Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 1 RGSA – Revista de Gestão Social e Ambiental ISSN: 1981-982X Submission date: 1/3/2025 Acceptance date: 2/28/2025 DOI: https://doi.org/10.24857/rgsa.v19n4-114 Organization: Interinstitutional Scientific Committee Chief Editor: Ana Carolina Messias de Souza Ferreira da Costa Assessment: Double Blind Review pelo SEER/OJS THE IMPORTANCE OF MONITORING ACTIONS IN REVERSE LOGISTICS: NATIONAL OVERVIEW, CETESB (SP) SUCCESS STORY AND INITIATIVES IN THE STATE OF SANTA CATARINA Andressa Ellen Bastos 1 Gabriela Azevedo de Souza 2 Alexandre Borges Fagundes 3 Fernanda Hänsch Beuren 4 Caroline Rodrigues Vaz 5 ABSTRACT Objective: To identify the challenges faced in the implementation of reverse logistics and to highlight the importance of inspection actions for its success, seeking to provide recommendations to guide future political and administrative actions aimed at improving reverse logistics in Brazil. Theoretical Framework: A national overview of reverse logistics is presented, covering the PNRS and SINIR, as well as a contextualization of the importance of inspection actions and current initiatives at the national and state levels, in addition to highlighting actions developed in Santa Catarina and presenting the success story of CETESB (SP). Method: The methodology adopted comprised exploratory qualitative research, involving a balance between observation, reflection and interpretation regarding the importance of inspection actions in Brazilian reverse logistics. Results and Discussion: The study reveals gaps in the inspection and structuring of reverse logistics in Brazil, highlighting the need for more effective public policies. CETESB in São Paulo exemplifies success with progressive regulations, while other states adopt fragmented models, such as the initiatives under development in Santa Catarina. Research Implications: This study aims to be a starting point for broader discussions on reverse logistics, involving monitoring as an important element in fostering greater effectiveness of these practices, thus assuming a crucial role in a context where the effectiveness of environmental policies is increasingly required. Originality/Value: The research stands out for its potential to influence public policies and promote social awareness. Keywords: Reverse Logistics, Monitoring, CETESB, Santa Catarina, Success Story, National Panorama. 1 Universidade do Estado de Santa Catarina (udesc), Lajes, Santa Catarina, Brasil. E-mail:
[email protected] Orcid: https://orcid.org/0009-0008-7614-6168 2 Universidade do Estado de Santa Catarina (udesc), Lajes, Santa Catarina, Brasil. E-mail:
[email protected] Orcid: https://orcid.org/0009-0005-2064-1176 3 Universidade do Estado de Santa Catarina (udesc), Lajes, Santa Catarina, Brasil. E-mail:
[email protected] Orcid: https://orcid.org/0000-0003-2941-1842 4 Universidade do Estado de Santa Catarina (udesc), Lajes, Santa Catarina, Brasil. E-mail:
[email protected] Orcid: https://orcid.org/0000-0003-1338-9660 5 Universidade do Estado de Santa Catarina (udesc), Lajes, Santa Catarina, Brasil. E-mail:
[email protected] Orcid: https://orcid.org/0000-0002-0378-2533
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 2 A IMPORTÂNCIA DE AÇÕES FISCALIZATÓRIAS NA LOGÍSTICA REVERSA: PANORAMA NACIONAL, CASO DE SUCESSO DA CETESB (SP) E INICIATIVAS NO ESTADO DE SANTA CATARINA RESUMO Objetivo: Identificar os desafios enfrentados na implementação da logística reversa e evidenciar a importância das ações fiscalizatórias para o seu sucesso, buscando fornecer recomendações no sentido de guiar futuras ações políticas e administrativas voltadas à melhoria da logística reversa no Brasil. Referencial Teórico: É apresentado um panorama nacional relativo à logística reversa, abrangendo desde a PNRS e o SINIR, passando por uma contextualização sobre a importância das ações fiscalizatórias e atuais iniciativas existentes em nível nacional e estadual, além de pontuar ações desenvolvidas em Santa Catarina e apresentar o caso de sucesso da CETESB (SP). Método: A metodologia adotada compreendeu pesquisa qualitativa exploratória, envolvendo um balanço entre observação, reflexão e interpretação acerca da importância de ações fiscalizatórias na logística reversa brasileira. Resultados e Discussão: O estudo revela lacunas na fiscalização e estruturação da logística reversa no Brasil, destacando a necessidade de políticas públicas mais eficazes. A CETESB em São Paulo exemplifica sucesso com regulamentações progressivas, enquanto outros estados adotam modelos fragmentados, como as iniciativas em desenvolvimento em Santa Catarina. Implicações da Pesquisa: Este estudo se propõe a ser um ponto de partida para discussões mais amplas sobre logística reversa, envolvendo a fiscalização como importante elemento ao fomento da maior efetividade dessas práticas, assim assumindo um papel crucial em um contexto onde a eficácia das políticas ambientais é cada vez mais requerida. Originalidade/Valor: A pesquisa se destaca pela possibilidade de influenciar políticas públicas e promover a conscientização social. Palavras-chave: Logística Reversa, Fiscalização, CETESB, Santa Catarina, Caso de Sucesso, Panorama Nacional. LA IMPORTANCIA DEL MONITOREO DE LAS ACCIONES EN LOGÍSTICA INVERSA: PANORAMA NACIONAL, CASO DE ÉXITO DE LA CETESB (SP) E INICIATIVAS EN EL ESTADO DE SANTA CATARINA RESUMEN Objetivo: Identificar los desafíos enfrentados en la implementación de la logística inversa y destacar la importancia de las acciones de fiscalización para su éxito, buscando proporcionar recomendaciones para orientar futuras acciones políticas y administrativas destinadas a mejorar la logística inversa en Brasil. Marco Teórico: Se presenta un panorama nacional de la logística reversa, abarcando el PNRS y el SINIR, además de contextualizar la importancia de las acciones de fiscalización y las iniciativas actuales a nivel nacional y estatal, además de destacar acciones desarrolladas en Santa Catarina y presentar la historia de éxito de la CETESB (SP). Método: La metodología adoptada comprendió una investigación cualitativa exploratoria, involucrando un equilibrio entre la observación, la reflexión y la interpretación acerca de la importancia de las acciones de inspección en la logística reversa brasileña. Resultados y Discusión: El estudio revela brechas en el monitoreo y estructuración de la logística reversa en Brasil, destacando la necesidad de políticas públicas más efectivas. La CETESB de São Paulo ejemplifica el éxito con regulaciones progresistas, mientras otros estados adoptan modelos fragmentados, como las iniciativas en desarrollo en Santa Catarina. Implicaciones de la investigación: Este estudio pretende ser un punto de partida para discusiones más amplias sobre la logística inversa, involucrando a la inspección como un elemento importante para promover una mayor
