| Who is obligated and thresholds | Decreto nº 10.936/2022 keeps specific rules on equal treatment of operators, whether or not they signed a sector agreement or commitment term, in reverse logistics. |
|---|---|
| Registration (steps and registry) | Reverse logistics systems must be integrated into Sinir under Decreto nº 10.936/2022. In Brazil, an importer acting on behalf of or to the order of a third party must have a prior contract with the buyer, and the contract and any later amendments must be uploaded to a dossier on the Portal Único before the import declaration is registered. |
| Reporting obligations and deadlines | The waste transport manifest is a self-declared document valid nationwide, issued through Sinir and used for environmental inspection of reverse logistics systems (Decreto nº 10.936/2022, Art. 9 §1). Reverse logistics systems under Decreto nº 10.936/2022 must include information on the location of voluntary delivery points, consolidation points and results obtained against the established goals. For household medicines, the annual performance report goes to the Ministry of the Environment by 31 March each year, consolidating data for 1 January to 31 December of the previous year (Decreto nº 10.388/2020, Art. 19 §§2–3). |
| PROs and compliance schemes | Reverse logistics systems may be established through sector agreements, commitment terms or public regulations. For household medicines, contracting or setting up a managing entity is optional, and joining one is voluntary (Decreto nº 10.388/2020, Art. 17 and §1). The Reciclus Programme, started in November 2014, rests on the sector agreement for reverse logistics of fluorescent, sodium-vapour, mercury and mixed-light lamps. |
| Penalties | Failure to comply with reverse logistics obligations can lead to penalties under the Environmental Crimes Law (Law No. 9.605/98). The infractions list includes failing to meet an obligation in a reverse logistics system (item XII) and failing to keep up to date and make available complete information on the system's actions (item XV). Consumers who breach their reverse logistics duties face a warning and, on repeat, a fine of R$ 50.00 to R$ 500.00. |
Decree No. 10.936/2022 regulates the National Solid Waste Policy and provides the general legal framework for reverse logistics systems, which manufacturers, importers, distributors and traders must structure, implement and operate.
Under Decree No. 12.688/2025 on plastic packaging, the responsibility of manufacturers, importers, distributors and retailers is determined in proportion to the mass of plastic each has placed on the market, in line with minimum regional and national targets.
For electrical and electronic products, the import declaration must state who is responsible for structuring, implementing and operating the reverse logistics system (Decree 10.240/2020).
Art. 7 of Decreto nº 10.936/2022 states that Art. 32 of Lei nº 12.305/2010 (the packaging provision) does not apply to packaging of products destined for export. In that case the manufacturer meets the importing country's requirements.
Under Decreto nº 10.388/2020, manufacturers and importers of household medicines bear the cost of the environmentally adequate final disposal of expired or unused medicines returned by consumers.
Under Decree 10.936/2022, reverse logistics systems may be extended, through sectoral agreements, regulations issued by the government or terms of commitment, to products sold in plastic, metal or glass packaging and other products and packaging.
For plastic packaging, Decree 12.688/2025 sets the responsibility of manufacturers, importers, distributors and retailers in proportion to the mass of plastic each places on the market.
The passages describe no stand-alone registration procedure for reverse logistics. The closest requirement is that reverse logistics systems be integrated into Sinir, the national solid waste information system.
Reverse logistics systems must be integrated into Sinir under Decree 10.936/2022; the Ministry of the Environment may request further information.
Decree 10.936/2022 establishes the National Reverse Logistics Program, integrated with Sinir and Planares, as an instrument to coordinate and integrate reverse logistics systems.
Cooperatives and associations of waste pickers must be registered and qualified in Sinir under the procedures of Ordinance GM/MMA No. 1,018/2024.
Under Decree 10.388/2020, producers and importers must transport expired or unused household medicines from the secondary storage point to treatment and final disposal, and an annual report on the system's results must be presented to the Ministry of the Environment.
Decree 10.936/2022 created the waste transport manifest (MTR), a self-declared document issued through Sinir and valid nationwide, used for environmental inspection of reverse logistics systems.
For household medicines (Decree 10.388/2020), the performance monitoring group must present an annual report covering the amount of medicines received by the system, the number of municipalities served, the fixed collection points installed and the weight in kilograms of medicines returned by consumers.
Under Decree 10.388/2020, the performance monitoring group must prepare a yearly report on the outcomes of the household medicines reverse logistics system and deliver it to the Ministry of the Environment.
Under Decree 10.936/2022, manufacturers, importers, distributors and retailers of the products covered must structure, implement and operate reverse logistics systems.
Under Decree 10.936/2022, reverse logistics systems are implemented through sectoral agreements, regulations issued by the public authorities, or terms of commitment.
