On February 9, the Minas Gerais State Secretariat for the Environment and Sustainable Development (Semad) published Copam Normative Resolution 249/24, which defines guidelines and minimum obligations for the implementation, operationalization and monitoring of the Reverse Logistics System (SLR). The SLR was instituted to enable the implementation and operationalization of reverse logistics of post-consumer products and packaging, with shared responsibility for the life cycle of the products.
The rule applies to manufacturers, importers, distributors and traders – whether or not subject to environmental licensing at the state level and regardless of the public service of urban cleaning and solid waste management – of the following groups of products and post-consumer packaging placed in the Minas Gerais market:
- household electronics, their components and packaging;
- portable batteries;
- automotive, industrial, and motorcycle lead-acid batteries;
- fluorescent, sodium vapour, mercury vapour and mixed light lamps;
- lubricating oil packaging;
- general packaging of plastic, paper, cardboard, metals and glass;
- expired or unused household medicines for human use and their packaging; and
- Scrap tires.
According to the resolution, the new obligations may be fulfilled in the following ways:
- individual, formalized in an Individual Reverse Logistics Plan previously registered with the competent state agency or entity; or
- in a Reverse Logistics Plan or Reverse Logistics Commitment Term (TCLR) to be signed between the body or entity and other interested parties provided for in the deliberation.
The deadline for registration of logistics plans is December 30, 2024. On the other hand, the annual results reports to prove the fulfillment of the goals and recovery of waste, in relation to the previous year, must be submitted by July 31 of each year.
The standard also presents a table with the quantitative and geographic goals for each sector, which must be reviewed by Copam every three years. The packaging sector in general, for example, has a quantitative target of 31.25% for the year 2025, in relation to the amount placed in the Minas Gerais market.
Another relevant point of the resolution refers to the responsibilities attributed to manufacturers, importers, distributors and traders. These include:
- inform and guide consumers about individualized and chained assignments, according to shared responsibility for the life cycle of products;
- costing, maintaining and managing the respective logistics points; and
- implement communication and environmental education plans by carrying out dissemination campaigns on the importance of the participation of consumers and other agents involved in SLRs and in the life cycle of products.
Failure to comply with the established obligations constitutes an environmental infraction. The inspection and application of penalties will follow the provisions of State Decree 47,383/18, which typifies violations of environmental protection standards – the decree provides for a maximum fine in the amount of 30,251,694.09 Ufemgs for environmental violations, which currently corresponds to R$ 159,719,869.28. The responsibility of companies and management entities will be assessed individually.
