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New formulas quietly multiply on store shelves in Brazil Business valorinternational.txt
Visits to Carrefour and roulette wheel strategiesP?o de A?úcar found 10 brands using “new formula” labels at the minimum font size — Foto: Claudio Belli/Valor Food and consumer product companies in Brazil are increasingly modifying their formulas to adjust for rising costs, shifting consumer habits, and fierce market competition. While such adjustments can be a sign of a dynamic industry, many manufacturers are failing to follow regulatory requirements on how to disclose these changes to shoppers. Brazil’s health regulator ANVISA requires manufacturers to clearly display the phrases “new formula,” “new recipe,” or “new composition” on packaging whenever a product’s ingredient list is altered or when a component becomes more or less relevant in the formulation. Under Resolution No. 727, issued in 2022 by ANVISA’s board, these disclosures must be printed in uppercase bold letters, in a color that contrasts with the background of the packaging. The text must also meet minimum height requirements: two millimeters for standard packaging and one millimeter for labels with less than 100 square centimeters of frontal area, roughly equivalent to 20 cm by 5 cm. Brands tweak recipes, raise prices with little notice to buyers But with packaging sizes shrinking, particularly following the surge in inflation in 2024, many products now fall under this “millimeter rule.” Shelves are filled with miniaturized packs of cakes, cookies, sweets, and coffee capsules that require the smaller one-millimeter font. “We’re seeing two overlapping problems: increasingly smaller packaging and the letter-height rules for labeling new formulas,” said Tamara Correia de Andrade, a food regulation specialist at the Brazilian Institute for Consumer Protection (IDEC). “If companies comply with the regulation, they’re within the law. But the Consumer Defense Code also requires that the information be clear and visible. So if it’s technically compliant but hard to read or barely noticeable, it still violates consumer rights,” she said. Minimal compliance For instance, Bauducco’s Cream Cracker biscuit package lists “new formula” in lowercase letters, contrary to the regulation requiring uppercase, and positions the text subtly in the bottom left corner of the front label. The same package also informs consumers of a recent 17.5% reduction in weight, from 200 to 165 grams. Under the law, such “shrinkflation” disclosures must remain on the packaging for at least six months. In some categories, different batches of the same product carry inconsistent labeling in the same store due to the wave of new and overlapping regulatory instructions issued by ANVISA. At the Carrefour Pamplona store in S?o Paulo, two versions of Unilever’s Brilhante powdered laundry detergent—“Total Hygiene” and “Total Delicacy”—sit side by side with the same weight and price, but with different formats for disclosing formula changes. The “Total Hygiene” label displays “new formula” prominently, while the “Total Delicacy” version features the text in smaller print on the side. That’s because Anvisa’s Instruction No. 243, issued in 2023, updated the minimum font height to 1.5 millimeters (or one millimeter for labels under 10 square centimeters). Unilever said the “Total Delicacy” packaging was updated in April 2025 to meet this rule, while “Total Hygiene” still uses the older 2022 design, which required the text to be 25% of the height of the product name’s font. The company noted that the newer design was only approved in July, and both formats are currently on shelves during a “stock balancing” period. The company reaffirmed its commitment to transparency. “Frequent rule changes are making the shopping experience more confusing for consumers,” said a product manager at a hygiene brand. “While improvements are needed, not every new rule seems to be a step forward.” Limited transparency Earlier this month, visits to Carrefour and P?o de A?úcar stores in western S?o Paulo revealed at least ten companies using the “new formula” or “new recipe” label at the bare minimum required font size, despite having the option to make the information more prominent. Among the compliant brands were Arcor, Bauducco, Colgate, M. Dias Branco, Mococa, Mondelez, Nestlé, Reckitt Benckiser, Sou’i, and Unilever. In one example, M. Dias Branco’s Adria “Tortinhas” cookies displayed “new formula” at the bottom left of the package in a one-millimeter-tall, one-centimeter-long text, within the current legal requirements. In today’s packaging landscape, every square centimeter is contested by marketing, design, and regulatory teams. Because the regulation only mandates font size and style—but not the placement or prominence of the text—it’s often hard for consumers to spot the disclosure at all. “The front panel is extremely valuable space. The cleaner it looks, the better for the brand,” said Leopoldo Leal, a design professor at ESPM. “No one wants to clutter the packaging, but it’s a tug of war, legal teams focus on compliance, while marketing and design teams are concerned with aesthetics and attractiveness.” Short windows for disclosure Manufacturers are also required to display the “new formula” or “new recipe” notice on the front panel for at least 90 days after the change is approved by ANVISA. This is significantly shorter than the six-month requirement for shrinkflation disclosures. Until 2020, brands were only required to show the shrinkflation notice for 90 days. The Ministry of Justice extended this to 180 days during the pandemic, responding to rising prices and further product downsizing. ANVISA said the 90-day window for formula change notices was determined after public consultation and deemed sufficient to ensure visibility. The agency said there are no current plans to extend the requirement, but suggestions can be submitted for inclusion in the 2026–2027 regulatory agenda. For Ms. Andrade of IDEC, more frequent and clearer rule updates are urgently needed. “There are gaps and vague language in the current instructions, and enforcement is spotty. In many cases, brands seem to have some flexibility,” she said. ANVISA noted that with Brazil’s decentralized public health system (SUS) and National Health Surveillance System (SNVS), on-site inspections of food products are handled mainly by municipal agencies, and there’s no centralized national database tracking fines or violations. The agency emphasized that any disclosure of a “new recipe” or “new formula” must be clear, legible, and highlighted on the label to ensure consumers can easily see the change. Brazil’s regulatory landscape for consumer goods has become increasingly complex, with overlapping rules and separate standards for different product segments. In addition to Resolution No. 727 (2022), Resolution No. 421 (2020) also governs the inclusion of “new formula” language for products under ANVISA’s purview, ranging from food and cosmetics to hygiene and cleaning products. Each segment also has its own specific instructions, further complicating compliance. This article was translated from Valor Econ?mico using an artificial intelligence tool under the supervision of the Valor International editorial team to ensure accuracy, clarity, and adherence to our editorial standards. Read our Editorial Principles.
