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On May 13, the Ministry of the Environment and Climate Change (MMA) launched a public consultation on the draft Decree intended to implement Law No. 15.022 of November 13, 2020 on the official page Participa + Brasil. The public consultation, which was open to interested parties on the government’s platform was cancelled a few days later.

The same proposal was then notified to the World Trade Organization (WTO) through a WTO notification. Only WTO Members countries can make comments on the draft, meaning that the general public would not be able to do it. The only plausible way to submit comments from companies and public entities is through national WTO TBT Enquiry Points.

The draft submitted to the WTO remains unchanged from the one published on the page Participa + Brasil. There is no official timeline for the final regulation to be published. Stakeholders are advised to monitor forthcoming developments closely, particularly any updates regarding the implementation timeline and reporting obligations.

From 4 July 2025, compliance with GHS Revision 7 will be mandatory in Brazil. This follows the publication of the updated ABNT NBR 14725 standard on 3 July 2023, which brings Brazil’s classification, labelling, and safety data sheet (SDS) requirements into line with the seventh revised edition of the UN Globally Harmonized System (GHS 7). The two-year transition period is now coming to an end, meaning that all affected companies must fully implement the updated hazard communication rules.

The Brazilian Association of Technical Standards (ABNT) released the update on 3 July 2023, marking the most substantial update to the ABNT NBR14725 standard in over a decade. It introduces significant changes that brings Brazil's regulations closer in line with international standards, particularly the GHS. 

Key Changes and Enhancements

Structural Reorganization: One of the most notable changes is the restructuring of the standard's layout. Previously divided into four parts, the new version consolidates all the content into a single, more extensive and comprehensive section, making it easier for users to navigate and understand the requirements. 

Alignment with GHS 7: The updated ABNT NBR 14725 Standard is based on the seventh revision of the GHS Purple Book. By adopting this GHS version, Brazil's regulations now closely align with international standards, promoting consistency and harmonization in chemical classification and labelling practices. 

New Hazard Classes: Two new hazard classes have been introduced: 

• Desensitized Explosives which address substances that have been treated to reduce their explosive properties.

• Ozone Depleting Substances which focus on chemicals that pose a risk to the ozone layer. 

Modified Labelling Elements: The labelling requirements have been updated, with changes to hazard statements (H phrases) and precautionary statements (P phrases). New H and P phrases have been added to provide more specific information about potential hazards and necessary precautions. Existing phrases have also been modified to enhance clarity and accuracy. 

Communication of Hazards for Small Packaging: The updated standard introduces new rules for labelling small packaging. These regulations ensure that even the smallest containers carry essential information about the hazardous nature of their contents, thereby enhancing safety measures and risk awareness. 

Revised Safety Data Sheet (SDS): The standard introduces a change in terminology for Safety Data Sheets (SDS). Formerly known as Material Safety Data Sheets (MSDS), they will now be referred to as SDS, thus aligning the Brazilian naming convention with international standards. The content and structure of SDSs remain largely unchanged, maintaining the requirement of 16 sections, each providing crucial information about chemical properties, handling, and safety measures. 

Impact and Compliance

Mandatory Updates: All companies are required to update their existing Safety Data Sheets (SDSs) to comply with the new standard. The change in document nomenclature necessitates revisions to ensure consistency and alignment with the updated requirements. Additionally, labels may need to be revised to reflect the modified hazard statements and precautionary phrases. 

Time and Cost Implications: Achieving compliance with the updated regulations may require additional investment in resources and expertise. Companies may need to allocate time and funds for training employees, acquiring specialized technologies, and reviewing and updating their SDSs and labels. The scale of these tasks will depend on the company’s size and the number of products in its portfolio. 

Revised Classification: Due to changes in concentration limits, some products that were previously classified may no longer require classification under the updated standard. However, it is important to note that this change does not apply universally, except for the inclusion of the new hazard class "Desensitized Explosives." 

Companies handling chemicals in Brazil should now complete their compliance preparations. All required updates to SDSs and labels must be finalized before 4 July 2025, when the revised standard becomes legally mandatory.

Access to the NBR 14725 standard via the ABNT Catalog website, through the link: ABNT Catálogo (abntcatalogo.com.br)