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 3 efectividad de estas prácticas, asumiendo así un papel crucial en un contexto donde cada vez se requiere más la efectividad de las políticas ambientales. Originalidad/Valor: La investigación se destaca por su potencial para influir en las políticas públicas y promover la conciencia social. Palabras clave: Logística Inversa, Inspección, CETESB, Santa Catarina, Caso de Éxito, Panorama Nacional. RGSA adota a Licença de Atribuição CC BY do Creative Commons (https://creativecommons.org/licenses/by/4.0/). 1 INTRODUCTION The growing concern about solid waste management and the need for sustainable practices have motivated studies on the effectiveness/efficiency of reverse logistics in Brazil. The National Solid Waste Policy (PNRS) presents guidelines for shared responsibility in the life cycle of products, aiming to reduce environmental impacts. However, despite the promising legislation, a significant challenge remains in the implementation and monitoring of these practices, which may result in inadequate waste management. This scenario therefore demands an investigation into possible gaps inherent in the practices currently developed in reverse logistics, especially with regard to inspection and the actions necessary to guarantee their effectiveness. In this sense, this research was structured to provide a national overview of reverse logistics, covering the National Solid Waste Policy (PNRS) and the National Information System on Solid Waste Management (SINIR), as well as contextualizing the importance of inspection actions in reverse logistics and current inspection initiatives at national and state levels. It highlights the actions developed in the state of Santa Catarina, presents the success story of CETESB (SP), and establishes analyses and discussions on the scope of reverse logistics inspection in Brazil, drawing a parallel with CETESB's actions. Thus, the research's main objectives were to identify the challenges faced in implementing reverse logistics and present an analysis of the importance of inspection actions for its success, also seeking to provide recommendations to guide future political and administrative actions aimed at improving reverse logistics in Brazil. The relevance of this research stands out not only due to the pressing need for more sustainable practices in waste management, but also due to the possibility of influencing public policies and promoting social awareness.
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 4 By contributing to a better understanding of barriers and opportunities in reverse logistics actions, this study aims to be a starting point for broader discussions on this topic, involving inspection as an important element in promoting greater effectiveness of reverse logistics practices, thus assuming a crucial role in a context where the effectiveness of environmental policies is increasingly required, emphasizing the need for articulation between government, private sector and civil society to build a more sustainable future. 2 THEORETICAL FRAMEWORK The National Solid Waste Policy (PNRS), Law No. 12,305/2010, regulated by Decree No. 10,936/2022, drove transformations in the management of solid waste, directly impacting the actions of public bodies, the productive sector and society as a whole. Reverse logistics is consolidated in this context, “[...] as an instrument of economic and social development, which is characterized by the set of actions, procedures and means designed to enable the collection and return of solid waste to the business sector, for reuse, in its cycle or in other production cycles, or for another environmentally appropriate final destination” (Brazil, 2022b). The obligation to structure, implement and operate reverse logistics systems, as well as responsibility for the product life cycle, are attributed to manufacturers, importers, distributors and traders related to the so-called priority flows, which would be: “I - pesticides, their residues and packaging, as well as other products whose packaging, after use, constitutes hazardous waste, in compliance with the rules for managing hazardous waste provided for in law or regulation, in standards established by the bodies of Sisnama, SNVS and Suasa, or in technical standards; II - batteries; III - tires; IV - lubricating oils, their residues and packaging; V - fluorescent, sodium and mercury vapor and mixed light lamps; VI - electronic products and their components” (Brazil, 2010; 2022b). Through sectoral agreements, regulations issued by the Public Authorities, or terms of commitment, there will be a consequent structuring of the product life cycle. This organizational aspect is elucidated through art. 14 and art. 18 of Federal Decree No. 10,936/2022, which specifies that:
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 5 “manufacturers, importers, distributors and traders are responsible for carrying out reverse logistics within the limits of the proportion of products they place on the domestic market, in accordance with progressive, intermediate and final targets established in the instrument that determines the implementation of reverse logistics” (Brazil, 2022b). Recently, Decree No. 11,413/2023 (Brazil, 2023a) introduced new instruments, such as Recycling Credit Certificates, which encouraged companies to participate in improving the efficiency of the system. Environmentally sound management and administration of all stages of the product life cycle, following the principles, guidelines and objectives established by Law No. 12,305/2010 (Brazil, 2010), require careful planning from the moment the products are designed. This includes the careful selection of materials (raw materials and inputs) and the modification of production processes, adopting clean technologies and environmental management systems. The objective is to avoid the generation of waste or reduce its hazardousness, considering all stages of the product flow, from production to consumption and final disposal. Currently, the implementation and operation of reverse logistics systems occur through the following instruments, as shown in Table 1: Table 1 Mechanisms for implementing and operationalizing reverse logistics systems. Mechanism Description Procedures Changes with the New Decrees Regulation Issued by the Public Authorities Reverse logistics