The Brazilian Institute of Environment and Renewable Natural Resources (IBAMA) has launched a public consultation on the draft of a new Normative Instruction (IN) aimed at strengthening and modernizing the control of imports of substances regulated under the Montreal Protocol.
The proposal seeks to consolidate existing obligations and prohibitions in Brazil related to these substances, define annual import limits for hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs), and establish a management model and national schedule for phase-out and reduction. The targets align with Brazilian legislation, Decision XIX/6, and the Kigali Amendment, enacted under Decree No. 11.666/2023.
Key proposed improvements include regulatory simplification through the consolidation of multiple rules into a single instrument and enhanced enforcement against informal trade. The regulation would require that all operations be carried out exclusively by legal entities (with CNPJ), ensuring traceability and alignment with global environmental goals.
The management of the technical reserve would be updated using the concepts of “economic unit” and “combined consumption mechanism,” aimed at preventing undue concentration, reducing costs, and streamlining processes. The proposal also introduces fixed limits for access to HFC reserves, transparent redistribution of unused quotas, and operational adjustments such as optimized container use and a monthly cycle for technical reserve requests.
The public consultation is open from December 10, 2025, to January 16, 2026. Stakeholders, including companies, experts, and civil society organizations, are invited to submit comments via an online form available on the official government platform.
According to IBAMA, the initiative reinforces Brazil’s commitment to protecting the ozone layer and mitigating climate change, supporting both the Brazilian HCFC Phase-out Management Plan and the HFC Consumption Reduction Program.
To participate in the Public Consultation and submit your contributions, please visit:
https://brasilparticipativo.presidencia.gov.br/processes/consolidacaodenormasprotocolodemontreal
