ILMA Compoundings July 2017 - 21

requiring permits or licenses. "Some
of the countries don't have a strong
regulatory approach at all."
There are also regulatory protocols
placed on lubricant manufacturers that
are connected with extraction processes,
Eggenschweiler said. When work or
chemical handling permits are required,
they are typically issued by a state or local agency depending on the area's size.

for the past three years, it has seen new
movement. "Brazil's potentially imminent adoption of a significant new
regulatory environment would have a
likely significant effect on all of South
America, and in many cases, it would
have an influential effect on Central
America," Eggenschweiler said.
Brazil tends to be the primary unofficial leader of the growth of regula-

member nations have access to those
standards and can adopt them into
their regulatory framework. "Some
of the smaller, less-developed nations
will just sometimes adopt the standard
and that becomes the law by default,"
Eggenschweiler said.
An increase in regulations in Brazil
would create more definition and
regulatory obligations while also stan-

"It is all handled in country at a semiformal level," he said, adding that some
countries require more details in terms
of the ingredient or use than others.
However, there are some countries
that are beginning to look at chemical regulations on a larger scale, with
Brazil taking the lead.
"It is anticipated Brazil may become
the very first of the Latin American
states to develop a comprehensive national system of chemical registration
and management," Eggenschweiler
said. "Brazil has been talking about
creating a European-style chemical
control law. It would fall under the
category of Global REACH."
While the topic of increased regulation within Brazil has been discussed

tions within Mercosur, a trade body
that has been growing for years within
South America, Eggenschwiler said.
"It has tried to bind together some
common approaches to regulations
around products and categories within
South America," he explained.
Mercosur keeps a body of regulatory
approaches and standards, and other

dardizing expectations. "It brings accountability that is uniform," Eggenschweiler said. "Right now you've got
a lot of variation from an application
standpoint. The requirements of some
who apply for a permit are a lot easier
than those [of ] others who apply."
There is opportunity for corruption
because the permit process can be
influenced in so many ways and there
is no accountability of the issuer to
review what criteria were used to grant
the permit. Eggenschweiler said data
requirements are not always enforced.
"In many cases it can be a matter of
payment of a fee," he said. "No one is
going to go in and audit the permits
that were issued and the applications,
nor is there a standard or data they

"Brazil has been
talking about
creating a Europeanstyle chemical
control law.

ILMA Compoundings July 2017

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