can be implemented directly by regulation, conveyed by decree issued by the Executive Branch. The Steering Committee must assess the technical and economic feasibility before issuing the regulation. Reverse logistics systems established by decree must be preceded by public consultation. The regulation must be submitted to public consultation and hearings by competent federal agencies. - Reverse Logistics Recycling Credit Certificate: Document that certifies the reintegration into the production cycle of the equivalent quantity of products or packaging subject to reverse logistics. Sectoral Agreements Acts of a contractual nature, signed between the Public Authorities and manufacturers, importers, distributors or traders, aiming at the implementation of shared responsibility for the life cycle of products. - They can be initiated by the Public Authorities or by manufacturers, importers, distributors or traders. - Economic and Financial Sustainability: the new decrees highlight the importance of ensuring the economic and financial sustainability of reverse logistics systems. - Inclusion of Cooperatives: sectoral agreements can now cover cooperatives and associations of recyclable material collectors.
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 6 Terms of Commitment Contractual agreements established between the Public Authorities and manufacturers, importers, distributors or traders, with the aim of implementing shared responsibility for the life cycle of products. - They are applicable when there is no sectoral agreement or specific regulation in the same area of coverage. - They can define more rigorous commitments and targets than those provided for in sectoral agreements or regulations. - Effectiveness begins after approval by the competent environmental body of SISNAMA, in accordance with the territorial scope. - They may involve cooperatives and associations of recyclable material collectors. - Structural Projects: the terms of commitment may cover structuring projects that promote the recovery of recyclable materials and the socioeconomic inclusion of collectors. - Socio-environmental Impact: must assume premises of socioenvironmental impact, such as income generation and environmental education. Source: The authors, based on Brazil, 2010; 2022a; 2022b; 2023a; 2023b. Responsibility for the product life cycle and the implementation of reverse logistics is established in article 31, section III, and detailed in article 33 of the National Solid Waste Law (Brazil, 2010). From the devices that deal with reverse logistics, the following assumptions can be concluded, as shown in Figure 1. Figure 1 Reverse Logistics Assumptions. Source: Adapted from Brazil, 2022a. Furthermore, article 36, IV, determines that, within the shared responsibility for the life cycle of products, it is up to the holder of public urban cleaning and solid waste management •The Municipality's actions for managing solid waste from households must be independent of the public authorities. Independence of Public Power •Reverse logistics must cover packaging. Packaging Scope •This should be assessed in relation to the product, not the chain. Technical and Economic Feasibility •They must take all necessary measures to ensure the implementation and operation of the reverse logistics system. Manufacturers, Importers, Distributors and Traders •If the municipal public authority participates, it must be by prior agreement (sectoral or commitment) and remunerated. Participation of the Municipal Public Authority •The existence of a general sectoral agreement does not exclude individual responsibilities. General Sectoral Agreement •The participation of recyclable material collectors should be foreseen. Participation of Recyclable Material Collectors
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 7 services to carry out the activities defined by sectoral agreement or term of commitment, with due remuneration by the business sector (Brazil, 2010). It is therefore clear that the government can only carry out activities related to reverse logistics if there is a prior agreement and if it is duly remunerated for it. In this sense, Serra (2015, p. 151-152) highlights that “the government cannot assume, without due consideration, the responsibility attributed to manufacturers, importers, distributors and traders in the reverse logistics system of products and packaging”. Sectoral agreements or terms of commitment must establish the remuneration due to the government, in accordance with articles 36, IV and 33, § 7º of the PNRS (Brazil, 2010). The PNRS highlights the importance of cooperation between the public and business sectors to make reverse logistics viable, establishing that this partnership must include counterparts. Furthermore, it determines that the costs of managing post-consumer solid waste must be borne by those responsible for its generation, and not by society. Any involvement of the public authorities in the implementation of reverse logistics, which is the responsibility of the private sector, requires financial compensation, under the risk of configuring illicit enrichment of the latter and unjustified impoverishment of the public treasury (Serra, 2015, p.222). Thus, as established by Brasil (2022a), it is up to the business sector, when implementing a reverse logistics system in accordance with art. 33 of Law No. 12,305/2010 (PNRS), to detail the actions, procedures and means it intends to adopt, assuming the costs independently of public urban cleaning services. The objective is to guarantee the collection and return of solid waste to the private sector, for reuse in its production cycle or in other cycles, or for an environmentally correct final destination. Importers, manufacturers, distributors and traders must take all necessary actions to ensure the implementation and operation of the reverse logistics system under their responsibility. These actions include: establishing procedures for the purchase of used products or packaging; providing collection points for reusable and recyclable waste; and establishing partnerships with cooperatives or other forms of association of collectors of reusable and recyclable materials (Brazil, 2022a). The PNRS requires the business sector to take specific measures to ensure the collection and return of post-consumer packaging, with a view to reusing it in its cycle or in other production cycles, and describe how it intends to implement them. Federal Decree No. 11,413/2023 (Brazil, 2023a) brought significant advances by establishing the general obligation to comply with reverse logistics based on measurable results.
