Mexico: COFEPRIS Pulls Over 31,000 Digital Ads in Escalating E-Commerce Enforcement Push
Mexico’s Federal Commission for Protection against Sanitary Risks (COFEPRIS) has significantly expanded its digital advertising surveillance program, known as VIGIMED, removing more than 31,000 irregular advertisements from social media and e-commerce platforms so far this year.
Of nearly 37,000 advertisements monitored, the largest share of violations involved medications and food supplements, followed by health services, aesthetic services, medical devices, and cosmetics. Facebook accounted for the majority of removals, followed by Instagram, TikTok, and Mercado Libre.
COFEPRIS operates VIGIMED through collaboration agreements with major platforms including Meta, TikTok, Amazon, Mercado Libre, and Google, under which COFEPRIS flags non-compliant content and platforms execute the removals. The program now also involves coordination with federal and Mexico City security agencies for cases that may involve unlawful conduct beyond advertising violations.
Key Takeaway:
For companies selling or marketing regulated products in Mexico through digital channels, VIGIMED represents active, ongoing regulatory risk. The product categories under heaviest scrutiny — medications, supplements, medical devices, and cosmetics — cover a broad swath of the audience that reads this newsletter. Advertising claims, authorization status, and platform presence for these products in the Mexican market warrant review against COFEPRIS advertising regulations.
Brazil: Updated Procedures for Controlled Chemical Substances (Drug Precursors)
Despite all the attention on Brazil REACH (which is well-deserved), the country has several important control regimes that for years have governed specific groups of chemicals. These so-called “controlled substances” include military controls for listed substances with potential weapons applications. Under a separate list and regime, the Federal Police controls so-called drug precursors under federal law. Finally, state civil police enforce state lists of controlled substance within their jurisdictions. These overlapping regimes affect both raw materials and finished products, and companies doing business in Brazil need to know which lists apply to their portfolio. (For now, no official compilation list exists, although both academic and consultants have created such combined versions over the years.)
In the latest development under the Federal Police regime, Brazil recently adopted Normative Instruction 338/2026 (IN DG/PF 338), published August 3, 2026, consolidating and replacing two prior implementing rules from 2020 and 2021. The new rule reforms how day-to-day controls and enforcement procedures are carried out, but does not alter the substance lists or exemptions, which continue in force under IN MJSP 204/2022. Companies subject to the Federal Police controlled chemicals regime should review the updated procedures.
Link to IN DG/PF 338/2026:
https://www.gov.br/pf/pt-br/assuntos/produtos-quimicos/legislacao/in-338-2026.pdf
Tariffs Are Driving ESG Agendas in Latin America
The intersection of trade policy and human rights compliance is reshaping Latin America’s regulatory landscape faster than any voluntary ESG initiative has managed. The mechanism is strong: the United States has used Section 301 of the Trade Act of 1974 to impose tariffs on countries it finds to lack effective national controls on goods produced with forced labor. Latin American countries are responding, but not all in the same way.
As covered in prior editions, Brazil is facing a 12.5% tariff surcharge on exports to the United States over the forced labor controls issue, stacked on top of a separate 25% Section 301 tariff for other trade practices. Brazil’s government has rejected the forced labor tariff as protectionist, said the US lacks legal basis for the measure, and signaled it will pursue the matter at the WTO. Meanwhile, a legislative bill that would create a domestic forced labor import prohibition seemed to be dusted off as a possible solution, but it is moving through Congress at a slow pace.
Colombia has taken the opposite approach. It was also hit with the 12.5% forced labor tariff effective July 24, 2026. However, its Ministry of Commerce moved quickly to close the alleged regulatory gap. A draft decree published for public comment would prohibit the import of goods produced wholly or partially through forced or compulsory labor, covering all stages of the supply chain and all customs regimes. DIAN, Colombia’s customs authority, would be responsible for enforcement through existing customs mechanisms including seizure and forfeiture. The comment period closed August 15, 2026. The government can move to issue the final standard any day now.
Key Takeaway:
For companies operating across the region, the broader signal is worth noting. Human rights due diligence is no longer a voluntary exercise. It’s becoming embedded in the infrastructure of international trade, with tariff consequences as the enforcement mechanism.
Link to Colombia draft:
Chile: Court Annuls Used Lubricating Oils EPR Decree
Chile’s Extended Producer Responsibility Law (Law 20.920) calls for manufacturers, importers, distributors, and merchants to take charge of their post-consumer priority products. Up to now, Chile recognizes seven priority product categories which are at they are at different stages of EPR implementation. Packaging and containers and tires already have active collection and recovery targets. Electrical and electronic equipment (EEE) and batteries (pilas) have published regulations, with their targets enforceable in 2028. Vehicle/industrial batteries (baterías) are still in the preliminary regulatory stage. Textiles have been officially designated as a priority product, with their implementing regulation currently under development. Lubricating oils were supposed to be one of the operational EPR categories, but a court decision just upended the underlying target-setting decree.
Chile’s Second Environmental Tribunal has annulled Supreme Decree 47/2023, which set the collection and recovery targets for used lubricating oils. The 2024 decree was struck down after the tribunal upheld two of three challenges brought against it by private companies.
