🇧🇷Brazil

Multas por Não-Conformidade com FDS e FDSR (Resolução CFQ 335/2025)

2 verified sources

Definition

Resolução CFQ 335/2025 (published Oct 16, 2025) mandates that FDS (Ficha com Dados de Segurança) and FDSR (Hazardous Chemical Waste Safety Sheet) must be evaluated and issued by CRQ-registered professionals. Non-compliance triggers regulatory audits by state/federal authorities. Typical violations: outdated product formulations, incorrect hazard classifications, missing professional signatures, incomplete dossiês.

Key Findings

  • Financial Impact: Estimated: R$10,000–R$50,000 per audit failure; typical multiplier = 2–4 non-conformities per facility annually = R$20,000–R$200,000/year in potential fines + rework.
  • Frequency: Quarterly state SEFAZ audits; annual federal RFB compliance sweeps (increasingly electronic 2025+).
  • Root Cause: Decentralized responsibility: FDS originator (importer/manufacturer) vs. qualified professional (CRQ); no integrated workflow; manual document tracking.

Why This Matters

The Pitch: Manufacturers in Brasil waste R$50,000–R$200,000 annually on corrective audits, re-documentation, and penalties for non-compliant FDS/FDSR. Automated FDS lifecycle management with CRQ-integrated submission eliminates audit risk.

Affected Stakeholders

Química/Responsável Técnico, Compliance Officer, Procurement (chemical sourcing), Warehouse/Inventory Manager

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Financial Impact

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Current Workarounds

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Methodology & Sources

Data collected via OSINT from regulatory filings, industry audits, and verified case studies.

Evidence Sources:

Related Business Risks

Custos de Conformidade REACH Brasil – Data Collection & Dossiê Assembly

Estimated: R$50,000–R$150,000 per substance (lab testing) + R$20,000–R$100,000 in consulting/internal labor per facility = R$100,000–R$400,000 aggregate for typical mid-sized manufacturer (5–10 regulated substances).

Multas por Não-Conformidade no Transporte de Produtos Químicos Perigosos (ANTT)

Estimated: R$5,000–R$20,000 per autuação (ANTT fiscal stop); typical facility = 2–4 annual violations = R$10,000–R$80,000/year; environmental penalties (IBAMA, state) = additional R$20,000–R$100,000 per spill/accident.

Atrasos Operacionais & Parada de Produção – Procedimentos Manuais de Inventário Químico

Estimated: 40–80 labor hours/month (administrative staff) = R$20,000–R$40,000/month; production delay per chemical approval = 5–10 hours of line downtime = R$10,000–R$50,000 in lost throughput. Annual impact: R$120,000–R$480,000.

Erros de Decisão – Falta de Visibilidade em Conformidade Química & Decisões Impulsivas de Sourcing

Estimated: 2–5% of chemical procurement budget lost to excess sourcing/rework = R$40,000–R$150,000/year; supplier penalties (non-compliance refunds) = R$10,000–R$50,000/year; expedited waste disposal (wrong classification) = R$5,000–R$20,000/incident = R$20,000–R$80,000/year. Aggregate: R$70,000–R$280,000/year.

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