Brazil: No Surprises as Forced Labor Bill Revived
First, as we reported last week, the United States proposed a 12.5% tariff on Brazilian goods over an alleged failure to enforce a forced labor import prohibition. Then, Brazil’s government rejected the claim. Now, Brazil’s Congress has dusted off a decade old bill aimed at cacao and repurposed it to function as an explicit statutory prohibition of forced labor. The new text would prohibit import and market placement of any product where forced, compulsory, or child labor is confirmed in production.
What It Would Do
The bill expands the prohibition from cocoa to any product or raw material entering Brazil. It introduces a “labor due diligence” defense: importers can avoid penalties by demonstrating, administratively, that they implemented due diligence proportionate to their size and risk. Confirmation of forced or child labor requires a final judicial decision, domestic or international. Customs enforces; violating goods are subject to seizure. A biannual list of offending foreign companies would be published.
What’s Next
The bill still needs two more committee approvals, a Chamber floor vote, and Senate passage. No fixed timetable exists, and the bill’s decade of stalling makes passage uncertain even now.
Why It Matters
This bill is worth tracking regardless of outcome. If enacted, it creates a new compliance dimension for anyone importing into Brazil: a documented due diligence framework to avoid liability. Companies sourcing from sectors with known forced labor exposure like agriculture, textiles, minerals, or electronics should watch closely. Perhaps most importantly this signals that Brazil is responding to the USTR pressure noted in last week’s edition of the newsletter.
Link to Bill:
Mexico-EU Trade Deal: Latin America as Market, Not Just Commodity Source
During this time of shifting global alliances and supply chain disruption, Latin America has become an important market — not just a commodity source — for key countries and regions like China and the EU. Although the US is pursuing tariff actions across Latin America, including the forced labor and deforestation determinations against Brazil we covered in recent editions, other major economies are moving the opposite direction. The EU just renewed its ties with Latin America’s second biggest market – Mexico.
Mexico and the EU signed the Modernized Global Agreement (MGA) and an Interim Trade Agreement on May 22, 2026, replacing the framework in place since 2000. Ratification is pending. European Parliament consent and ratification by all EU member states are still required.
Notable features
- Services market access. EU companies gain new ability to provide services in Mexico across finance, telecommunications, transport, digital trade, and environmental services. This represents a shift from goods trade toward Mexico as a services destination.
- Subnational procurement access. EU companies gain access to Mexican state-level government procurement for the first time, beyond the federal tenders already covered under the prior agreement.
- Raw materials on new terms. The deal eliminates export restrictions and import duties on raw materials, bans export monopolies, and prohibits dual pricing schemes. It reforms how the commodity relationship works rather than simply expanding it.
- More flexible rules of origin in chemicals. Alongside automotive and aeronautical, the chemical sector gets more flexible origin rules, relevant for companies with globally diversified inputs feeding Mexican or European manufacturing.
- Enforceable sustainability commitments. Environmental and labor provisions are legally binding and enforceable through independent dispute panels, with a dedicated monitoring committee. Although this might be touted as a step beyond symbolic FTA sustainability chapters, the real impact will depend on the enforcement activity and not just the black letter provisions.
Next Steps Toward Implementation
The agreement operates on a two-speed track. The Interim Trade Agreement enters into force once both parties complete internal notifications, expected by late 2026 or early 2027. That first move covers only the trade matters within exclusive EU competence and will apply in the meantime. The full Modernized Global Agreement requires a longer path: consent from the European Parliament, ratification by all 27 EU national parliaments, and approval by the Mexican Senate, a process that historically takes several years. Certain provisions of the MGA may be provisionally applied before full ratification, subject to agreement between the parties. Companies should watch for the ITA’s entry into force as the first practical milestone, with full MGA ratification as the longer-term horizon.
Link to agreement text:
Brazil: New Plastics Bill Would Add PFAS Ban and Mandatory Labeling on Top of Existing EPR Regime
Could a PFAS ban come in through the side door? A Brazilian Congressional committee just approved a substitute bill ostensibly focused on plastic waste. Whle it clearly calls for tacking on significant new obligations onto the plastic packaging framework we already know (the reverse logistics decree we have covered in depth in prior editions), it’s PFAS provision is the real headline here.
