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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. She is the head of the firm’s Climate Change, Environmental Law and Sustainability group in Brazil, and the leader of Ablfs McKfnzif’s global climate change group in Latin America. Is also the coordinator of the sustainability initiatives conducted by the office’s B-Green Committee. Renata assists the major players in the Brazilian market in Nature-bases Solution (NbS) projects, transaction of carbon credits, implementation of decarbonization strategies and carbon-related advocacy and regulatory matters. Renata leads several of the largest environmental and regularization cases in the country. She has extensive experience in sustainability matters, as well as in managing crises and negotiating with stakeholders. Advises on negotiating with authorities; judicial and administrative litigation; reviewing environmental aspects of institutions and financial operations; drafting environmental provisions in contracts and other commercial operations. Renata has extensive experience in dealing with environmental management, legal auditing 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 and acting in transactions related to various aspects of the energy transition.
*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.

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