The Government of the State of Mato Grosso published, on June 1, 2026, State Decree No. 2,156/2026, which regulates State Law No. 12,560/2024 and establishes guidelines for the implementation, structuring, operation, and monitoring of Reverse Logistics Systems in the state.
The regulation came into effect on the same date of its publication, revoking previous state provisions on the subject and consolidating a new set of obligations applicable to sectors subject to reverse logistics.
The Decree is applicable to manufacturers, importers, distributors, and retailers of products and packaging and indicates responsibility for these links in the production chain in post-consumption stages, including packaging in general made of plastic, paper, cardboard, metal, and glass, pesticides, batteries, tires, lubricating oils, lamps, electronic products, and household medicines. Furthermore, the obligations apply regardless of whether the economic agents have their headquarters or establishment in Mato Grosso, also covering operations carried out through e-commerce destined for the Mato Grosso consumer market.
Among the main requirements of the new regulation is the mandatory annual proof of compliance with the goals established in the Reverse Logistics Plans, whether individual or collective. To this end, those responsible for the systems must submit, through the State Reverse Logistics System (SISREV/MT), the Annual Results Report by July 31st of each year, including information relating to the period from January 1st to December 31st of the previous year.
The Decree provides a transitional rule for reverse logistics systems for packaging in general. Exceptionally, the results relating to the performance of 2025 must be reported by July 31st, 2027 (article 14 of State Decree No. 2,156/2026). From then on, the provision of information will occur annually, observing the deadlines defined in the regulations (article 11 of State Decree No. 2,156/2026).
Regarding packaging in general, the Single Annex of the Decree establishes progressive recovery targets, corresponding to 32% in 2026, 33% in 2027, 35% in 2028, and 36% in 2029. The results must be calculated individually by type of material, and compensation between different categories of waste is not permitted. Furthermore, geographical coverage targets have been established, requiring systems to demonstrate operation in at least 30% of the state’s municipalities by 2026, a percentage that should gradually increase until reaching 45% in 2029.
The traceability of operations is one of the pillars of the new regulations. Waste movement must be recorded through the Waste Transportation Manifest System (MTR), ensuring greater transparency and control over the flow of materials.
Additionally, the results declared by the systems must be audited and validated by an independent verification entity approved by the Ministry of the Environment and Climate Change (MMA), responsible for the custody of the information and the validation of the tax documents used to prove the recovery of waste. The supporting documents must be kept on file for a minimum period of 5 (five) years.
Another relevant aspect is the strengthening of inspection and control mechanisms. The decree assigns to the State Secretariat for the Environment of Mato Grosso (SEMA/MT) the competence to monitor compliance with obligations, analyze the reports submitted and adopt administrative measures in case of irregularities. Failure to comply with the obligations provided for in the regulation may constitute an environmental infraction, subjecting those responsible to the administrative sanctions provided for in state and federal legislation, including warnings, fines, suspension of activities and other applicable penalties.
The publication of State Decree No. 2,156/2026 reinforces the trend of strengthening state instruments for post-consumer responsibility and aligning them with the guidelines of the National Solid Waste Policy (Law No. 12,305/2010). In light of the new requirements, companies that market products and packaging in the state must review their regulatory compliance strategies, especially regarding the verification of results, traceability of operations, and compliance with the quantitative and geographical targets established by the regulation.
This material is exclusively institutional and informative in nature, limited to presenting general normative and administrative aspects of the subject.
Evelini Oliveira de Figueiredo Fonseca | evelini.fonseca@nascimentomourao.adv.br
Partner in the Environmental, Regulatory and Biodiversity Law area.
Juliana Robles Tasca juliana.tasca@nascimentomourao.adv.br
Advogada da área de Direito Ambiental, Regulatório e Biodiversidade.