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 8 It applies to individuals and legal entities, under public or private law, involved in activities related to reverse logistics, integrated management and solid waste management. Figure 2 shows the main aspects of Federal Decree No. 11,413/2023. Figure 2 General Obligation to Comply with Reverse Logistics – Individual or Collective, SelfDeclaratory and Results-Based Systems. Source: Adapted from Brazil, 2022a; 2023a. •The decree applies to all sectors involved in reverse logistics, including specific systems already in operation, such as packaging for pesticides, lubricating oils, tires, electronics, lamps, batteries, medicines, among others. Applicability •It defines the reverse logistics system as an integrated set of actions, procedures and means designed to enable the collection, sorting and return of recyclable products or packaging to the business sector for reuse or environmentally appropriate final disposal. Reverse Logistics Systems •Collective Model: Executed by a managing entity that encompasses a group of entities representing the sectors involved and the participating companies. Individual Model: Executed directly by a participating company. Collective and Individual Models •All manufacturers, importers, distributors and packaging traders must prove that reverse logistics has been carried out, either through credits established in the decree or by other means. Obligation to Prove •Managing entities and legal entities must submit annual reports by July 30 of each year, detailing the efficiency of return and recovery of packaging in relation to the investments made. Annual Reports •The participation of recyclable material collectors should be foreseen . Self-declaration systems •The remuneration of reverse logistics credits is made through electronic invoices relating to the sale of recyclable products or packaging, approved by the managing entity and verified by a results verifier . Remuneration of Credits •Companies have a period of one year and cooperatives have two years (extendable) to adapt to the Waste Transport Manifest (MTR) system. Compliance Period
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 9 These points highlight the importance of the aforementioned decree in creating a welldefined and measurable structure for reverse logistics, encouraging shared responsibility and environmental sustainability. The main legislations that deal with reverse logistics systems in Brazil are highlighted in Figure 3. Figure 3 Legislation regarding Reverse Logistics in Brazil. Source: Adapted from Brazil, 2010; 2022b; 2023a; 2023b. In this regard, it is worth mentioning that, according to Matos (2024), since the launch of the PNRS, 16 Brazilian states have already regulated Reverse Logistics, through specific legislation and decrees, and this regulatory advancement has brought an increase in recycling in the country. When analyzing the state of Santa Catarina, we can see the existence of some specific legislation, which complements the PNRS, such as those listed in Figure 4. Federal Law No. 12,305/2010:Institutes the National Solid Waste Policy (PNRS), which establishes shared responsibility for the life cycle of products and defines reverse logistics as one of the instruments for solid waste management. Federal Decree No. 10,936/2022: Updates and consolidates the rules on the National Solid Waste Policy, including specific guidelines for reverse logistics. Federal Decree No. 11,413/2023: Introduces new instruments within the scope of reverse logistics systems, such as the Reverse Logistics Recycling Credit Certificate and the Certificate of Structuring and Recycling of Packaging in General. Federal Decree No. 11,414/2023: Complements Decree No. 11,413/2023, detailing the control and inspection mechanisms for reverse logistics systems.
