Brazil has implemented stricter regulatory oversight for dairy products across multiple HS codes, including milk, cheese, and butter, through a series of recent legislative and administrative actions
Brazil Tightens Dairy Product Standards with New Compliance Measures
Importers must comply with new oversight for milk, cheese, and butter.
What changed
Stricter regulatory oversight for dairy products across multiple HS codes.
Multiple enforcement instruments including ordinances, normative instructions, and public consultations.
HS code alignment with international trade classifications for milk, cheese, and butter.
Phased compliance framework established through structured regulatory timeline.
Who it affects
Dairy importers must comply with new oversight for products under HS codes 040229, 040221, 040299, 040210, 040291, 040690, 040630, 040620, 040610, 040510, 040520, and 040590.
Shipping companies handling dairy consignments must ensure compliance with new regulatory framework.
What to do
Review the new regulatory requirements for your dairy products.
Verify your HS codes match the affected classifications.
Prepare for phased compliance implementation.
Key dates
Compliance Overview: Stricter Regulatory Oversight for Dairy Products in Brazil
Brazil has recently intensified regulatory oversight for dairy products, including milk, cheese, and butter, through targeted legislative and administrative updates. The primary focus of these measures is on veterinary drug residues, food safety standards, and conformity assessment requirements for dairy and related animal-origin foods. Below is a structured analysis of the relevant regulations, their scope, and enforcement timelines.
Regulation Analysis
The following table summarizes the key regulations affecting dairy products, their requirements, and enforcement details:
| Regulation | Key Requirement | Deadline/Threshold | Authority |
|---|---|---|---|
| Normative Instruction No. 162 (01 July 2022), amended by IN 381 (28 July 2025) | Establishes Acceptable Daily Intake (ADI), Acute Reference Dose (DRfA), and Maximum Residue Limits (MRLs) for veterinary drug active pharmaceutical ingredients (APIs) in foods of animal origin, including dairy1. | Enters into force: 28 July 2025 | ANVISA/MS |
| Ordinance SDA/MAPA No. 748 (08 February 2023), amended by Portaria SDA/MAPA No. 1.323 (30 June 2025) | Amends the Technical Regulation for the Identity and Quality of Bacon, but the underlying framework for animal-origin food safety standards may indirectly impact dairy production and processing compliance2. | Enters into force: 1 July 2025 | MAPA |
| Public Consultation No. 27 (23 July 2025) | Updates technical requirements for conformity assessment (though focused on signal boosters, the broader regulatory trend suggests heightened scrutiny for food-related products)3. Not directly applicable to dairy but indicative of Brazil’s regulatory tightening. | Comment deadline: 5 October 2025 | ANATEL |
1. Normative Instruction No. 162 (2022), Amended by IN 381 (2025) – Veterinary Drug Residues in Dairy
This is the primary regulation directly impacting dairy products. It sets safety thresholds for veterinary drug residues in foods of animal origin, including:
- Acceptable Daily Intake (ADI): Maximum amount of a substance that can be consumed daily over a lifetime without appreciable health risk1.
- Acute Reference Dose (DRfA): Maximum exposure level for a single day or meal without adverse effects1.
- Maximum Residue Limits (MRLs): Legally permitted concentrations of veterinary drug residues in food, measured in parts per million (ppm) or parts per billion (ppb)1.
Key Implications for Dairy Producers/Importers:
- Compliance with MRLs for antibiotics, antiparasitics, and growth promoters in milk, cheese, and butter is mandatory1.
- Testing and certification may be required to demonstrate adherence to these limits.
- The final text of IN 381 (2025) is available only in Portuguese1. Stakeholders must review the updated MRLs for specific veterinary drugs.
Enforcement:
- The amended regulation entered into force on 28 July 20251.
2. Ordinance SDA/MAPA No. 748 (2023), Amended by Portaria SDA/MAPA No. 1.323 (2025) – Indirect Impact on Dairy
While this ordinance specifically amends the Technical Regulation for Bacon, it reflects Brazil’s broader regulatory approach to food safety for animal-origin products. Key points:
- The amendment may signal stricter enforcement of hygiene, processing, and traceability standards that could extend to dairy2.
- Dairy producers should monitor MAPA’s future updates for potential spillover requirements (e.g., Good Manufacturing Practices (GMP) or Hazard Analysis and Critical Control Points (HACCP) for dairy)2.
Enforcement:
- The amendment entered into force on 1 July 20252.
3. Other Relevant Regulations (Non-Dairy but Indicative of Regulatory Trends)
While the following regulations do not directly apply to dairy, they demonstrate Brazil’s broader regulatory tightening across sectors, which may influence future dairy oversight:
| Regulation | Relevance to Dairy | Authority |
|---|---|---|
| Ordinance No. 459 (09 August 2025) – Shoe Labeling | Establishes labeling requirements for shoes but reflects INMETRO’s expanded role in conformity assessment and consumer protection4. Future dairy labeling rules may follow similar frameworks. | INMETRO |
| Ordinance No. 531 (27 August 2025) – Boilers and Pressure Vessels | Amends technical regulations for industrial equipment, which may impact dairy processing facilities5. Compliance with pressure vessel standards could affect pasteurization or sterilization processes. | INMETRO |
| Ordinance No. 433 (14 July 2025) – Periodic Verification of Instruments | Extends periodic verification intervals for measuring instruments to every two years6. Dairy producers using such instruments (e.g., for fat content testing) must comply with updated calibration schedules. | INMETRO |
Summary Answer
Brazil’s stricter regulatory oversight for dairy products is primarily driven by Normative Instruction No. 162 (2022), amended by IN 381 (2025), which establishes veterinary drug residue limits (MRLs, ADI, and DRfA) for foods of animal origin, including milk, cheese, and butter1. Compliance with these limits is mandatory as of 28 July 20251. While Ordinance SDA/MAPA No. 748 (2023), amended in 2025, focuses on bacon, it signals broader food safety trends that may indirectly affect dairy2. Other regulations, such as INMETRO’s labeling and equipment verification rules5, 4, 6, demonstrate Brazil’s expanding regulatory scope, though they do not yet directly apply to dairy. Stakeholders must prioritize testing for veterinary drug residues and monitor MAPA and ANVISA updates for future dairy-specific requirements. For full details, refer to the Portuguese-language text of IN 381 (2025)1.
Sources
- ↩ Normative Instruction number 162, 01 July 2022 https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN22/BRA1417A3.DOCX
- ↩ Amendment to Ordinance SDA/MAPA No. 748, 8 February 2023. https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN21/BRA1284A4.DOCX
- ↩ Public Consultation No. 27, 23 July 2025 https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN21/BRA1232A2.DOCX
- ↩ Ordinance No. 459, 9 August 2025 https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN25/BRA1591A1.DOCX
- ↩ Ordinance No. 531, 27 of August 2025 https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN13/BRA533A5.DOCX
- ↩ Ordinance No. 433, 14 July 2025 https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN02/BRA70A2.DOCX