On 20 July, Brazil's food regulator opened a consultation to let labels move information onto a QR code: the same draft rewrites which ingredients require a printed percentage on the pack

What Anvisa opened on 20 July, and the labeling rule it revises

Anvisa's board approved opening the consultation at its 12th Ordinary Public Meeting of 2026, held on 8 July, and the formal filing followed twelve days later. Public Consultation No. 1,400/2026 proposes three changes to RDC No. 727/2022, the resolution published on 1 July 2022 and in force since 9 October 2022 that sets the labeling rules for every packaged food product sold in Brazil, domestic or imported. First, it sets new calculation, rounding, placement and exception rules for the Quantitative Ingredient Declaration (Declaração Quantitativa de Ingredientes, DQI), the printed disclosure of an ingredient's exact percentage in a product, and states that DQI becomes mandatory whenever an ingredient is highlighted on the label through words, images or graphic elements, or whenever a specific food regulation already requires it. Second, it adds new definitions to Article 3 of RDC No. 727/2022 to let a manufacturer deliver information technology (QR codes and equivalent means) classifies as supplementary through a digital channel, while everything Anvisa treats as mandatory information still has to be printed on the physical label. Third, it revises the rules for irradiated food: the international Radura symbol becomes optional, a clear textual declaration of the irradiation process becomes mandatory on the main display panel with a defined minimum size and position, and the rules for declaring irradiated ingredients used within a compound product are standardized. Comments are open through Anvisa's Participa + Brasil electronic system until 19 October 2026.

The numbers behind a rule revised before its predecessor finished landing

One number is how long interested parties have to comment before Anvisa can finalize the text. One is how recently the labeling rule this draft revises finished phasing in for most of the industry. One is how many separate label rules this single consultation touches at once.

The real subject: the QR code is downstream of a classification test that is still being written

The QR code provision reads, on its own, like a modernization story: Brazil letting technology carry information a printed panel used to have to hold. But the draft does not define supplementary information by exclusion, as whatever is left over once mandatory content is accounted for. It defines mandatory content partly through the DQI trigger test the same document is rewriting: an ingredient highlighted through words, images or graphic elements on the pack now pulls its exact percentage back onto the printed label, no matter how much space a brand hoped to free up for a QR code. A strawberry printed on a yogurt lid, a headline claim naming an ingredient on the front panel, or an image implying an ingredient's presence can each trigger the same obligation. Until Anvisa finalizes where that line sits, a brand does not actually know how much of its current label is even eligible to move. Reading the QR code allowance without reading the DQI trigger test next to it means planning a digital-label migration around a printed footprint that has not been fixed yet.

Why it matters for brands

Any brand selling packaged food into Brazil, global CPG, private label or importer, now has two SKU-level audits to run while the text is still open for comment, not after it is adopted. The first is a highlighting audit: which products name, depict or graphically imply an ingredient on the front panel, since that is what the draft says triggers mandatory DQI, independent of whether the ingredient was already declared elsewhere on the label. The second is a mandatory-versus-supplementary map of everything currently printed, since only the content Anvisa is prepared to call supplementary can legally move to a QR code once the rule is final. Brands that wait for the finalized text to start this classification work are not skipping a step, they are deferring it to a shorter runway: the general food industry only finished adapting to RDC No. 727/2022's original labeling requirements in October 2025, on a 36-month timeline from the rule's entry into force, with small businesses given 48 months and returnable-packaging beverages up to 60. If the current draft keeps a comparable staged timeline for these changes once adopted, as Anvisa's own consultation materials propose, the brands that already know which of their SKUs trigger the new DQI test, and which of their disclosures actually qualify as supplementary, are the ones positioned to use that runway for execution instead of discovery.

Two ways to read 20 July