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 16 The aim was to analyze, at a national level, the cases of actions by environmental agencies that operate in Reverse Logistics, and how they are being made viable. Some of the main inspection initiatives that exist at a national level are shown in Table 3. Table 3 Existing inspection initiatives at national level in Brazil. Organ Environm ental Actions Implemented Flows Priorities Potentialit ies Challenge s Criticism CETESB (SP) Establishment of reverse logistics systems through Terms of Commitment, whether individual or collective Packaging, electronics, lamps, batteries, tires Solid structure and clear regulation Adherence and complianc e by companies Complexity in relation to meeting goals INEA (RJ) Implementation of reverse logistics systems through sectoral agreements and terms of commitment. Packaging, electronics, lamps, batteries, tires Integration with federal policies Coordinati on between different sectors Lack of clarity in some regulations IMASUL (MS) Structuring and implementation of reverse logistics systems considering Sema Resolution No. 33, through a Commitment Term Lubricating oils, batteries, lamps, tires, electronics and pesticides (consolidated in general packaging) Clear and specific guidelines Effective monitoring and control Need for greater engagemen t from companies Water and Land Institute (PR) Development of reverse logistics programs in collaboration with companies and associations Packaging, electronics, lamps, batteries, tires Publicprivate partnership s Continuou s monitoring and evaluation Challenges in practical implementa tion SEMA (RS) Implementation of reverse logistics systems through state regulations Packaging, electronics, lamps, batteries, tires Structuring efficient systems Ensure the participatio n of all those involved Need for greater supervision IMA (SC) Implementation of reverse logistics systems through specific terms of commitment and regulations Packaging, electronics, lamps, batteries, tires Structuring of integrated systems Coordinati on between different sectors Challenges in monitoring and control Source: Prepared by the authors, compiled from CETESB (2024); INEA (2024); IMASUL (2024); Water and Land Institute (2024); SEMA (2024); IMA (2024b). 2.3 REVERSE LOGISTICS INITIATIVES CARRIED OUT IN THE STATE OF SANTA CATARINA The initiatives being implemented in Santa Catarina have been promoted through the actions of the Environmental Institute (IMA), a state environmental agency, and the Public Ministry of Santa Catarina (MPSC). One of IMA's main projects is the Penso, Logo Destino Program, launched in 2019. The program aims to raise awareness among the population about the correct disposal of waste and
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 17 promote collaboration between merchants, municipal administration and management entities to ensure the adequate collection of recyclable materials. In addition, it seeks to encourage sustainable practices and reduce environmental impact (IMA, 2024a). IMA also provides technical support to municipalities to implement reverse logistics initiatives tailored to their local needs, and carries out educational activities to inform the population about the benefits of recycling and the risks of improper disposal. These actions are essential to improve waste management and promote a culture of sustainability in Santa Catarina (Estado de Santa Catarina, 2022). The MPSC, in turn, has collaborated with the IMA to expand reverse logistics throughout the state, especially in relation to products such as light bulbs, batteries, tires and pesticide packaging. With resources from the Damaged Assets Reconstitution Fund (FRBL), the IMA is expanding the program to serve all municipalities in Santa Catarina. The project is starting with small municipalities (up to 20 thousand inhabitants) and will subsequently reach large cities (MPSC, 2023). These initiatives are relevant and fundamental for building a culture of sustainability in the state, providing shared responsibility among all sectors of society and contributing to progress with waste management. 2.4 MEASURES ADOPTED BY THE STATE OF SANTA CATARINA As evidenced, Santa Catarina currently does not have its own regulations to deal with reverse logistics systems. In October 2024, the Santa Catarina Environmental Institute (IMA) and the State Secretariat for the Environment and Green Economy (Semae) held a public consultation for a proposed Decree regulating the structuring, implementation, and operation of reverse logistics systems in the State. This public consultation will be open for a period of 30 days, and contributions and suggestions must be substantiated, identified, and sent using the electronic form available on the IMA website (IMA, 2024b). The process for creating and implementing reverse logistics systems in the state can be initiated by the sectional environmental body, by the State Secretariat responsible for the environment or by managing entities, as long as they present a proposal for a commitment term. When analyzing the draft decree (Semae, 2024), it is clear that the proposal clarifies, within the scope of environmental licensing, the creation of specific guidelines. These guidelines determine that manufacturers, importers, distributors and traders, responsible for
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 18 implementing reverse logistics systems, must prove the environmental compliance of their systems. Proof must be made through a protocol with the environmental agency, which is an essential condition for obtaining licensing. The opening of the public consultation to society demonstrates the government's commitment to adapting state legislation and its local needs to the PNRS guidelines. 2.5 CETESB'S ROLE IN REVERSE LOGISTICS In 2011, the State Secretariat for the Environment and CETESB developed a long-term strategy to implement reverse logistics in the state of São Paulo. Taking into account the existence of state legislation that predated the federal one, a more advanced infrastructure and a strong demand from civil society, the private sector and the Public Prosecutor's Office for improvements in waste management, the State Government decided to adopt its own approach, parallel to that of the Federal Government (CETESB, 2025). The strategy recognized the economic complexity involved in reverse logistics and was therefore designed to be implemented gradually. In addition, the plan included initiatives already underway for certain products and highlighted the importance of involving the private sector in the process, allowing it to present economically viable proposals for the system. The strategy was structured in three phases: from 2011 to 2015, with pilot programs focused on industry and importers; from 2015 to 2021, with expansion to commerce and municipalities; and from 2021 to 2025, aiming to consolidate the legislation (Cetesb, 2025). In April 2018, CETESB published Board Decision No. 076/2018/C , which “establishes the regulations for the inclusion of reverse logistics in the state environmental licensing process”. The standard defines criteria for the gradual requirement of reverse logistics as a condition for the issuance or renewal of operating licenses for companies that manufacture, import, distribute or sell various products and packaging subject to this system (Cetesb, 2018). In July 2024, CETESB made further progress in monitoring and overseeing reverse logistics by publishing Board Decision No. 051/2024/P. This new regulation details the procedures for companies to demonstrate compliance with reverse logistics requirements in the context of environmental licensing. The decision reinforces the obligation for companies, especially those linked to the production, import and marketing of products subject to reverse logistics, to integrate this practice into their operations, aiming to ensure more effective management of the waste generated (Cetesb, 2024).
