The EU–Mercosur Secondary Raw Materials Evidence Series is a set of six linked technical records, published on 27 October 2026 with DOIs on Zenodo. It addresses one commercial question: what must a European recycler, trader or buyer be able to read, trust and defend before accepting secondary feedstock from a Brazilian supplier? One hub sets out the gap; five spokes cover shipment legality, origination due diligence, the interim trade agreement, an operational chain-of-custody case and a scoring instrument.
The series is methodology and reference. It is not legal, customs or tax advice, not an audit, certification or compliance determination, and not a guarantee of buyer acceptance. Every substantive claim in the records is tagged as Fact, Interpretation or Hypothesis.
Why the question is now commercial
European demand for documented secondary feedstock is being written into regulation, while the Brazilian documentary trail that would support it is uneven. Three rules frame the exposure:
Recycling benchmark
The Critical Raw Materials Act, Regulation (EU) 2024/1252, sets a 2030 benchmark of 25% of EU annual consumption of strategic raw materials from recycling.
Magnet disclosure
Under Article 29 of the same Regulation, products containing permanent magnets above the set threshold must disclose their recycled content once the delegated rules apply. Recycled-content claims need evidence behind them.
Shipment rules
Regulation (EU) 2024/1157 on shipments of waste applies from 21 May 2026, and all e-waste moves under Basel prior informed consent since 1 January 2025. A shipment without the consent chain is a legal problem, not a paperwork delay.
On the supply side, the Global E-waste Monitor 2024 records 3% documented collection of the e-waste generated in Brazil. Volume exists; buyer-readable provenance is the scarce part. The interim EU–Mercosur trade agreement, provisionally applied since 1 May 2026, changes tariff and market-access terms. It does not create documentary provenance: waste-shipment, due diligence and data obligations remain with supplier and buyer.
The six records
EMS-01 · Hub
The EU–Mercosur Secondary Feedstock Evidence Gap. Maps what EU rules require, what the Brazilian chain documents, and where the two do not meet. Proposes an expected-evidence-cost structure for buyers.
Use it to: size the gap before committing to a sourcing route.
EMS-02 · Shipment chain
Shipping E-waste and Magnet-Bearing Components from Brazil to the EU. The Basel–Ibama–Waste Shipment Regulation evidence chain after 21 May 2026, with an ordinal shipment-legality-risk indicator.
Use it to: check whether a proposed shipment can move lawfully.
EMS-03 · Due diligence
Origination Due Diligence for Brazilian Secondary Feedstock. A 41-question protocol in six blocks, each question with the evidence expected and the red flag it tests.
Use it to: run supplier qualification before the first contract.
EMS-04 · Trade agreement
The EU–Mercosur Interim Trade Agreement and Critical Raw Materials. What provisional application since 1 May 2026 changes, and what it leaves to supplier evidence.
Use it to: separate tariff benefit from evidence obligations in a business case.
EMS-05 · Operational case (PT)
Cadeia de custódia documental na destinação de eletroeletrônicos corporativos. How Brazilian corporate e-waste destination is documented, using the operation described by Ecobraz Emigre as the case. English summary included.
Use it to: know what can and cannot be verified remotely.
EMS-06 · Scoring instrument
Brazil Secondary Feedstock Evidence Readiness Instrument (BSF-ERI v1.0). Converts the EMS-03 protocol into a weighted score with six domains, four gates and four decision bands.
Use it to: decide ready, conditional, remediate or do not proceed.
How a European buyer uses the series
- Frame the exposure. Read the hub (EMS-01) and decide which rules touch the material and the product it ends up in.
- Qualify the supplier. Send the 41 questions of EMS-03 and collect the evidence each one names.
- Test the shipment. Check the consent and documentation chain in EMS-02 before any sample or lot moves.
- Score and decide. Grade the file with BSF-ERI (EMS-06): the gates stop a weak file regardless of the total score.
Who it is for
European recyclers and traders
Sourcing e-waste, magnet-bearing components or recycled metals from Brazil and needing a defensible qualification file.
Procurement and compliance teams
Inside companies that must back recycled-content or due diligence statements with supplier evidence.
Brazilian suppliers
Preparing to answer European buyer questions with documents, not declarations.
Public, versioned and citable. All six records are open access under CC BY 4.0, linked to each other on Zenodo and to the author's ORCID record (0009-0001-8072-6287). The series builds on the EU-Brazil Supplier Evidence Gap report and the Supplier Evidence Maturity Model (SEMM). A DOI makes a work identifiable and retrievable; it is not peer review, regulatory approval or institutional endorsement.
What the series does not do
- It does not state that any operator, shipment or material is compliant.
- It does not set prices or value for any material, and quotes no market prices.
- It does not replace the competent authorities: Ibama in Brazil and the authorities of dispatch, transit and destination under the Waste Shipment Regulation.
- Regulatory status is stated as at 27 October 2026 and must be checked against EUR-Lex and official sources at the time of use.
Questions buyers ask
Does the EU–Mercosur agreement remove the need for supplier evidence?
No. The interim agreement changes tariff and market-access terms. Waste-shipment consent, due diligence and data obligations remain with the supplier and the buyer. EMS-04 sets out the distinction.
Can e-waste be shipped from Brazil to the EU?
Only through the prior informed consent procedure: since 1 January 2025 the Basel Convention amendments bring all e-waste under it, and Regulation (EU) 2024/1157 applies to shipments into the Union from 21 May 2026. EMS-02 maps the documents a buyer should expect to see.
Is a BSF-ERI score a certification?
No. It is an advisory grading against a published method. A Ready band means the evidence is sufficient to proceed to standard commercial and legal review; it is not a compliance determination or a guarantee of buyer acceptance.
Does a Brazilian destination certificate (CDF) cover exported material?
No. Under the Brazilian national waste manifest system, the export manifest issues no domestic Certificate of Final Destination. Proof of final destination for exported shipments rests on the Basel documents and the recovery facility's certificate. EMS-02 and EMS-05 cover this.
Assessing a Brazilian secondary feedstock supplier? Send the supplier file or the buyer request you are working on. We apply the EMS-03 protocol and the BSF-ERI score and return the priority evidence gaps and the recommended next step.
Start the scope assessment →All records: Publications and technical records · Method: SEMM · Context: For European buyers · Knowledge base · Author: Marcio Villanova