Brazil REACH and Polymers: What the Law Actually Says
One of the most common questions from companies reviewing their Brazil REACH exposure involves polymers. The answer requires careful reading of the law — because the treatment of polymers, monomers, and polymer additives is more nuanced than a simple in or out.
The general rule: polymers must be registered
Law 15.022/2024 establishes that polymers must be registered in the National Inventory of Chemical Substances. This is the starting point.
The exceptions: what does not need to be registered
Article 8 of the law is explicit. The following do not need to be registered:
— Monomeric units when they form part of a polymer structure
— Additives added solely to preserve the stability of polymers
— Polymers of low concern, as defined by criteria to be established in implementing regulations
This means that if a monomer is incorporated into and forms part of a polymer chain, it is not separately registerable as a substance. The obligation sits with the polymer itself, not its constituent monomeric units.
What this means in practice
For companies that manufacture or import polymers into Brazil:. The polymer itself is registerable if it meets the 1 ton per year threshold. The monomers that make up the polymer structure are not separately registerable. Additives used only to preserve polymer stability are also excluded . However, additives with other functions — processing aids, colorants, functional additives — are not automatically excluded and need to be assessed separately.
The open question: polymers of low concern
The law creates a category of low concern polymers that will be exempt from registration, but it leaves the criteria entirely to implementing regulation. Until those criteria are published, companies cannot determine with certainty whether their specific polymer portfolio falls within the low concern exemption.
This is one of the many reasons why monitoring the implementing regulation closely matters for polymer manufacturers and importers.
The practical takeaway
If you manufacture or import polymers into Brazil, your starting position is that registration is required. The monomer exclusion and the low concern polymer exemption may reduce your scope, but the boundaries of both will depend on how implementing regulations define the details.
A preliminary portfolio review can help identify which of your substances are likely in scope and where the open questions sit.
This content is based on Law No. 15.022/2024. Implementation details will be further defined through regulation. This is not legal advice.