Labelling rules for packaged food imported into Brazil

The short answer

The identification side of the label runs on RDC 727/2022. Article 1 states that the resolution deals with the labelling of packaged foods. It brings MERCOSUL GMC 26/2003 into Brazilian law and replaced RDC 259/2002. It has been in force since 1 September 2022 under article 41, with one later deadline: the preparation instructions for raw meat and poultry under article 34 ran to 23 December 2022.

The nutrition side runs on RDC 429/2020 together with IN 75/2020. RDC 429/2020 was published on 9 October 2020 and, under article 51, took effect twenty four months later, on 9 October 2022. Article 50 gave a longer transition to part of the industry, including family farming and artisanal producers. This is the act that set the current nutrition table format and made front-of-pack warning labelling mandatory above defined limits.

A label cannot be finished after the container arrives, for reasons that are structural rather than administrative. The front of pack mark, where it applies, sits on Idec's description of the rule in the upper half of the main display panel, sized in proportion to it, so the front of the pack has to be laid out around it. The allergen declaration has its own typography rules, including a minimum character height. The nutrition table has to carry both total and added sugars, and the added sugars figure is one of three that get tested against the front of pack limits, alongside saturated fat and sodium. None of that is a line of text that can be dropped into whitespace at the last moment.

Which agency registers the product is a separate question from these two acts. Products of animal origin, beverages and unprocessed plant produce run through MAPA registration, while other packaged foods sit with ANVISA registration.

What the label has to carry

The mandatory declarations under RDC 727/2022, with the article each one comes from:

Element	Article of RDC 727/2022
Product name (denominação)	11
List of ingredients	12
Net content	28
Origin and manufacturer details: name, full address, country or municipality, establishment registration number	29
Importer name (razão social) and address, for imported food	29, item X
Lot number	30
Date marking (shelf life)	31
Preparation instructions, where applicable	32 to 35
Allergen declaration	13 to 15

The full text of RDC 727/2022 used for this page came from the São Paulo state health authority's published copy of the act, which is a government mirror of the official text rather than a commercial summary.

The importer line, and why article 29 item X shapes a commercial decision

Article 29, item X requires "nome (razão social) e endereço do importador, no caso de alimentos importados". The label names a specific Brazilian legal entity by its registered company name and address.

That has a consequence people usually meet late. The importer on the pack is fixed at the moment the artwork goes to print. If the exporter later changes importer, adds a second one, moves from an exclusive distributor to a multi importer model, or restructures the local entity, the printed labels no longer match reality and the artwork has to be reissued for the new name. For a producer running long print jobs to get unit cost down, that is a real cost attached to a commercial decision that often gets treated as reversible.

So the order of work is the reverse of what many exporters assume. The importing entity is chosen first, its registration and import licensing position is settled, and only then does artwork go to print with that name on it.

What language the label has to be in

The mandatory declarations described in RDC 727/2022 are set out in Portuguese, with fixed Portuguese wording for specific statements such as the allergen line, and the act transposes the MERCOSUL labelling model into national law.

A dedicated language article, one that states in terms that the label must be in Portuguese and can be cited by number, was not found in the text of RDC 727/2022 obtained while preparing this page. That is a gap in the checking, not a finding that no such requirement exists. Commercial guides state the Portuguese requirement freely and rarely cite an article for it. Treat the practical answer as settled by the wording of the declarations themselves, and if a legal citation is needed for a filing or a supplier contract, get it verified against the full current text rather than taken from a summary.

The nutrition table under RDC 429/2020

RDC 429/2020 replaced the previous nutrition table with a set format. The table is printed in black text on a white background, at a minimum of 8 pt, equivalent to 2.8 mm. Both total sugars and added sugars are declared, which was the substantive change for most imported products: added sugars had not been a separate line before.

Added sugars is not a number that can be borrowed from a category average or from an existing label written for another market. It comes out of the formulation, and it is the same number that gets tested against the front-of-pack limits in the next section. A product whose recipe is adjusted for the Brazilian market, for sweetness or for cost, can move across a threshold without anyone noticing until the artwork is being checked.

On sourcing: the text of RDC 429/2020 used here was read from the FAO's FAOLEX archive of the act, because ANVISA's own legislation database was returning a server side database error when checked and the health ministry's digital library blocks automated access. FAOLEX carries the full text, but it is an archive rather than the Brazilian official gazette.

The front-of-pack warning, the "lupa"

Article 18 of RDC 429/2020 makes front-of-pack nutrition declaration mandatory for products whose quantities of added sugars, saturated fats or sodium are equal to or above the limits defined in Anexo XV of IN 75/2020. IN 75/2020 is the technical instruction that sits alongside the resolution, and its article 17, as rendered in a legislation database rather than in the official text, is the provision that hands the numeric limits to Anexo XV.

The mark itself is a black and white symbol showing a magnifying glass, the "lupa", with the words "ALTO EM" followed by the nutrient at issue: "açúcar adicionado", "gordura saturada" or "sódio". It goes in the upper half of the main display panel and is sized in proportion to that panel. This description of the mark comes from published guidance by Idec, a Brazilian consumer defence organisation that specialises in this rule, rather than from the annex text.

Nutrient	Solid and semi-solid, per 100 g	Liquid, per 100 ml
Added sugars	15 g or more	7.5 g or more
Saturated fat	6 g or more	3 g or more
Sodium	600 mg or more	300 mg or more

These six figures need a plain statement about their status, because this page does not publish numbers without one.

