Brazilian Legislative Draft on Industrial Chemicals

Brazil does not currently have a Reach-like regulation of new chemical substance notification requirements for industrial chemicals. While Brazil is developing its own national substance inventory, the following is a summary of its efforts to create one:

Brazil has specific regulations for pharmaceuticals, cosmetics, pesticides, sanitizing products and explosives, but as yet there are no regulations that apply for industrial chemicals.

In October 2018 Brazil started to create its substance inventory and new chemical management policy. The National Chemicals Safety Commission (Comitê Nacional Sobre Segurança Química, or CONASQ), along with the Ministry of Environment (Ministério do Meio Ambiente, or MME), published a Preliminary Bill for the Inventory, Evaluation, and Control of Chemical Substances.

The draft provisions are set on the creation of an existing national chemical substance inventory and the evaluation and control of chemical substances. The draft also makes GHS mandatory for industrial chemicals in the workplace.

The draft law mainly applies to an amount greater than or equal to 1 ton per year (>=1t/y) of industrial chemical substances. According to article 3 of the draft, the following chemical substances are out of scope.

  • Radioactive substances
  • Substances in development or solely for research
  • Non-isolated intermediates
  • Narcotic and psychotropic substances
  • Pharmaceuticals
  • Agrochemicals
  • Cosmetics and personal hygiene products
  • Food and food additives
  • National Inventory of Chemical Substances

Articles  6 and 7 of the legislative draft requires producers or importers of industrial chemical substances, including substances in mixtures, in an amount equal to or greater than 1 ton per year (>=1t/y) based on three years’ average, to submit the following information to the National Register of Chemical Substances maintained by CONASQ.  All substances gathered will be used to build the National Inventory of Chemical Substances in Brazil.

The following is also required:

Company identification of producer or importer;
Substance identity such as CAS name or IUPAC name and CAS number if available;
Quantity produced or imported per year;
Recommended uses;
GHS classification

The expected deadline to submit the above will be three (3) years from the availability of a substance.

New Substance Registration

Once the existing national chemical substance inventory has been finalized, chemical substances which are not listed will be regarded as new chemical substances.

Manufacturers and importers of greater than or equal to 1 ton (>=1t/y) per year of new chemical substances need to register those new substances by submitting additional studies and risk assessment report. Data requirements will increase with tonnage bands.

Certain existing chemical substances on the inventory will be selected for Evaluation

New substances and certain existing industrial chemicals on the inventory will be selected for hazard evaluation by an Industrial Chemicals Assessment Technical Committee if they meet the following criteria: Persistent, bio-accumulative or toxic to the environment; or Carcinogenic, mutagenic or toxic to reproduction; or Endocrine disruptors, based on scientific evidence; There are relevant potential exposure to humans and the environment; Controlled by international treaties or conventions of which Brazil is a member or signatory.

Note:Industrial chemical substances which do not fulfill one or more of the criteria above but may give rise to a level of equivalent concern may also be subject to evaluation. Producers and importers of greater than or equal to 1 ton per year of (>=1t/y) of industrial chemicals subject to evaluation will be required to submit certain information, studies, and safety data sheets to CONASQ to support risk assessment. Depending on the results of risk assessment, CONASQ may prohibit or restrict the production, import, trade or use of certain chemical substances. For additional information, visit:

Brazil is planning a national policy on industrial chemicals. The country intends to conclude the draft by the end of the year, and then it will be presented to the National Congress.

The proposed law, which includes a proposal to create a chemicals inventory, will list the obligations, mechanisms and institutional arrangements to meet the policy’s goals. These will include establishing a national chemicals inventory using information in official databases, such as those used in the EU and Canada and the UN Globally Harmonized System (GHS) of classification and labeling for classifying chemicals in its inventory.

A timeline for implementing Brazil’s plans has not yet been disclosed.

For additional information, please see:

Throughout 2019 SILLAC thanks HAZCOM Warriors

Get to know the Hazcom Warrior Program

The Wounded Warrior Project contributes to chemical management compliance.


Who are HAZCOM Warriors?

The HAZCOM Warriors Program is comprised of injured veterans and their caregivers. The Program includes men and women who, while healing from injuries received during deployments and missions, specifically healing from post-traumatic stress disorder (PTSD), traumatic brain injury (TBI), or other physical injuries, have approached a way to continue their service through chemical management compliance and implementation. The program allows the HAZCOM Warriors to become experts on exposure risks with a thorough understanding of what employers can do to help ensure workplace safety.

