Implementation Timeline of REACH Brazil (INSQ)

1. Timeline: From Initial Discussions to Mandatory Compliance

2. Planned Implementation Phases According to the Regulatory Decree

3. Other Important Definitions in the Draft

4. What Companies Can Do Now to Prepare

5. Conclusion

The approval of Law No. 15.022/2024, which establishes the National Chemical Substances Inventory (INSQ), represents a significant step for Brazil by creating a modern chemical management system inspired by REACH Brazil.

The new regulatory framework sets the foundations for the notification and control of chemical substances in the country, impacting manufacturers, importers, and distributors.

The information in this article is based on the preliminary draft of the Regulatory Decree, published in April 2025 by the Working Group of the National Chemical Safety Commission (CONASQ). It is a structured but unofficial version, subject to change until formally approved.

Below, we present the implementation timeline of REACH Brazil (INSQ), its phases, and what companies can already begin preparing.

Timeline: From Initial Discussions to Mandatory Compliance

Although the INSQ Law is recent, the topic has been discussed in Brazil for several years. The following timeline summarizes the key milestones.

REACH Brazil (INSQ) Timeline

• 2019–2023 – Early Discussions
  Debates between the federal government, private sector, professional entities, scientific community, and NGOs regarding the need for a national inventory of chemical substances.

• November 2024 – Approval of Law No. 15.022/2024
  The creation of the INSQ is officially established.

• December 2024 – Formation of the Regulatory Working Group
  CONASQ establishes the group responsible for drafting the regulatory decree.

• April 2025 – Publication of the Draft Decree
  The Working Group releases the preliminary version with operational guidelines for the INSQ.

• 2025–2026 – Regulatory Period
  During this phase, criteria, categories, exemptions, and responsibilities will be defined.
  The official electronic system will also be developed and tested, along with the publication of guides and supporting documents.

• From 2027 – Expected Start of Mandatory Notifications
  The draft does not specify an exact date, but establishes that mandatory reporting will only begin after:

  • completion of the electronic system

  • publication of operational procedures

  • availability of official guidelines
    
    

Planned Implementation Phases According to the Regulatory Decree

The draft organizes REACH Brazil (INSQ) into four pillars, which function as practical phases for companies.

Substance Registration

Manufacturers and importers must enter the following information into the Ministry of the Environment (MMA) electronic system:

• Chemical identity (IUPAC name, CAS, purity, relevant impurities)

• Annual manufactured or imported volume

• GHS classification and labeling

• Identified uses and exposure data

• Available physicochemical, toxicological, and ecotoxicological properties
  

Prioritization for Risk Assessment

After registration, substances will be prioritized based on:

• Toxicity, persistence, and bioaccumulation

• Environmental risk

• Annual volume

• Human or environmental exposure potential

A list of prioritized substances will be periodically updated.

Risk Assessment

Conducted by a Technical Committee and may require:

• Additional information

• Complementary studies

• More detailed exposure data

Risk Management Measures

Depending on assessment results, measures may include:

• Use restrictions

• Concentration limits

• Additional safety requirements

• Gradual substitution of critical substances

Management will involve agencies such as Ibama, Anvisa, and the Ministry of Labor.

Other Important Definitions in the Draft

Governance

The proposal includes:

• CONASQ providing strategic coordination

• A Technical Committee responsible for substance evaluation

• A Deliberative Committee overseeing management measures

Regulatory Fees

The Registration, Evaluation, and Inspection Fee will be proportional to:

• company size

• annual volume

• number of notified substances

Confidentiality

The draft allows confidentiality requests for:

• chemical identity

• critical impurities

• proprietary data and studies

Integration with ABNT NBR 14725:2023

With regard to integration with ABNT NBR 14725:2023, the decree reinforces the need for

• use of GHS classification

• consistency between INSQ data and SDS

• alignment between inventory, labeling, and hazard communication
  
  

What Companies Can Do Now to Prepare

Although mandatory compliance is not immediate, early preparation will be essential under REACH Brazil.

Organize the Substance Inventory

• Compile an updated list of substances and mixtures

• Record annual volumes

• Ensure SDS are compliant with NBR 14725:2023

• Review CAS, purity, and complete composition

Identify Data Gaps

It is essential to review:

• GHS classification

• Physicochemical properties

• Toxicological and ecotoxicological information

• Inconsistencies in supplier SDS

Coordinate with International Suppliers

Especially important for importers:

• Request updated SDS compliant with GHS and NBR 14725:2023

• Establish confidentiality agreements

• Obtain full composition whenever possible

Evaluate Digital Tools (such as eQgest)

Specialized software supports:

• automatic classification

• generation of NBR 14725:2023 SDS

• centralized regulatory data management
  
  

Conclusion

With the 2025 draft of the Regulatory Decree, Brazil advances toward implementing REACH Brazil (INSQ), establishing a modern system for chemical substance management.

Although mandatory compliance is expected for 2027, preparation time will be limited. Companies that organize their inventories, update SDS, and structure their data will be better positioned to meet INSQ requirements.

If your company needs support organizing inventories, updating SDS, or structuring data for the future REACH Brazil, eQgest offers a complete solution for regulatory management. Contact our team and request a demo.