They are reported here on ANVISA's own authority: they appear on ANVISA's summary page on nutrition labelling, and the same limits appear in a peer reviewed article that tabulates them. Two independent sources agree, one of them the regulator's own website, which is why the numbers are published rather than withheld. What could not be obtained while preparing this page is the primary text of Anexo XV of IN 75/2020 itself, for the technical reasons described in the previous section. Before artwork goes to print, check these limits against the current text of Anexo XV, not against this page and not against a commercial guide.

Where the other set of numbers comes from

There is a second set of thresholds in circulation, and it belongs to a different act with a different subject.

RDC 24/2010 regulates the advertising of food to children. It is not a labelling rule. Its articles 4 and 6 set their own limits, and they are close enough to the front-of-pack limits to be mistaken for them.

Nutrient	Front-of-pack labelling, RDC 429/2020 with IN 75/2020	Advertising to children, RDC 24/2010
Added sugars	15 g per 100 g, 7.5 g per 100 ml	15 g per 100 g, 7.5 g per 100 ml
Saturated fat	6 g per 100 g, 3 g per 100 ml	5 g per 100 g, 2.5 g per 100 ml
Sodium	600 mg per 100 g, 300 mg per 100 ml	400 mg per 100 g or per 100 ml, no split

The sugar figures are identical in both acts, which is exactly why the confusion survives: a reader checks the first line, sees a match, and assumes the rest of the column is right.

The tell is sodium. RDC 24/2010 uses a single figure of 400 mg for solids and liquids alike, with no separate limit per 100 ml. The front-of-pack rule splits solids from liquids for all three nutrients. If a commercial guide, a supplier deck or a consultancy one pager shows 5 g, 2.5 g and 400 mg and calls it front-of-pack labelling, it has almost certainly quoted the advertising act. The text of RDC 24/2010 is available in full and was read at first hand for this page, which is the reverse of the situation with Anexo XV.

Allergens run on two separate legal bases

Gluten and the wider allergen list come from different instruments, and they get merged in commercial material more often than not.

Lei 10.674/2003 covers gluten and only gluten. Article 1 requires the label to carry "contém Glúten" or "não contém Glúten", and paragraph 1 requires it in large, clear and easily readable type. Paragraph 2 gave industry one year to adapt. The law is in force.

The wider allergen declaration comes from RDC 727/2022. Article 13 sets the format, "ALÉRGICOS: CONTÉM" followed by the allergen name, drawing on the list in Annex III of the resolution. Article 15 sets the typography: capital letters, bold, in a colour that contrasts with the background, at a minimum height of 2 mm, reduced to 1 mm for packages of 100 cm² or less.

A note on an older act. RDC 26/2015 previously regulated allergen labelling separately, and it is still cited in circulating material. Whether RDC 727/2022 revoked it, and under which provision, was not verified for this page. What is verified is that articles 13 to 15 of RDC 727/2022 are the provisions that set the allergen declaration and its typography today.

What this means for your timeline

The practical sequence runs backwards from the print job.

The formulation produces the added sugars, saturated fat and sodium figures per 100 g or per 100 ml. Those figures decide whether one, two or three warning marks apply. The number of marks decides how much of the front panel is unavailable for brand design, so the panel is laid out after that test, not before. The nutrition table format, the allergen line and its 2 mm typography, and the importer name under article 29 item X are all fixed in the same artwork. A change to any of them, including a change of importer, means a new print run.

For an exporter, that puts label design in the same planning block as importing into Brazil generally: the entity decisions, the registration track and the label all have to be resolved before a first commercial production run is scheduled, not after the first container has shipped.

One thing worth stating for anyone reading this alongside trade news. Tariff schedules and labelling rules are separate bodies of law, and a trade agreement does not rewrite ANVISA's resolutions. That distinction is set out in more detail on what the EU-Mercosur agreement does not change.

Sources

• Mandatory label elements and their article numbers, allergen format and typography, and the effective dates of 1 September 2022 and 23 December 2022: RDC nº 727/2022, full text, mirrored by the São Paulo state health authority's BVS repository. Text of the act.
• Nutrition table format, minimum type size, total and added sugar declaration, the obligation to carry front-of-pack warnings and the effective date of 9 October 2022: RDC nº 429/2020, full text, archived by FAOLEX, the FAO legislative database, rather than obtained from the Brazilian official gazette directly.
• IN nº 75/2020 as the instruction carrying the front-of-pack limits in its Anexo XV: confirmed through the cross reference in article 18 of RDC 429/2020 and a legislation database rendering of article 17 of IN 75/2020. The text of Anexo XV itself could not be obtained; ANVISA's legislation database returned a server-side error and the health ministry library blocks automated access.
• The six front-of-pack limits themselves: ANVISA's own summary page on rotulagem nutricional, gov.br/anvisa, and a peer-reviewed article tabulating the same values. Converging secondary sources, not the annex text.
• Appearance and placement of the lupa mark: published guidance from Idec, a Brazilian consumer protection institute. Specialist secondary source.
• The different limits in RDC nº 24/2010, articles 4 and 6: full text of that act, archived by FAOLEX. Text of the act, cited here only as the likely origin of conflicting figures in circulation.
• Gluten declaration: Lei nº 10.674/2003, article 1 and paragraph 1, planalto.gov.br. Text of the act.
• The status of RDC 26/2015 and a dedicated language article in RDC 727/2022 were not confirmed in this review and are described on the page as open questions rather than findings.

Facts on this page were checked on 7 September 2026 against the text of each act named, except where the page says otherwise. Brazilian sanitary regulation is revised frequently, and the front-of-pack limits in particular should be reconfirmed against the current Anexo XV of IN 75/2020 before any label is printed.