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 19 The implementation of this standard brought greater clarity to companies regarding their responsibilities and consolidated the role of reverse logistics as a crucial factor in the environmental licensing process in the state of São Paulo. By establishing this regulatory framework, CETESB sought to intensify control and monitoring over compliance with reverse logistics goals, aiming to create a more efficient and transparent waste management system. According to recent studies, the inclusion of these requirements in environmental licensing promoted greater adherence by companies to material return and recycling practices, contributing significantly to the reduction of solid waste destined for landfills (Silva et al. , 2023). Despite national challenges, the strategy used by CETESB has evolved continuously. The experience gained in previous phases of implementation has served as a basis for the improvement of public policies that encourage shared responsibility and the minimization of waste generation. When compared to other Brazilian states, CETESB's performance is recognized as one of the most advanced in the country in terms of regulation and monitoring of reverse logistics. In the state of Mato Grosso do Sul, for example, the Environmental Institute (Imasul, 2024) adopts general guidelines based on federal legislation, applying reverse logistics requirements to specific sectors and integrating them into licensing processes, but without a gradual phased structure like that practiced by CETESB. In Rio de Janeiro, the State Environmental Institute (INEA, 2024) is advancing sectoral agreements aimed at specific waste, such as electronics and hazardous waste, promoting shared responsibility, but with a lower level of demand and detail than the São Paulo model. In Paraná, the Water and Land Institute (2024) adopts reverse logistics through agreements and licensing conditions, but without unified and continuous regulation for industries that need to comply with this requirement. Regulation is still done in a fragmented manner, which reflects the lack of a systemic structure like that of CETESB. Similarly, in Rio Grande do Sul, the State Foundation for Environmental Protection (Fepam, 2024) implements reverse logistics with a focus on urban solid waste and packaging, but without the same rigidity in licensing conditions or regulatory progressiveness as the São Paulo model. As a case study, CETESB's performance exemplifies the importance of effective oversight and the creation of a regulatory environment that fosters sustainability, engaging both the private sector and public bodies in the construction of a circular economy (Carvalho et al. , 2021).
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 20 3 METHODOLOGY This study is characterized as a qualitative approach, as it concerns aspects of reality that cannot be quantified, and allows for the understanding, analysis and interpretation of social interactions, emphasizing the understanding of the whole (Gerhardt and Silveira, 2009; Bogdan & Bicklen, 1994; Godoy 1995). According to Gil (2016), qualitative research involves a balance between observation, reflection and interpretation throughout the development of the research, making the organization of the work complex, in accordance with the proposal of this work, which aims to describe the difficulties in carrying out effective inspections in relation to the priority flows outlined within reverse logistics in Brazil. Regarding the objectives, the research is classified as exploratory, carried out through bibliographical research (Gil, 2016, p. 27), and also as descriptive, by exposing characteristics of a population, or identifying relationships between variables (Marconi and Lakatos, 2017). Both classifications are used by social researchers concerned with practical action (Gil, 2014). Regarding the procedures, these are detailed as documentary research, as they use materials that have not received analytical treatment, or that can still be reworked according to the research objectives, such as official documents, newspaper reports, contracts, recordings and research reports (Gil, 2014, p.51). 4 RESULTS The results of this study point to a gap in the monitoring and structuring of reverse logistics in Brazil, highlighting the need for public policies to ensure the effectiveness of this practice throughout the country. The comparative analysis revealed CETESB's progress as an example of successful implementation of reverse logistics, in contrast to other regions of the country, which adopt more fragmented and less effective approaches. Since 2011, CETESB has been adopting an innovative approach, with progressive regulations for reverse logistics, notably Board Decisions no. 076/2018/C and no. 051/2024/P. These guidelines impose specific requirements for environmental licensing and the verification of targets by companies, creating a continuous monitoring model that has encouraged the private sector to adhere to the appropriate disposal of waste. In states such as Mato Grosso do Sul and Rio de Janeiro, adherence to national guidelines is observed, although in a less structured and rigorous manner in terms of targets. The Mato Grosso do Sul Environmental Institute (IMASUL) and the State Environmental
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 21 Institute (INEA) in Rio de Janeiro implement reverse logistics practices, focused on packaging and electronic waste, but without additional guidelines that consolidate systematic monitoring practices such as those observed in São Paulo. In Paraná and Rio Grande do Sul, the reverse logistics model is applied in a more localized manner and with less comprehensive regulations. In the state of Santa Catarina, reverse logistics initiatives are still in the development phase. In 2019, IMA implemented the “Penso, Logo Destino” program, with the aim of raising awareness about the importance of proper waste disposal and establishing collection points, in collaboration with commercial establishments and municipal administrations. The state recently moved forward with opening a public consultation for reverse logistics regulation, which should establish the requirement for manufacturers and distributors to prove environmental compliance as a licensing criterion. 