The Chamber of Deputies’ Industry, Commerce and Services Committee approved a substitute combining three bills — PL 1.071/2025, PL 1.242/2025, and PL 5.321/2025 — on June 16, 2026. The substitute amends Law 12.305/2010, Brazil’s framework solid waste law, that sets out the current EPR requirements (called “reverse logistics” in Brazil).
PFAS and Heavy Metals Phase-Out
The bill would add progressive elimination of PFAS — per- and polyfluoroalkyl substances — and heavy metals from plastic packaging composition as a formal objective of the national waste policy. The rapporteur’s reasoning is explicit: without a clear prohibition, Brazil risks becoming a dumping ground for materials already banned in other markets. For companies using PFAS in plastic packaging formulations for functional properties, this is the provision to watch.
Mandatory Polymer and Recyclability Labeling
Plastic packaging would need to visibly and indelibly display the polymer material identification along with a recyclability index, in categories still to be defined by regulation. Generic labeling using terms like “plastic” or “resin” would be explicitly prohibited, and labels would need to specify the predominant thermoplastic resin.
Recycled Content Targets
A minimum 10% recycled content target would apply within five years of the law’s publication, with future regulations setting progressive targets beyond that.
Reverse Logistics Scope Expansion
The bill also opens the door to extending reverse logistics obligations beyond plastic to products in metal and glass packaging, prioritized by health and environmental impact and low recyclability — a notable signal of where this framework could expand next. Notably, other packaging is already covered by EPR in Brazil under its existing framework for “general packaging” (including paper and glass). Presumably the bill is referencing expansion of the more innovative provisions to these other materials.
Modeled on the EU
The rapporteur explicitly used the EU’s Packaging and Packaging Waste Regulation (PPWR) as the reference point for this substitute, citing labeling and recyclability frameworks in the EU, France, and South Korea as evidence that clear labeling improves sorting efficiency at recycling facilities.
Timeline
The bill has cleared one committee. It still needs approval from two more committees before a floor vote and Senate consideration. If enacted, it would enter into force 365 days after publication. Bills in Brazil can notoriously take years to advance, but this proposal seems to be moving rather quickly.
Key Takeaway
First, this Bill would heap obligations onto an already full compliance plate. Companies that have built compliance programs around the existing plastic packaging reverse logistics decree should not assume that work is complete. We are already waiting on the traceability system and more details around the enacted plastic packaging decree, and now we must envision that scenario could be further complicated by labeling requirements, a potential PFAS ban, and eco-design requirements.
Second, the PFAS part stands out. Brazil for now is the only country in Latin America we are aware of with a US- or EU-style framework PFAS bill wending its way through Congress. (See earlier editions for coverage at www.ambientelegal.com/blog) Now, we are seeing how PFAS might be tackled through more narrow scope bills yet still result in bans or limits on products – or packaging – containing the substance.
Link to Bill:
https://www.camara.leg.br/proposicoesWeb/fichadetramitacao?idProposicao=2487402
A Rose in Not a Rose: Mexico’s Guide to Supplements
As readers know, we recognize that Gertrude Stein’s famous line – A Rose is a Rose – does not hold water in the world of product classification. A rose in one country could be a daisy in another. Proper product classification drives everything from tariff codes and taxes to permits and registrations. It is an art that requires attention to detail and deep knowledge of national or even state-level regulations. Mexico’s COFEPRIS just did us all a favor by releasing a guide to product classification of dietary supplements under national law.
Although the agency calls these ‘non-regulatory’ guides because they don’t have binding legal impact, they are priceless for the clearest articulation yet of how COFEPRIS handles the truly arcane patchwork of rules governing this growing category.
The Core Test
The guide structures classification around four sequential checklists, each tied to a different legal instrument: the General Health Law, the Health Products and Services Control Regulation, the Food Additives Agreement, and the Permitted/Prohibited Plants Agreement for teas and edible oils. A product must pass every checklist to qualify as a supplement — failing any one is enough to disqualify it, and the guide instructs users to stop evaluating at that point.
Why It Matters
For companies marketing supplements, herbal products, or functional foods in Mexico, this guide gives the clearest public signal yet of COFEPRIS’s classification logic. It is useful both for new product development and for auditing existing portfolios against enforcement risk.
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Tracking Brazil’s new chemical management law? Visit www.BrazilREACH.com for 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.com to talk about how we can help your business succeed in Latin America.y requirements?
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