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July 25, 2023

Brazil Adopts Major Revision to NBR 14725

Bergeson & Campbell, P.C.

On July 3, 2023, the Brazil Association of Technical Standards (ABNT) adopted the amendment to the standard for classifying and labeling chemicals according to NBR 14725. The “new” NBR 14725:2023 merges the four-part standard into one, and adopts the 7th revised edition of the United Nations (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS). These revisions enter into force on July 4, 2025.

The following four parts consolidated into NBR 1475:2023 include:

  • ABNT NBR 14725-1 on Terminology;
     
  • ABNT NBR 14725-2 on Hazard Classification System;
     
  • ABNT NBR 14725-3 on Labeling; and
     
  • ABNT NBR 14725-4 on Safety Data Sheet (SDS).

The major updates to NBR 14725:2023 include the following items:

  • The SDS name in Brazil, referred to in the older ABNT, was “Ficha de Informações de Segurança de Produtos Químicos (FISPQ).” The SDS name was revised to “Ficha com Dados de Segurança (FDS).” This results in required revisions to all SDSs before the end of the implementation period;
     
  • The label may contain a QR code to gain access to the FDS content; and
     
  • Section 1 of the SDS will now require a 24-hour local phone number for emergencies.

The current standard in Brazil is based on Revision 3 of the UN GHS, and includes adoption of all building blocks (physical, health, and environmental). The adoption of Revision 7 impacts the following:

  • Changes to amend/add physical hazard categories;
    • Flammable gases amended to include categories 1A and 1B, chemical unstable gas categories A and B, pyrophoric gas, and changes to classification criteria;
       
    • Flammable aerosols renamed to aerosols, and the addition of the new category non-flammable aerosols; and
       
    • Addition of the physical hazard desensitized explosives with categories 1 through 4.
       
  • Change to classification criteria for the health hazard categories for acute toxicity and others;
     
  • The addition of the environmental classification, Hazardous to Ozone Layer;
     
  • Revisions and additions to hazard (H) and precautionary (P) statements; and
     
  • Update to labeling small packages.

Companies are provided two years to comply but are able to adopt the new changes at any time. The NBR 14725:2023 is currently available in Portuguese for sale, but unfortunately, not yet available in English.

Commentary

The consolidation of the four standards into one has been proposed and discussed in Brazil for many years. This update to Revision 7 of the UN GHS is in alignment with many others globally, including Canada’s recent updates to its Hazardous Products Regulation (HPR). Brazil’s version of the UN GHS model is nearly identical to the UN model, which is a relief to many stakeholders that deal with many variations on the UN approach across the globe. The reconciliation of four separate technical standards into one does improve the workability for users and provides for a consolidated approach for Brazil for potential future updates. Some stakeholders may feel two years is not sufficient to prepare and update all documents because of the name change of the SDS, but it is worth noting that not doing so provides easy opportunities for regulatory agencies to spot an obvious non-compliance.