A/HRC/45/12/Add.4 23. The statement mentioned on page 8 of the preliminary report is also noteworthy, namely: 8. Brazil continues to use and export sulfuramid to other countries, a pesticide banned in other jurisdictions for decades, which degrades into “forever chemical” substances contaminating people around the world. 24. The source of information highlighted regarding the export of the substance “sulfluramide” by Brazil has not been identified. 25. In any case, it is vital to inform that “sulfluramide” is 81st among the active ingredients marketed in Brazil in 2018, according to Ibama’s Pesticide Marketing Bulletin. According to the bulletin mentioned above, the volume of sulfluramide sold corresponds to 0.01% of the total amount of active ingredients sold in 2018. 26. Another relevant fact is that researches for the active ingredient sulfluramide in more than seven thousand samples of different foods, from 2013 to 2018, within the scope of the PARA program, did not detect residues in any sample. Currently, the substance is authorized in Brazil as an insecticide and ant killer in the control of ants of the species Atta spp or Acromyrmex spp. 27. Also, page 9 of the preliminary report indicates the following: To the contrary, Brazil has increasingly pursued deregulatory measures to authorize additional hazardous pesticides through legislative and regulatory changes promoted by industry. In recent years, the “flexibilization” of pesticides regulations points to a tendency of misplaced interests. In 2019 alone, Brazil permitted the introduction into the market of 474 new pesticides products. 28. It is recalled that the registration of pesticides, their components, and the like is an assignment shared between three federal agencies: the Ministry of Agriculture, Livestock and Supply, the Ministry of Health, represented by Anvisa, and the Ministry of the Environment, represented by Ibama. All have equal decision-making power over whether or not to grant registration, safeguarding their respective areas of activity and institutional competencies. 29. It is essential to highlight that the three federal agencies have been looking for solutions specific to their internal realities, to obtain increased productivity when evaluating pesticide registration requirements. As a result of this joint effort, it is natural that there will be an increase in the number of assessed products and, in many cases, registered, following the trend of growth in demand for registration presented by the regulated sector. 30. In this context, it must be reiterated that all registered products are previously subjected to a rigorous technical evaluation carried out by those bodies concerning aspects related to health and the environment. Thus, the number of products registered per year should not be considered a negative indicator, since it refers only to the insertion in the market of new safe alternatives for rural producers, including chemical and biological products, which were approved because they met the requirements toxicological criteria. 31. The chart below shows the total number of evaluation requests filed by companies interested in obtaining their registration, the number of favorable analyzes by type of registration and the number of analyzes not granted, as they were registered or rejected, which, added together, total the number of requests processed by Ibama: 5

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