Brazil: Sisrev-BR centralizes take-back obligations

In brief

GM/MMA Ordinance No. 1,778/2026, published on September 18, 2026, established the National Take-Back System (Sisrev-BR), a module integrated with Sinir designed for reporting results, consolidation, monitoring, traceability, and supporting the oversight of take-back systems nationwide. Managing entities and companies operating collective or individual models must register their systems and submit annual reports through the platform. The Ordinance also regulates the certification of integrated electronic platforms and the rules for the traceability of recycled content.

Recommended actions

1. Map out responsibilities: Identify the model adopted (collective or individual) and the parties responsible for registration and reporting via Sisrev-BR.
2. Prepare the registration: Organize the information from the Take-Back System for registration between January 1 and May 31 of each year and review any updates prior to submitting the annual report.
3. Structure the report: Consolidate data and supporting documents from the previous fiscal year for submission by July 30, including information on actions taken and compliance with results, broken down by state.
4. Assess recycled content: Enter data from the previous fiscal year into the specific platform to be created for tracking recycled content by April 30 and review proof of raw materials, including the required certifications from importers.
5. Review data governance: assess controls related to confidentiality, data protection, and the handling of commercially sensitive information, considering that the minimum content of the annual report may be made public.

More details

• Scope and operation

The new Sisrev-BR system covers collective models, operated by management entities, and individual models, operated by manufacturers, importers, distributors, or retailers. It will also function as an interoperability environment among result verifiers, with a single database and standardized information exchange. Furthermore, in the event of conflicting invoices, verifiers will be notified, and if no agreement is reached on the assignment of the invoice within 30 days, the invoice will be disregarded.

The reports, documents, and information provided by take-back systems will be accessible to the federal government, the states, the Federal District, municipalities, and oversight and control agencies. States with their own reporting systems may choose to receive data through Sisrev-BR, though participation is not mandatory. Furthermore, in the event of a conflict between state and national targets, reporting must comply with the more restrictive target.

• Registrations and reports

1. Registration: must be completed between January 1 and May 31 of each year; it becomes valid upon approval by the MMA and must be updated every three years or prior to the submission of the annual report. The MMA’s review will take place within ninety days of receipt, extendable upon justification, subject to due diligence. If no response is received by the deadline, the system will be considered valid until proven otherwise. In the event of non-approval, an administrative appeal may be filed, pursuant to Federal Law No. 9,784/1999 (the law governing administrative proceedings within the Federal Public Administration).
2. Annual report: must be submitted by July 30, containing consolidated data from January 1 through December 31 of the previous year and supporting documents, in accordance with the Manual to be published on Sinir. The minimum content of the report constitutes “environmental information”; therefore, claims of commercial, industrial, or financial confidentiality will not be accepted, although exceptions may be granted upon express and substantiated justification, at the discretion of the MMA. The review follows the same ninety-day deadline, with the possibility of an administrative appeal in the event of rejection.
3. Imports: In transactions carried out on behalf of or at the request of a third party, or on consignment, the purchaser or the party placing the order will be responsible for complying with the obligations set forth in the new Ordinance.

• Integrated platforms

Sisrev-BR may also incorporate electronic platforms developed by agencies and entities of the Federal Public Administration. To this end, interested parties must complete the information requested by the MMA and submit the specified documentation. During the first year of the regulation’s effective period, applications will be accepted for up to 60 days after publication. The platform’s certification will be valid for up to three years and will be preceded by a technical opinion specifying the service, type of product, or packaging to which it refers, taking into account the type of material.

• Recycled content

The recycled content rate will be verified preferably through a traceability platform authorized by the MMA. The platform must be integrated with Sisrev-BR within ninety days of the system becoming operational. Companies must enter, by April 30 of each year, data regarding the recycled content from the previous fiscal year, which will be incorporated into the annual results report.

The Ordinance further establishes that the mass of imported recycled waste will not be counted toward the calculation of domestic manufacturers’ targets, and no credits or credit certificates related to the recycled content ratio will be accepted. The managing entity may adopt different rules for the financial contributions of domestic manufacturers and importers, based on objective, measurable, auditable, and transparent criteria.