Exporting machinery to Brazil represents a strategic opportunity for Italian companies. In the first six months of 2023, Italian exports of industrial machinery to Brazil increased by 51%, reaching USD 147 million. However, despite these positive figures, machinery exports to Brazil must be approached with rigorous attention to regulatory compliance, particularly regarding NR-12, the Brazilian regulation governing machinery safety. In this article, we explore the regulation and what Italian companies need to do to ensure a successful export process to Brazil.
Origins and Evolution of NR-12
NR-12 is the Brazilian regulation governing occupational safety in the use of machinery and equipment. It was introduced in 1978 to address the risks associated with industrial machinery in a context of rapid industrialization and increasing workplace accidents.
The regulation defines the minimum safety requirements for machinery and equipment throughout their entire lifecycle: design, manufacturing, importation, use, and maintenance.
In 2010, Ordinance MTE No. 197 of December 17 radically updated NR-12, expanding it from just a few pages to more than 100 and introducing stricter obligations for manufacturers and end users, inspired by European and international standards (ISO, IEC). This revision resulted from a tripartite process involving government authorities, employers, and workers, initiated in 2006. It aligned the regulation with ABNT standards and addressed previous gaps by imposing retroactive compliance requirements.
Subsequently, Ordinance SEPRT No. 916 of July 30, 2019 further modernized the regulation by introducing greater flexibility — such as alternative solutions based on risk assessment — reducing bureaucracy and balancing safety requirements with economic sustainability, particularly for SMEs. Additional amendments, including those introduced by Ordinance No. 915/2019, clarified practical applications without altering the regulation's core principles.
Following the 2010 revision, the regulation became particularly stringent, prohibiting the commercialization and operation of non-compliant machinery in Brazil. This means that every export project to Brazil must incorporate technical compliance from the very beginning.
This is not merely a legal obligation: NR-12 directly influences purchasing decisions made by Brazilian companies, which increasingly prefer suppliers already compliant with the regulation in order to avoid legal risks, production downtime, and penalties.
In this context, compliance becomes a commercial differentiator, transforming a regulatory requirement into a competitive advantage for companies exporting to Brazil.
Technical Compliance and Risk Management: The Role of Expertise
NR-12 requires a structured approach based on three key elements:
- Risk assessment
- Implementation of safety systems
- Technical documentation (manuals, test reports, procedures)
The regulation establishes that risks must be identified during the design phase and that safety systems must be developed according to the state of the art.
Moreover, compliance is not limited to NR-12 alone. There is a strong interconnection with other regulations, such as NR-10 (electrical safety) and NR-33 (confined spaces).
For European companies, this implies conducting a gap analysis between CE regulations and Brazilian requirements, which are often more specific from an operational standpoint.
This is where technical expertise becomes essential: without qualified local consulting support, companies risk exporting machinery that is formally compliant in Europe but unacceptable in Brazil.
Digital Transformation: The Key to Reducing Risks and Costs
The real evolution in the Brazilian export process lies in integrating digital technologies into compliance management.
The combination of technical expertise and digital tools transforms NR-12 compliance into a structured, scalable, and repeatable process, improving the overall efficiency of exports to Brazil.
Today, digital tools allow exporters to:
- Simulate risk assessments using advanced software
- Create digital twins of machinery for preventive verification
- Manage technical documentation in digital and continuously updatable formats
- Monitor operational conditions and safety performance in real time
These tools significantly reduce design errors, compliance adjustment times, and non-compliance costs.
Furthermore, digitalization facilitates communication between European manufacturers and Brazilian customers, improving transparency and accelerating certification processes.
Conclusions
Exporting machinery to Brazil requires method, specialized expertise, and informed decision-making. NR-12 leaves no room for interpretation: if the requirements are not met, the machinery cannot be commercialized or operated in Brazil. The consequences are immediate and concrete: delays, additional costs, unforeseen technical modifications, and even the loss of the order itself.
For this reason, it is essential to involve professionals familiar with the Brazilian regulatory framework from the earliest stages of the project and capable of properly managing risk assessments, technical adjustments, and documentation requirements.
Relying on unqualified intermediaries or approaching the process without local support exposes companies to mistakes that are extremely difficult to correct at later stages.
Proper preparation means avoiding wasted time and resources while ensuring that the export project reaches its destination without obstacles.
Sources:
- Norma Regulamentadora nº 12 – Segurança no Trabalho em Máquinas e Equipamentos
- Santos Júnior, J.R. – Manual de interpretação e aplicação da NR-12