5 ANALYSIS AND DISCUSSION The regulation of reverse logistics by state decrees in Brazil represents a step forward in solid waste management, complementing the National Solid Waste Policy (PNRS). With 16 states already adopting specific legislation, there is an effort to adapt national policies to local realities. These decrees are essential for more efficient waste management, allowing each state to create solutions suited to its needs. However, the lack of specific regulations in states such as Santa Catarina highlights gaps, making it difficult to implement reverse logistics systems in a uniform and efficient manner. This lack of uniformity can lead to regional disparities in waste management, compromising national sustainability goals and complicating reverse logistics monitoring and inspection activities. The lack of effective public policies and financial incentives can discourage companies from investing in product return practices, while the scarcity of resources limits the effectiveness of structural actions. Inadequate infrastructure for collection and recycling, combined with a lack of public awareness about correct waste disposal, undermines the performance of collection systems. To address these challenges, a joint effort between government, the private sector and civil society is needed to create practical, innovative and sustainable solutions. Only through an integrated approach will it be possible to overcome obstacles and achieve the environmental and public health objectives of the PNRS. In an analysis of SINIR, it was observed that, despite being an instrument aimed at integrating information from states and municipalities, supporting public policies, inspection
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 22 measures, monitoring targets, and seeking to involve all actors in the production chain, there is a need to improve the quality of the data managed on the platform, since all stakeholders involved in the process have not yet been characterized, especially those who insert the products into the market. There is a low participation of companies and municipalities, and there is a lack of robust sectoral agreements, which leads to the need for investments in technology and standardization of information. Reverse logistics in Brazil presents a complex and constantly evolving scenario, with significant variations in the implementation and effectiveness of waste collection and recycling practices. While the Environmental Company of the State of São Paulo (CETESB) stands out for its rigorous monitoring model and progressive guidelines, other regions still face considerable difficulties in implementing efficient reverse logistics strategies. In Brazil, the National Solid Waste Policy (PNRS) establishes a fundamental regulatory framework, but its effectiveness depends on the capacity for inspection and the commitment of companies to adopt sustainable practices. As noted by Dias et al. (2022, p.45), “the effective application of reverse logistics requires not only robust legislation, but also the mobilization of the stakeholders involved, from consumers to manufacturers”. CETESB exemplifies this mobilization, having implemented regulations that require proof of targets and environmental licensing, resulting in a significant increase in waste collection and the private sector's adherence to sustainable practices. This reality contrasts with the panorama found in states such as Mato Grosso do Sul and Rio de Janeiro, where reverse logistics practices are still incipient. Lima and Silva (2023, p.32) state that “the lack of clear guidelines and an effective inspection system compromises the implementation of reverse logistics, generating a lack of interest on the part of companies in investing in sustainable solutions”. This disparity highlights the urgent need for a more uniform and structured model that can be applied throughout the national territory. Internationally, countries such as Germany and Sweden have stood out in the implementation of reverse logistics systems. Germany, through the Packaging Act of 1991, established a deposit and return system that encouraged the recycling and reuse of materials, achieving recycling rates of over 60% (European Commission, 2021). Similarly, Sweden implemented a bottle and can return system that has contributed significantly to reducing waste and promoting a circular economy (Bridging the gap, 2023). In Brazil, it is necessary to move forward in creating clearer guidelines, defining specific goals, and expanding state regulations in accordance with the PNRS. The public consultation proposed in Santa Catarina, for example, points to significant progress in reverse logistics in
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 23 the state. However, it is essential that this initiative be translated into practical actions that ensure monitoring and environmental compliance by manufacturers and distributors. Furthermore, the implementation of environmental education programs, such as those observed in European countries, can be a crucial factor in raising public awareness and increasing consumer participation in reverse logistics. The formation of partnerships between government, companies and civil society is essential for the success of these initiatives. Ferreira and Almeida (2023, p.28) argue that "collaboration between different sectors is key to developing effective reverse logistics that not only meets legal requirements but also promotes social and environmental responsibility". 6 FINAL CONSIDERATIONS This study aimed to analyze the importance of monitoring in the implementation of reverse logistics in Brazil, highlighting the differences and challenges faced by the responsible agencies. The results indicate that, despite the efforts made, the effectiveness of monitoring actions is still compromised by several limitations, such as lack of rigor, absence of wellstructured specific legislation, lack of engagement of stakeholders involved in the logistics chain and inconsistency in the practices adopted. The relevance of this study is linked to the identification of existing gaps and the proposal of improvements to strengthen monitoring, which is essential for environmental sustainability. However, it is recognized that the lack of accurate data and the inconsistency of adherence to SINIR by all those who hold responsibilities for the life cycle of products are crucial limitations that require more assertive approaches with the aim of achieving not only conceptual but also more feasible maturity. To increase transparency and reliability of data, it is suggested that the annual reports submitted to SINIR be made available in a consolidated format. Conducting the survey and requiring the participation of manufacturers, importers, distributors and traders present in the Federation Units is imperative to enable the adaptation of strategies that increase the participation of those involved in the platform. This can help identify possible discrepancies that currently do not reflect the reality of the data provided. The difficulty in establishing the degree of reliability of the information provided is a challenge, especially considering the possibility of inspections not being effective.
