MAPA’s Secretariat of Agricultural Defense has opened a public consultation on a draft ordinance that updates and consolidates procedures applicable to the import and export of pesticides, fertilizers and related products, seeds, and seedlings. As stated on the consultation webpage, the deadline for submitting comments is October 23.
The proposal aims to align sector-specific rules with the New Import Process—utilizing the LPCO (Licensing, Permits, Certificates, and Other Documents) and Duimp (Single Import Declaration) systems—while incorporating risk management mechanisms and consolidating currently scattered regulations. Key points warranting attention from the affected sectors include:
• Pesticides: new scenarios requiring prior import authorization, risk management criteria, and changes to rules for rectifying irregularities regarding documentation, labeling, and packaging.
• Fertilizers and related products: updated import procedures—including those for personal use and research—featuring new documentation requirements and the possibility of authorizations covering multiple operations in specific situations.
• Seeds and seedlings: review and consolidation of procedures currently outlined in specific regulations, integrating them into the LPCO and Duimp model.
Bio-inputs warrant special attention. This category, established by Law No. 15.070/2024, is explicitly mentioned in the chapter covering fertilizers and related products but is not independently regulated within the draft ordinance. This may raise questions regarding the scope of the new rules for products that do not clearly fit into the traditional categories addressed by the ordinance. The decree regulating the Bio-inputs Law is still being drafted, and the law itself provides for future regulation of aspects related to—among other topics—the import and export of these products.
The public consultation offers an opportunity for affected sectors to assess the operational impact of the new rules, as well as any potential gaps, overlaps, or needs for regulatory clarification.
Leonardo Mattoso Sacilotto | leonardo.sacilotto@nascimentomourao.adv.br
Partner in the Environmental, Regulatory, and Biodiversity Law practice.
