Have you ever noticed whether a cosmetic product package lists its net content in “grams” or “milliliters”? Behind that small print lies a strict set of technical regulations. Recently, Brazil’s National Institute of Metrology, Quality and Technology (Inmetro) published a major draft proposal aimed at comprehensively updating the quantitative labeling rules for cosmetics across the Southern Common Market (MERCOSUR/Mercosul). This update is crucial for export compliance and directly impacts consumer transparency.
I. Regulatory Background: Overhauling a 22-Year-Old Rule
On April 24, 2026, Inmetro published Public Consultation No. 8 in the Diário Oficial da União (Brazil’s Federal Official Gazette), introducing a new draft of the MERCOSUR Metrological Technical Regulation on the Quantitative Indication for Cosmetics (Draft Resolution No. 02/25).
This draft is designated to replace the long-standing GMC Resolution No. 50/00, which has been in effect since 2000, bringing regional requirements in line with modern market developments and international standards under Working Subgroup No. 3 (SGT-3).
II. Core Requirements: Strict Division by Physical State
According to the new draft, net content declarations on cosmetic packaging must be rigorously separated by the physical characteristics and states of the product formulation:
1. Solids, Semi-Solids, and Solid-Liquid Mixtures $\rightarrow$ Must Use Mass
- Required Units: Grams or kilograms (g / kg)
- Applicable Products: Creams, hair waxes, clay masks, paste-like skincare products, and solid-liquid mixed scrubs.
2. Liquids $\rightarrow$ Must Use Volume
- Required Units: Milliliters or liters (mL / L)
- Applicable Products: Shampoos, shower gels, body mists, toners, and liquid serums.
3. Gels $\rightarrow$ Mass, Volume, or Both (Major Shift!)
- This is the most significant breakthrough of the revision. Gel-based products are no longer bound to a single mandatory unit. Instead, brands can choose the declaration method that best reflects the nature of their formulation (whether fluid or viscous) or align with international practices:
- By mass (g)
- By volume (mL)
- Dual-declaration (g + mL)
- Applicable Products: Hair gels, shampoo jellies, gel cleansers, and gel-based serums.
III. Public Feedback: 60-Day Consultation Period
Inmetro is actively seeking comments and suggestions from public stakeholders, industry organizations, and consumer groups to refine the regional draft before it is locked into national legal frameworks across MERCOSUR member states:
- Consultation Window: 60 days starting from April 24, 2026.
- Deadline for Submissions: June 23, 2026.
- Submission Channel: Contributions must be filed exclusively through the Brazilian government’s platform “Participa + Brasil” (Brasil Participativo via https://brasilparticipativo.presidencia.gov.br).
- Crucial Note: Comments submitted through any alternative or unofficial channels will not be legally accepted.
Summary and Industry Outlook
A tiny line of text on cosmetic packaging involves international trade rules, consumer rights protection, and market agility. This modernization of the MERCOSUR quantitative labeling rules reflects an active response to industry needs, adding flexibility for gel-formulation manufacturers.
Exporters, manufacturers, and private-label brand owners supplying Brazil and the wider MERCOSUR market should monitor this draft closely. Once approved at the MERCOSUR level, the text will be internalized into the domestic laws of individual member nations without further structural modifications.