The Reciclus Programme started in November 2014. It rests on the sectoral agreement for reverse logistics of fluorescent, sodium-vapour, mercury and mixed-light lamps.
The Union, through the Ministry of the Environment (MMA), Abilux, Abilumi and 24 lamp manufacturers, importers, retailers and distributors signed the lamp sectoral agreement behind Reciclus.
For household medicines, Decree 10.388/2020 allows manufacturers, importers, distributors and retailers to hire or create a managing entity to run the reverse logistics system for expired or unused medicines and their packaging; adhesion to such entities is voluntary.
Pharmaceutical sector companies, including manufacturers, distributors, importers, pharmacies and drugstores, may act through an entity with its own legal personality to administer the implementation and operation of medicines reverse logistics.
Under Decree 10.388/2020, the production sector must deliver a yearly report on the outcomes of the medicines reverse logistics system to the Ministry of the Environment.
Failure to meet reverse logistics obligations may lead to penalties under environmental legislation, such as the Environmental Crimes Law (Law 9.605/98).
Manufacturers, importers, distributors and retailers of products covered by reverse logistics must implement reverse logistics systems under Law 12.305/2010 and Decree 10.936/2022.
The same list includes failing to keep up to date, and failing to make available to the competent municipal body and other authorities, complete information on the actions of the reverse logistics system for which the company is responsible (item XV).
Consumers who breach their obligations under the reverse logistics and selective collection systems face a warning (advertência). If they repeat the breach, a fine of R$ 50.00 to R$ 500.00 may be imposed.
The repeat-offence fine for consumers may be converted into services that preserve, improve and restore environmental quality.
Importing hazardous solid waste and tailings, or waste whose characteristics harm the environment, public or animal health or plant health, carries a fine of R$ 500.00 to R$ 10,000,000.00 (Art. 71-A). This applies even if the import is for treatment, refurbishment, reuse or recovery.
In São Paulo State, any act or omission that breaches Law 12.300/2006 or Decree 54.645/2009 is an infraction (Art. 21).
Under Art. 22 of São Paulo Decree 54.645/2009, infractions are punishable by: warning; fine; temporary or permanent interdiction; embargo; demolition; suspension of financing and tax benefits; and temporary or permanent seizure or collection. The environmental body applies these following the procedures of Decree 8.468/1976.
São Paulo Decree 54.645/2009 (Art. 23) sets a fine of 100 to 3,000 UFESP for failing to submit the solid waste plans required by Arts. 10 to 12, and for failing to file, or filing incompletely or incorrectly, the Annual Declaratory System form by the deadline in Art. 14, § 1.
Decree 10,936/2022 requires manufacturers and importers, among others, to structure, implement and operate reverse logistics systems for the products and packaging they place on the market.
For plastic packaging, Decree 12,688/2025 makes the responsibility of manufacturers, importers, distributors and retailers proportional to the mass of plastic each places on the market, measured against the decree's minimum targets.
Reverse logistics for agrochemical packaging follows specific legislation, which assigns responsibilities along the supply chain, including importers.
Decree 10,936/2022 reinforces equitable supervision of the fulfilment of reverse logistics obligations.
Yes. Operators that have not signed a sector agreement or commitment term with the Union must still structure and implement reverse logistics systems. Operators that have not signed a sectoral agreement or commitment term must still structure and implement reverse logistics systems.
Where the import is made under the 'por conta e ordem' or 'por encomenda' modalities and the buyer or orderer is the real recipient, that buyer or orderer must structure, implement and operate the system (Decreto nº 10.936/2022, Art. 14 §4). Where the import is made by a third party under the 'por conta e ordem' or 'por encomenda' modalities, the buyer or orderer who is the real recipient is responsible for the reverse logistics system, as established in specific regulations (Decreto nº 10.936/2022, Art. 14 §4). The third-party importer must include in the import declaration the information on who is responsible for structuring, implementing and operating the importer's reverse logistics system, as defined by contract (Decreto nº 10.936/2022, Art. 14 §7).
Reverse logistics for agrochemicals follows specific legislation. For imported pesticides, the importing company is responsible for collecting and disposing of the empty packaging; users must return empty packaging, lids and residues to the point of purchase or a collection point. Where the imported product undergoes industrial processing or repackaging, the registering body decides who is responsible.
They must record in the waste transport manifest the mass in kilograms received at secondary storage and sent for treatment and final disposal.
Decree 10.936/2022 created the waste transport manifest, a self-declared document issued through Sinir, to support inspection of reverse logistics systems.
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This guide is for general information only and does not constitute legal advice. It summarises the official legal texts listed above as of the "last verified" date; obligations may have changed since. Check the official sources or consult a qualified professional before making compliance decisions.
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