Brazilian Exclusive Representative for Chemical Registration (Law 15.022/2024)
Managing Brazil registration centrally through a Brazilian Exclusive Representative
Law 15.022/2024 provides for foreign manufacturers whose chemical substances or mixtures are exported to Brazil to appoint a Brazilian Exclusive Representative — sometimes referred to as an Only Representative or OR, a concept familiar from other regulatory frameworks.
The National Chemical Substances Registry (Cadastro Nacional de Substâncias Químicas) is under development, with the platform expected by 2027, consistent with the three-year implementation period established by law.
Who can appoint an Exclusive Representative
The OR mechanism is available to foreign manufacturers whose chemical substances or mixtures are exported to Brazil.
The Exclusive Representative (the OR) must be a natural or legal person established in Brazil with the financial, administrative, and technical capacity to assume the responsibilities imposed on importers under the law. The appointment must be made by mutual agreement between the foreign manufacturer and the Representative.
Why foreign manufacturers appoint an Exclusive Representative
Managing registration through individual importers creates practical risks — inconsistent filings, loss of continuity when distributors change, and loss of control over how substance information is presented to Brazilian authorities. An Exclusive Representative addresses all of these.
Companies typically appoint an Exclusive Representative to:
- Manage registration obligations centrally
- Maintain consistency of registration data and filings when importers or distributors change
- Protect the confidentiality of substance identity — including CAS number — across the supply chain
- Ensure consistent communication with Brazilian authorities
- Provide customers with confirmation of registration status
- Coordinate supply chain administration and reduce the risk of inconsistent or incomplete filings
What the Exclusive Representative does
Under the law, the Exclusive Representative assumes the responsibilities and obligations imposed on importers. In practice this means:
- Preparing and submitting registration information to the National Chemical Substances Registry (Cadastro Nacional de Substâncias Químicas)
- Maintaining and updating registration records as required
- Providing safety data and supplementary information when requested by authorities
- Communicating with Brazilian regulatory authorities on behalf of the manufacturer
- Supporting Brazilian customers with confirmation of registration status
- Updating registrations when production volumes or other registered data change
Confidentiality protection under the law
The law provides specific confidentiality protections relevant to foreign manufacturers. Manufacturers and importers may request up to five years of protection against disclosure of substance identity and CAS number, subject to approval under the law.
Information constituting trade secrets — including technical and scientific information about manufacturing processes — is protected for an indefinite period or until the manufacturer consents to disclosure, the information is first released in any country, or disclosure is necessary to protect the public or the environment.
Information that cannot be claimed as confidential includes: recommended uses, hazard classification, health and environmental impact results, and risk assessment conclusions. Substance identification is non-confidential under the law; however, manufacturers and importers may request protection of substance identity and CAS number for a limited period (up to five years), subject to approval.
Information typically required
For preliminary evaluation:
- Substance identity (name and CAS number or IUPAC name)
- Approximate annual volume supplied to Brazil
- Product type (substance as such or substance as ingredient in a mixture)
- Number of Brazilian customers or importers
Ongoing responsibilities
Once appointed, the Exclusive Representative typically:
- Maintains registration records and manages updates
- Monitors and communicates relevant regulatory developments
- Provides customers with compliance confirmation as needed
- Coordinates with the manufacturer when new substances are added or volumes change
Request evaluation
We can review your substance list and outline a practical approach.
We are also developing Only Representative appointment services ahead of the 2027 registration platform launch. If you would like to discuss how this structure might work for your supply chain, we would be happy to connect.
This page provides general information based on Law No. 15.022/2024 as publicly available. It is not legal advice. The operational scope of the Exclusive Representative mechanism will be further defined in implementing regulations.