The tribunal found the Ministry of Environment committed illegalities on two specific points. First, the restrictions imposed on Individual Management Systems were found to amount in practice to total prohibition, since the traceability and tracking requirements made adherence to that compliance pathway materially impossible, effectively eliminating producers’ right to choose between individual and collective management systems as the law provides. The tribunal also noted that the Ministry’s own justification for the restriction relied on competition-related arguments that the National Economic Prosecutor had already reviewed and rejected. Second, the decree granted distributors the ability to valorize used lubricating oils on their own or through waste managers, a faculty the tribunal found belongs exclusively to industrial consumers under the law.
Because the illegalities affected the integrity of the entire management model and could not be corrected partially, the tribunal ordered total annulment and mandated the Ministry of Environment to issue a new decree as soon as possible, correcting both defects.
Key Takeaway:
Companies in the lubricant sector are now operating without a binding targets decree while the Ministry prepares a replacement.
Link to court decision:
Battery EPR and Recycling: A Week of Developments
Batteries continue to grow in regulatory importance as the clean energy transition accelerates demand for lithium-ion cells and raises urgent questions about what happens at end of life.
In the United States, the Bureau of Industry and Security recently issued a temporary rule prohibiting exports of black mass, the intermediate material produced in the first stage of recycling lithium-ion batteries, without a license or approved exception. The rule takes effect August 27, 2026. The practical challenge is significant: virtually all refining capacity for black mass sits in Asia, leaving U.S. recyclers with limited domestic options in the near term.
Meanwhile, Latin American countries continue to build out their own battery EPR frameworks, which include collection and recycling obligations on producers. Brazil, Colombia, and others have had battery EPR requirements in place for years. Chile is still finalizing its target-setting decree under its Extended Producer Responsibility Law (Law 20.920), and that process has just been extended further: the Ministry of Environment recently pushed the deadline for the decree to January 29, 2027, citing the volume of public comments requiring review.
The contrast is notable. While the U.S. grapples with the recycling infrastructure gap that EPR frameworks are designed to prevent, Latin American regulators are tightening the upstream obligations on producers.
Link to Chile resolution:
Cosmetics: Panama Applies EU’s New Fragrance Allergens to Cosmetics
The interconnectedness of global standards, in particular in the cosmetics sector, is notable. The latest example is Panama’s National Directorate of Pharmacy and Drugs’ safety notice confirming that the EU’s recent expanded fragrance allergen labeling requirements apply to cosmetic products marketed in Panama.
Let’s understand the legal basis. First, Panama applies the Central American Technical Regulation on cosmetic labeling (RTCA 71.03.36:21), a regional standard adopted across Central America and Panama. That regulation requires that safety information on cosmetic labels conform to EU Regulation 1223/2009 on cosmetics and its updates. Because the EU regulation expanding the list of fragrance allergens requiring individual labeling is an amendment to Regulation 1223/2009, Panama’s authority logically confirmed it is now a compliance requirement for cosmetics commercialized in Panama.
The practical obligation: Any of the 81 listed fragrance allergens present above 0.001% in leave-on products or 0.01% in rinse-off products must be individually identified in the ingredient list for cosmetic products in Panama. Products placed on the market by July 31, 2026, may continue to be sold until July 31, 2028, without updated labeling. Products introduced after that date must comply immediately.
Key Takeaway: For cosmetics companies selling into Panama and Central America, take note that EU fragrance allergen compliance has traveled into markets that have adopted the RTCA framework through its dynamic EU reference.
Link to Safety Note 068/SCV/DFV/DNFD-2026: https://dnfd.minsa.gob.pa/sites/default/files/2026-08/Nota%20068-26%20AEMPS%20INFORMA%20DEL%20AUMENTO%20A%2081%20EL%20N%C3%9AMERO%20SUSTANCIAS%20AL%C3%89RGENAS%20DE%20FRAGANCIAS%20QUE%20DEBER%C3%81N%20ETIQUETARSE.pdf
Brazil: ANVISA Cosmetics Sandbox Advances to Protocol Stage
Brazil’s National Health Surveillance Agency (ANVISA) has completed the detailed analysis phase of its regulatory sandbox pilot for personalized cosmetics, clearing all four projects that had passed the preliminary stage to move forward. The four projects, submitted by Grupo Boticário and Natura, involve point-of-sale customization of perfumes and facial bases through automated equipment or digitally assisted manual processes.
With the detailed analysis concluded, the two companies will now be called to present their projects to ANVISA’s working group and provide any additional clarifications needed to develop individualized experimental flexibility protocols. Those protocols will set out, for each project, the operating conditions, temporarily relaxed requirements, activity scope, timelines, monitoring obligations, and risk mitigation measures. The protocols must then pass legal review and be agreed with the companies before going to ANVISA’s Board of Directors for final approval.
ANVISA expects the first point-of-sale cosmetic personalization initiatives to be implemented before the end of 2026.
Link to Report:
Parecer_Analise_Detalhada_VERSAO_PUBLICA_05ago20261.pdfs
Want this delivered weekly? Subscribe to Around Latin America on LinkedIn to get each edition straight to your inbox. Miss an edition? Check out the word searchable repository: www.ambientelegal.com/blog
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.
This site provides general information based on publicly available sources and is not legal advice.
© 2026. All rights reserved. This publication is protected by copyright and monitored by AI-powered content tracking systems. Unauthorized use, reproduction, or distribution is strictly prohibited.
