Take-Back Requirements: MMA issues guidance for 2025 reports

In brief

The Ministry of the Environment and Climate Change (MMA, in Portuguese) issued Notice No. 001/2026, providing guidance on the submission of the 2025 take‑back requirements results report. The Notice consolidates prior guidance and sets out submission deadlines, reporting format, content requirements, eligibility rules for managing entities and result verifiers, applicable targets, and review procedures.

Recommended actions

In light of the recent guidance, managing entities and companies should ensure that the information reported complies with the MMA’s updated requirements, so that the annual reports to be submitted by 30 July 2026 meet the applicable format, documentation requirements, and the MMA’s review procedures.

In more detail

• General aspects on content and format

In the Notice, the MMA reiterates that reports must be submitted through the SEI/MMA system and comply with the specific rules applicable to each take‑back system, as well as with Federal Decree No. 11,413/2023 and the relevant ordinances. The Notice also highlights the need to use duly authorized result verifiers, to evidence take‑back activities through invoices and Certificates of Final Disposal (CDF, in Portuguese) issued via the MTR/SINIR system, and to comply with the requirements applicable to the participation of waste picker organizations, including registration, authorization, and contractual arrangements.

• Applicable targets

For 2025, the Notice distinguishes the recovery targets applicable to packaging in general and to glass packaging. For packaging in general, a national recovery target of 31.25% applies, subject to regional targets. For glass packaging, the specific recycling and recycled content targets set forth under Decree No. 11,300/2022 apply, also with regional breakdowns.

• Report review procedures

The MMA states that results reports will be subject to up to two administrative reviews. The first review may identify the need for adjustments or additional information, while the second review will be conclusive, resulting in approval, approval with reservations, or rejection of the report. The Notice also differentiates review procedures according to the type of take‑back system and the relevant supply chain, including specific rules for supply chains whose reports are reviewed through the Performance and Monitoring Group (Grupo de Acompanhamento e Performance – GAP, in Portuguese).