
Naomie Halioua
Co-founder & CRO, AI Research

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
On 20 July 2026, Brazil's health regulator Anvisa (Agência Nacional de Vigilância Sanitária) opened Public Consultation No. 1,400/2026, a 90-day comment window on a draft revision of RDC No. 727/2022, the resolution governing labels on packaged food sold in Brazil. The headline most coverage led with: for the first time, some label information could move onto a QR code instead of being printed. What most coverage did not lead with is that the same draft only allows this for information Anvisa classifies as supplementary, and in the same document, redefines when an ingredient's exact share of a product must appear printed on the pack at all. A brand cannot plan its QR code migration until it knows which of its own ingredients that second rule now catches.
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.
Three nuances that separate signal from noise
01
Only "supplementary" information can move to a QR code
The draft does not let a brand redesign its label around a QR code. It creates a category of information Anvisa treats as movable, and everything outside that category, including a highlighted ingredient's DQI, still has to be printed.
02
The DQI trigger test is being rewritten in the same draft
Whether an ingredient's exact share must be printed now turns on whether it is highlighted through words, images or graphics on the pack. That test, not the QR code allowance, is what a brand has to run against its own SKUs first.
03
This is a consultation, not an adopted rule
Comments close on 19 October 2026. Anvisa still has to review submissions, finalize the text and publish it before any of these three changes, or the compliance runway attached to them, takes legal effect.
1 Jul 2022
RDC No. 727/2022, the resolution this draft revises, is published; it enters into force on 9 October 2022.
Oct 2025
RDC No. 727/2022's own general adequacy deadline closes: most of the food industry had until this point, 36 months from the rule's entry into force, to bring existing labels into compliance.
8 Jul 2026
Anvisa's board approves opening the consultation at its 12th Ordinary Public Meeting of 2026.
20 Jul 2026
Public Consultation No. 1,400/2026 formally opens for public comment.
19 Oct 2026
The 90-day comment window closes.
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.
90 days
the public comment window on Public Consultation No. 1,400/2026, running from 20 July to 19 October 2026 through Anvisa's Participa + Brasil system
~9 months
roughly how long passed between RDC No. 727/2022's own 36-month general adequacy deadline closing, around October 2025, and Anvisa opening a consultation to revise that same resolution
3 label rules
the distinct areas of RDC No. 727/2022 this one draft rewrites at once: the ingredient-quantity trigger test, the mandatory-versus-digital information split, and irradiated-food labeling
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
The narrow read
Brazil opened a consultation to let food labels use QR codes: a routine modernization step, similar to digital-labeling moves already underway in other markets.
The structural read
The QR code allowance only applies to a category the same draft has not finished defining, because the trigger test for one of the most consequential printed disclosures, the Quantitative Ingredient Declaration, is being rewritten in the same document. A brand's actual printed-label footprint, and how much of it can legally move, will not be known until that test is settled.
Sources
- Anvisa (gov.br): "Confira os destaques da 12ª Reunião Ordinária Pública da Diretoria da Anvisa" (8 July 2026)
- Anvisa (gov.br): DICOL 12th Ordinary Public Meeting agenda, Process SEI No. 25351.900108/2026 (8 July 2026)
- Anvisa (gov.br): background document on DQI, use of technology and irradiated-food labeling supporting Public Consultation No. 1,400/2026
- Anvisa (gov.br): official food-labeling page (Rotulagem de Alimentos)
- Anvisa Legis (AnvisaLegis): full text of Resolução da Diretoria Colegiada (RDC) No. 727, of 1 July 2022
- ABRE (Associação Brasileira de Embalagem): "A Consulta Pública nº 1.400/2026 da Anvisa propõe mudanças na RDC nº 727/2022 sobre rotulagem de alimentos"
- Fukuma Advogados & Consultores: "RDC propõe mudanças à Declaração Quantitativa de Ingredientes e sua rotulagem"
- CRN2 (Conselho Regional de Nutricionistas): "ANVISA abre duas Consultas Públicas para modernizar rotulagem de alimentos"
- APAS (Associação Paulista de Supermercados): coverage of RDC No. 727/2022 staged adequacy deadlines (12, 36, 48 and up to 60 months)
Frequently asked questions
What did Anvisa actually propose on 20 July 2026?
Anvisa opened Public Consultation No. 1,400/2026, a 90-day comment window (20 July to 19 October 2026) on a draft revision of RDC No. 727/2022, Brazil's core packaged-food labeling resolution. The draft makes three changes: it sets new rules for when and how the Quantitative Ingredient Declaration (DQI) must be printed, it adds definitions letting supplementary label information be delivered through a QR code while mandatory information stays printed, and it revises irradiated-food labeling, making the Radura symbol optional while requiring a clear textual declaration on the main panel. It is a consultation, not an adopted rule: Anvisa still has to review comments and publish a final text before any of it takes legal effect.
Does this mean nutritional information can now go on a QR code instead of the label?
Not automatically. The draft only allows information Anvisa classifies as supplementary to move to a digital channel; content Anvisa treats as mandatory, which includes a Quantitative Ingredient Declaration triggered by a highlighted ingredient, still has to be printed on the physical label regardless of how much information a brand would rather deliver digitally. Which specific data points ultimately count as supplementary is part of what the consultation is meant to settle.
Why does the ingredient-highlighting rule matter more than the QR code allowance for compliance teams?
The QR code allowance only applies to whatever ends up classified as supplementary, and the draft defines mandatory content partly through the DQI trigger test it is rewriting at the same time: an ingredient named, pictured or graphically implied on the front of a pack now pulls its exact printed percentage back onto the label. Until that test is finalized, a brand does not know how much of its current label is even eligible to move, so planning a QR code migration before running that highlighting audit means building on a printed footprint that has not been fixed yet.
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