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In brief

On 6 October 2021, the CETESB (environmental agency of the state of São Paulo) published Board Decision No. 105/2021/P/C of 29 September 2021, which altered Board Decision No. 114/2019/P/C, establishing the “procedure for the incorporation of reverse logistics in the scope of environmental licensing”.


More details

The new board decision changed the deadline for the beginning of the obligation to incorporate reverse logistics in environmental licensing (in cases of obtaining and renewing), extending it to until 31 March 2022.

The extension will be applied when the enterprises are classified, simultaneously, in item 2.4.2 and items c, d, e and f of Board Decision No. 114/2019/P/C and in the categories of individual microentrepreneurs, microenterprises or small businesses whose built area is less than 500 square meters.

The projects covered by the items mentioned in item 2.4.2 are as follows:

(i) Food products, for the reverse logistics of their packaging

(ii) Drinks, for the reverse logistics of their packaging

(iii) Toiletries, perfumes and cosmetics, for the reverse logistics of their packaging

(iv) Cleaning and related products, for the reverse logistics of their packaging

The board decision applies to all ongoing administrative procedures.

Our Environment, Consumer and Sustainability team is available to provide further clarification on this subject.

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Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

Author

Renata Campetti Amaral joined the firm in 2002 and became a partner in 2013. As a Senior Partner, she is the Head of the Environment, Climate Change and Sustainability practice group in Brazil. She coordinates the sustainability initiatives conducted by the office. In the environmental and sustainability area, she coordinates several of the biggest cases of contamination and environmental regularization in the country. Renata provides advice on negotiations with authorities; judicial and administrative litigation; review of environmental aspects of financial institutions and operations; drafting and negotiation of environmental provisions in contracts and other commercial operations. She has vast experience in dealing with environmental management, legal audit and other organizational practices; regulatory and institutional analysis and environmental control; negotiation and implementation of environmental remediation plans; environmental licensing; legal aspects of biodiversity protection; environmental crisis management; development of preventive policies and strategies for companies; negotiation and drafting of contracts for the purchase and sale of carbon credits. In matters related to Consumer Law, she conducts analysis of aspects of Consumer Law in contracts and commercial transactions, judicial and administrative litigations; works on the negotiated solution of matters related to Consumer Law; celebration of agreements with competent authorities; analysis, planning and supervision of legal aspects of recalls; marketing strategies and campaigns; aspects of Consumer Law in electronic commerce and in matters related to information technology and on the development of preventive policies and strategies for companies. Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

Author

Giovani Bruno Tomasoni joined the Firm in 2008 and became partner of the Environment, Consumer and Sustainability practice group in 2020. He practices with focus on Environment, Public Law, Energy, Forestry, and helps clients in the internalization of concepts such as sustainability, ESG, circular economy, environmental compliance, among others. Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

Author

Livia Lupinacci is an Associate in Trench, Rossi e Watanabe Advogados Sao Paulo office. *Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

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