BRAZIL → GERMANY / EUROPEAN UNION
Brazil plastic recovery and recycled content targets
Decree 12,688/2025 addresses recovery and post-consumer recycled material with implementation conditions.
Legal and market context
Recycled-content duties are packaging-specific and include exclusions for categories regulated separately, including relevant food packaging.
Required records and evidence
Verify company size, packaging resin, post-consumer material and sector before applying a percentage or deadline to each SKU.
Practical controlled workflow
Retain supplier, traceability and evidence documents. Organising records in EPRORA alone does not constitute statutory Brazilian submission.
32% recovery differs from 22% PCR content
For 2026, Annex I sets 32% national recovery and Annex II sets 22% incorporated recycled content. These are different indices. Article 34 specifies January 2026 for large companies and July 2026 for small and medium companies; document company size and coverage before applying the target.
Recycled-content exceptions require a regulatory basis
Article 33(3) addresses packaging regulated specifically, including food packaging. Corrected MMA Notice 002/2026 clarifies that sanitary restrictions need a regulatory basis; there is no blanket exemption for all food packaging. Separate mass subject and not subject to PCR and record the rules supporting restrictions. Guidance does not replace legislation.
Brazilian German EPR and DPP guides
Primary regulatory sources
Content reviewed: