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In brief

Federal decree No. 10.936/2022, which regulates the National Solid Waste Policy, was published on 13 January 2022, revoking the previous regulation established by federal decree No. 7.404/2010 and federal decree No. 9.177/2017, which dealt with isonomy in reverse logistics as well as other provisions.

More details

The new regulation institutes the Nacional Reverse Logistics Program, integrating the National Information System on Solid Waste Management (“Sinir“) and the National Solid Waste Plan (“Planares“).

This program will be the instrument for coordinating and integrating reverse logistics systems and aims to: (i) optimize the implementation and operationalization of the physical and logistics infrastructure; (ii) provide scale gains; and (iii) enable synergy between systems.

The reverse logistics systems must be, within 180 days of the publication of this decree, integrated into Sinir. Also, for the purpose of inspecting these systems, the waste transport manifest, which is a self-declaratory document issued by Sinir and valid in the national territory, was established.

In addition to information on waste transport, reverse logistics systems must include the following other basic requirements: the location of voluntary delivery points; the consolidation points; and the results obtained, considering the established goals and any others requested by the Ministry of the Environment.

Also, reverse logistics systems, through sectoral agreements, regulations issued by the government or terms of commitment, shall be extended to products sold in plastic, metallic or glass packaging, as well as other products and packaging, primarily considering the degree and extent of the impact of the waste generated on public health and the environment.

Despite the revocation of the previous decree dealing with equality between those responsible for reverse logistics (whether signatories or not to a sectoral agreement or term of commitment), a specific subsection for this topic was provided in the new regulation.

According to information from the Ministry of the Environment, the new regulation aims to bring clearer and more effective measures to comply with the norm.

The public consultation for sectoral agreements and regulations, being formally standardized, also underwent changes.

In practical terms, the decree did not bring significant changes but reinforces the position that the government will continue to focus its action on urban policies, notably on reverse logistics and mass recovery of waste, which is one of the priorities of current management.

Our Environment, Consumer and Sustainability Team is available to provide further clarification on the subject.

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


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.


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.


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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