In 2018 SILLAC launched its SDS Authoring, GHS Management, and other Chemical Management compliance services and appreciates the work that HAZCOM Warriors have contributed to this year’s efforts.  SILLAC HAZCOM Warrior consulting model is a perfect fit for many nonprofits and small businesses who might otherwise be faced with either non-compliance or product deletion.

If you would like to find out more about the HAZCOM Warrior Program please contact us at


SILLAC – RegVine to Boost Chemical Management Compliance

For Release

Partnership to benefit Latin American and Caribbean Industry

Annapolis, MD— May 23, 2018— Specialists in International Law on Latin America and the Caribbean, S.C. – SILLAC announced the immediate availability of SILLAC Safety Data Sheet Management Plan, which includes SDS Authoring, Management, Distribution, Hazard Communication, and Chemicals Regulatory Consulting which will boost Chemical Management Compliance in Latin America and The Caribbean.

This is an empowering move because it allows regional and international industries to comply in a cost-effective manner with national and international laws, regulations, and standards, including the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

Through SILLAC, all industries in Mexico, Central America, South America and the Caribbean are served and granted access to SILLAC comprehensive plans for Safety Data Sheets that include Authoring, Management, and Distribution at a sensible cost. In this way, mid to large sized companies and businesses can economically comply with jurisdictional mandatory provisions governing regional and international Environmental, Health & Safety (EH&S) and GHS.  

“Today, more than ever, it pleases me to repeat our first mission statement—To let our clients know what they must do to be in compliance with the regulatory framework of Latin America and the Caribbean. I am eager to serve all businesses while helping them achieve compliance with the applicable regulatory framework,” said R. Leticia Cuevas, Chief Executive Director at Specialists in International Law on Latin America and the Caribbean, S.C.- SILLAC in Annapolis, Maryland.


Positive Customer Impact

SILLAC has begun to contact potential customers who have made inquiries on Safety Data Sheets (SDS) authoring, labeling, management and distribution of their products manufactured in Peru, Colombia, and Mexico. The SILLAC Safety Data Sheet Management Plan, which includes SDS Authoring, Management, Distribution, Hazard Communication, and Chemicals Regulatory Consulting.will enable such businesses to manage their raw materials and chemicals with best business practices and to export their products globally without the fear of expired or incorrect SDS or labeling. In today’s regulatory landscape, there are very high costs to non-compliance and liability, business leaders must take an active role to significantly reduce these risks.

SILLAC Background

SILLAC has grown considerably since it was founded in 2000 when its goals were to analyze sociolegal issues; propose solutions for non-compliance and omissions in laws or the lack of legislative measures; and strive to find ways of helping societies and governments. SILLAC inaugurated the firm with an International Law Conference on “The Future of Alternate Dispute Resolution in International Trade in Latin America and the Caribbean,” held in Mexico City on September 8, 2000. Among the invited speakers was Carlos Loperena R., a renowned expert from the prestigious school of law, Escuela Libre de Derecho, who presented a “Panorama of Trade Arbitration in Mexico” (Panorama del Arbitraje Comercial en Mexico).

Today, R. Leticia Cuevas, Chief Executive Director, leads Chemical Management Compliance and together with seven international and environmental lawyers, who have been part of SILLAC since 2014, provide the most current, accurate data for clients who depend on precise regional information.

You may find information on Chemical Management Compliance, the SILLAC Safety Data Sheet Management Plan, which includes SDS Authoring, Management, and Distribution at



Specialists in International Law on Latin America and the Caribbean, S.C.- SILLAC  are either registered trademarks or trademarks of Specialists in International Law on Latin America and the Caribbean, S.C.- SILLAC in the United States and/or other countries.

The names of actual companies and products mentioned herein may be the trademarks of their respective owners.

For more information, press only:

R. Leticia Cuevas

Mexico City to Welcome Air France Airbus in 2016 while Southwest Flights Already in Progress

Mexico City to welcome Air France AirBus A380 inaugural flight on January 12, 2016. The flight is scheduled to land in Mexico’s Benito Juarez International Airport, to start three times weekly, and after March on a daily basis. The Secretariat of Communications and Transportation began work to prepare the airport facility and runway for the large aircraft, which will carry 560 passengers from Paris to Mexico City. However, this is not the first time that Mexico greets the Airbus flight A380: the first flight landed in Cancun in 2013.

Another major flight trend is the Southwest non-stop flights from Houston to Mexico City, Cancun, Los Cabos and Puerto Vallarta. The Southwest flight from Cancun was landed in Houston Hobby last week, in Southwest’s five gate terminal that was recently inaugurated after construction operations since 2013.

Southwest expects to transport approximately four thousand passengers per month from Houston to Mexico City on non-stop flights.