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 24 In this scenario, it is essential to establish methods to verify the veracity of the data presented. This may include conducting independent audits and creating verification mechanisms that ensure the accuracy and integrity of the information. The practices adopted by CETESB, which monitors the activities of companies related to reverse logistics through environmental licensing, have proven to be an effective management alternative. Its progressive guidelines, consolidating a rigorous inspection model, can serve as a reference for other regions, such as the state of Santa Catarina. For future research, it is suggested to investigate the monitoring of regulations related to reverse logistics, strategies to increase the participation of generators in SINIR, and analysis of successful international models in reverse logistics. It is concluded that efficient monitoring is essential to ensure transparency, data reliability and continuous improvement of processes, promoting integrity and sustainability. ACKNOWLEDGMENTS We would like to thank the financial support of the Santa Catarina State Research and Innovation Support Foundation - FAPESC and the Santa Catarina State University - UDESC. REFERENCES Bogdan, R. C. & Biklen, S. K. Investigação qualitativa em educação. Porto: Porto Ed., 1994. 335 p. Brasil. Conselho Nacional do Ministério Público. Gestão de resíduos: estratégias de atuação interinstitucional. / Conselho Nacional do Ministério Público. - Brasília: CNMP, 2022(a). 212 p. il Brasil. Decreto n. 10.936, de 12 de janeiro de 2022. Atualiza e consolida as normas sobre a Política Nacional de Resíduos Sólidos, incluindo diretrizes específicas para a logística reversa. Diário Oficial da União, Brasília, DF, 13 jan. 2022(b). Disponível em: https://www.planalto.gov.br/ccivil_03/_ato2019-2022/2022/decreto/D10936.htm. Acesso em: 30 jan. 2025. Brasil. Decreto n. 11.413, de 22 de fevereiro de 2023. Introduz novos instrumentos no âmbito dos sistemas de logística reversa, como o Certificado de Crédito de Reciclagem de Logística Reversa e o Certificado de Estruturação e Reciclagem de Embalagens em Geral. Diário Oficial da União, Brasília, DF, 23 fev. 2023(a). Disponível em: https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2023/decreto/D11413.htm. Acesso em: 30 jan. 2025. Brasil. Decreto n. 11.414, de 23 de fevereiro de 2023. Complementa o Decreto n. 11.413, de 22 de fevereiro de 2023, detalhando os mecanismos de controle e fiscalização dos sistemas
The Importance of Monitoring Actions in Reverse Logistics: National Overview, CETESB (SP) Success Story and Initiatives in the State of Santa Catarina ___________________________________________________________________________ Rev. Gest. Soc. Ambient. | Miami | v.19.n.4 | p.1-29 | e012026 | 2025. 25 de logística reversa. Diário Oficial da União, Brasília, DF, 24 fev. 2023(b). Disponível em: https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2023/decreto/D11414.htm. Acesso em: 30 jan. 2025. Brasil. Lei n. 12.305, de 2 de agosto de 2010. Institui a Política Nacional de Resíduos Sólidos (PNRS), que estabelece a responsabilidade compartilhada pelo ciclo de vida dos produtos e define a logística reversa como um dos instrumentos para a gestão de resíduos sólidos. Diário Oficial da União, Brasília, DF, 3 ago. 2010. Disponível em: https://www.planalto.gov.br/ccivil_03/_ato2007-2010/2010/lei/l12305.htm. Acesso em: 30 jan. 2025. Bridging the gap. Sweden’s recycling system: A model for circularity. Environmental Policy Review, v. 19, n. 4, p. 123-135, 2023. Carvalho, A. F.; Menezes, D. R.; Pinho, V. G. Políticas públicas e a economia circular: o caso da logística reversa no estado de São Paulo. Revista de Gestão e Sustentabilidade, v. 20, n. 1, p. 123-138, 2021. Cavalcanti, P.; Ferreira, L.; Rodrigues, M. Políticas públicas para a gestão de resíduos sólidos urbanos no Brasil: uma análise crítica. Revista de Administração Pública, v. 53, n. 5, p. 1021-1045, 2019. Cavalcanti, T. P.; Pereira, F. H.; Moura, S. A. Acordos setoriais na logística reversa: avanços e desafios no Brasil. Revista Brasileira de Gestão Ambiental e Sustentabilidade, v. 9, n. 4, p. 198-214, 2019. Cetesb - Companhia Ambiental do Estado de São Paulo. Decisão de Diretoria n. 051/2024/P. São Paulo: CETESB, 2024. Disponível em: https://cetesb.sp.gov.br/wpcontent/uploads/2024/07/DD-051-2024-A-Procedimentos-para-demonstracao-LogisticaReversa.pdf . Acesso em: 15 fev. 2025. Cetesb - Companhia Ambiental do Estado de São Paulo. Decisão de Diretoria n. 076/2018/C. São Paulo: CETESB, 2018. Disponível em: https://cetesb.sp.gov.br/wpcontent/uploads/2018/04/DD-076-2018-C.pdf . Acesso em: 15 fev. 2025. Cetesb - Companhia Ambiental do Estado de São Paulo. Estratégia de implementação da logística reversa no estado de São Paulo. São Paulo, 2025. Disponível em: https://cetesb.sp.gov.br/logisticareversa/logistica-reversa/estrategia-de-implementacaoda-logistica-reversa-no-estado-de-sao-paulo/. Acesso em: 27 jan. 2025. Costa, P. R.; Gonçalves, L. F.; Souza, C. V. O papel da logística reversa na Política Nacional de Resíduos Sólidos. Revista de Gestão Ambiental e Sustentabilidade, v. 10, n. 2, p. 245267, 2021. Couto, M. C. L.; Lange, L. C. Análise dos sistemas de logística reversa no Brasil. Engenharia Sanitária e Ambiental, v. 22, n. 5, p. 889-898, set./out. 2017. Disponível em: <https://www.scielo.br/j/esa/a/S5FHdbHp3ZV6kQHgmFfSSWF/?lang=pt > Acesso em: 13 mar. 2025. Dias, R.; Oliveira, M.; Pinto, J. Logística reversa: desafios e oportunidades no contexto brasileiro. Revista Brasileira de Gestão Ambiental, v. 11, n. 2, p. 40-56, 2022.