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In brief

On 9 February 2024, the Minas Gerais State Secretariat for the Environment and Sustainable Development (SEMAD in Portuguese) published Copam Normative Decision No. 249/2024, which defined the guidelines for implementing, operating and monitoring the take-back requirement systems in the state.

More details

By establishing guidelines for operationalizing take-back systems, Copam Normative Decision No. 249/2024 made it mandatory for manufacturers, importers, distributors and traders to structure and implement take-back obligations for the products it specifies in the state of Minas Gerais.

The new regulation foresees take-back systems for the following products: (i) Household electronics and their packaging; (ii) Batteries; (iii) Automotive lead-acid batteries; (iv) Fluorescent, sodium vapor, mercury vapor and mixed light bulbs; (v) Lubricating oil packaging; (vi) Packaging in general; (vii) Household medicines for human use and their packaging; and (viii) Waste tires.

The obligations are aimed at manufacturers, importers, distributors and traders – whether or not they are based in the state – who must demonstrate that they have met the goals related to the take-back systems specified above. The obligations are imposed regardless the agents are subject or not to environmental licensing. The rules also apply to e-commerce traders.

The planned targets are similar to those set out in the National Solid Waste Plan (PLANARES in Portuguese), approved by Federal Decree No. 11,043/2022. For example, the take-back targets for general packaging to be fulfilled by 2025 are 31.25%.

All agents subject to take-back obligations in the state must register the take-back plans to which they are aligned to, whether in the individual or collective model, before 30 December 2024.

The first report demonstrating compliance with the targets and waste recovery must be submitted by 31 July 2026 and will refer to the products and packaging placed on the market in the base year of 2024, whose environmentally appropriate final disposal must take place in 2025.

Copam Normative Deliberation No. 249/2024 has already incorporated specific concepts from federal regulations, such as the new take-back credits for packaging in general (CCRLR, CERE and Future Mass Credit Certificate in Portuguese) – which can be traded between agents and used to demonstrate compliance with the targets imposed – and the determination for greater participation and inclusion of cooperatives, associations and waste collectors organizations in the take-back systems.

Unlike the model adopted in other Brazilian states, the regulation does not foresee a specific provision establishing the need to comply with take-back targets as a condition for issuing or renewing environmental permits.

Our Environment, Climate Change and Sustainability team has extensive experience in the subject and is available to discuss the impacts of the new regulation on companies’ day-to-day operations.

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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. 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.


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.


Manuela Demarche joined the Firm in 2017, and has been working with Environmental Law since 2010. She is currently a Senior Associate of the firm’s Environment, Sustainability and Climate Change practice group.
She has several years of experience in complex matters connected to environmental, sustainability and climate change, and her practice focus on a wide range of matters, particularly in connection to environmental liability, licensing proceedings, carbon and M&A transactions and cross-border disputes. During 2022, she did an attorney training program in the U.S. and has worked as a Legal Extern for the American Clean Power Association.
She regularly advises international and domestic clients in relevant cases, including preparing opinions, overseeing due diligences, drafting administrative and judicial claims for disputes arising from controversial environmental matters. Under her umbrella, she regularly deals with regularization (air pollution, effluents, solid waste, contaminated areas), circular economy, take-back schemes, extended producer responsibility, carbon markets, REDD+, biodiversity and crisis management.
Awards and Recognitions
Manuela Demarche is recognized for her work as an outstanding professional – “Associate-to-watch” – in Environmental Law in Brazil, by the publication Chambers and Partners. She was also mentioned by Análise Advocacia Mulher.
*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

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