First, let’s take a minute to talk about the other major packaging news out of Brazil: the decree on mandatory EPR for plastic packaging (primary, secondary, and tertiary) that also introduces mandatory recycled content requirements for covered plastic packaging. Packaging for cosmetics products are already covered in Brazil by the rules on “General Packaging,” and now their plastic packaging is covered by the new plastic packaging decree (Decree 12688/2025).
On top of that, Brazil’s FDA analog (ANVISA) has now posted for public comment two draft standards on cosmetics packaging: Public Consultations (CP) 1.380 and 1.381/2026. The drafts cover fractionation of products and the reuse of packaging for personal hygiene products, cosmetics, and perfumes sold directly to consumers, respectively. The drafts aims to update existing rules, expand the range of product categories eligible for fractionation, and allow packaging reuse in specific cases.
Fractioning is defined as the “set of operations intended to divide the product into smaller quantities, preserving the technical quality specifications and labeling identification data in accordance with current legislation and resulting in a finished product.”
The drafts set out technical requirements and best practices to ensure product quality, safety, and traceability, covering company and establishment responsibilities, documentation, staff training, facilities and equipment, hygiene and maintenance, handling of complaints and recalls, cosmetovigilance, and specific conditions for packaging reuse.
Comments can be submitted up to March 21, 2026 through Anvisa’s electronic consultation forms.
Link to Drafts:
Consulta Públicas (CP) n. 1.380/2026
Consulta Pública (CP) n. 1.381/2026
EPR Enforcement in Chile
First, the client wants to know: Does the country have a law requiring this? (In this case, EPR for packaging.)
Second, some ask me: Do they enforce the requirement?
That last question is a bit sticky as an attorney. In theory, compliance should not be subject to a country’s enforcement of their laws. If your company has global commitment to compliance, all we need to do is determine if there is a requirement that applies to your scenario. In the real world, though, it’s more complicated.
Enforcement is often the driver that makes some players take note. Some actors move not only when they are told to, but when they know there are real consequences to not doing so. For that reason, I try from time to time to cover novel enforcement matters. That’s the case here.
Chile has had a requirement for companies that place packaged products on the market to be responsible for that packaging at end of life for several years. Packaging is one of its “priority products” under its 2016 EPR Law. Each priority product is supposed to be covered by its own target-setting decree. For packaging, Supreme Decree 12/2020 set a deadline of September 16, 2023, for covered companies to create their own (individual) or join others (collective) in a management system.
In the case at hand, a major international telecommunications OEM that sells products in Chile recently found that some of the moves accepted under standard Chilean environmental law will not serve as a defense to the EPR obligations. Essentially, the company did not meet that 2023 deadline. Instead, it did not take action until the environmental authorities (SMA) formally raised the non-compliance and requested information.
The company then came into compliance by joining an EPR management system – and told the authorities about it before charges were formally notified. That – under general environmental law – might have worked as a Compliance Plan defense (Programa de Cumplimiento, PDC). The government did not accept this defense.
Instead, it found that for violations of the EPR Law (Ley REP), lawmakers created a special sanctioning regime, and Compliance Programs are not permitted under this regime, regardless of timing or content.
Key Takeaways from the ruling:
📌Chilean authorities are looking at your operations – and beginning enforcement actions when they don’t find your EPR Management Program in place.
📌Companies won’t be able to use the Compliance Plan option to avoid enforcement.
📌Instead, compliance with the EPR obligations appears to require strict compliance with the obligations as enacted – including the deadlines.
📌Companies placing packaged products on the market in Chile – a very broad category – need to get their EPR scheme in order.
Mexico – Changes to Controlled Chemical Precursor Rules
Companies who transport controlled chemical precursors in Mexico must migrate to the online version of two common forms. The changes are part of the country’s continued efforts to standardize and modernize how chemical precursors and essential chemicals are handled.
- What was changed?
Mexico has published modifications to two official forms:
· One-Time Notice (Aviso único)
· Annual Report (Informe anual)
- Who does it apply to?
Changes impact to transporters in:
- Federal road transport
- Air transport
- Rail transport
- What do companies need to do differently?
· Move reporting to the new PREQUIM
· File the “One-Time Notice”and the “Annual Report” (Informe Anual) online in the official digital formats
- When do the new rules go into effect?
NOW! They went into effect upon publication of the notice in the Official Gazette.
- Where can companies access the new system?
⚠️Tricky! Officials acknowledge the new system is not ready yet – but the legal obligation already exists. One industry association in Mexico recommended to its members that they begin preparing the information for this migration now to be prepared.
Link to Notice:
https://www.dof.gob.mx/nota_detalle.php?codigo=5350651&fecha=01/07/2014#gsc.tab=01/16/44350/01/2749490.pdf
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