Brazil Controlled Chemicals Instruction Updates Licensing And Reporting

Brazil controlled chemicals instruction replaces INs 166/2020 and 211/2021. It implements control, SIPROQUIM, inspection and penalty procedures for chemicals listed under Portaria MJSP 204/2022, rather than creating controls for every chemical product.

Brazil Controlled Chemicals Instruction And SIPROQUIM

Persons and businesses conducting controlled activities must use SIPROQUIM to apply for registration, an operating licence, special authorisation and prior import, export or re-export authorisation documents, and to submit Monthly Control Maps. The Brazil controlled chemicals instruction requires applications for relevant control documents through SIPROQUIM with the evidence required by Portaria MJSP 204/2022. Detailed requirements for registration, licensing, amendments, renewals, cancellations and authorisations remain in that Portaria.

Businesses should confirm that each controlled product and activity is active in the relevant registration or authorisation and that every establishment has the certificates required under Portaria MJSP 204/2022, taking account of concentration, quantity and exemption rules. Changes to registered or constitutional details, locations, activities, controlled products or representatives may require prior or timely updates under Portaria MJSP 204/2022; certain cadastral changes must be communicated within 30 days. Where mandatory administrative treatment applies, importers, exporters and re-exporters must obtain prior Federal Police authorisation. Shipment may occur only after approval.

Unauthorised cross-border movements can trigger seizure and administrative penalties. Under IN 338, the calculated fine may reach BRL350,000 before applicable increases, but that is not the final legal ceiling. Any increased amount remains capped at the statutory maximum of BRL1,064,100 under Law 10.357/2001, making document accuracy and timing significant.

Monthly Control Maps And Supporting Records

Persons and businesses subject to control must report through SIPROQUIM all activities conducted with controlled chemicals during the previous month by the fifteenth day of the following month. A Monthly Control Map is still required where no controlled-product movement occurred. Maps and supporting records should reconcile every applicable reportable operation.

Practical Compliance Checks

Businesses should map products against Portaria MJSP 204/2022 lists, concentrations, quantities and exemptions; verify each establishment, activity and licence; test Monthly Control Maps; and require counterparties to provide accurate registration and shipment data.

Importers should build authorisation lead times into purchasing schedules. Distributors and carriers should train staff to recognise controlled products and escalate discrepancies before dispatch. Under Law 10.357/2001 and Portaria MJSP 204/2022, documents supporting reported operations, including Control Maps, invoices, manifests and other fiscal documents, must be retained for five years and produced to the Federal Police when requested. IN 338 governs how Monthly Control Map data remain available through SIPROQUIM.

The Brazil controlled chemicals instruction is in force. A gap assessment can reduce shipment delays, reporting errors and enforcement exposure.