Autocontrole: what Brazil's new decree expects from a kombucha producer
Since October 31, 2025, Decree 12,709/2025 has been the legal base for plant-origin products in Brazil, replacing the old Decree 6,871/2009. For a kombucha producer its central word is one: autocontrole, self-control. You control your own process, document that control, and can show the records when someone asks.
The good news arrives in article 117 itself: self-control programs must be structured "proportional to the economic agent's size and the identified risks". A two-person kombucharia does not need a multinational's binder. It needs a program its own size, one that actually works.
What a self-control program is
It is the documented set of procedures by which you yourself guarantee the safety, identity, quality, traceability and security of what you make (art. 117). The decree explicitly allows building the program on published codes of practice, national and international, and on manuals produced by the sector itself (art. 117, § 4). KBI's Code of Practice, which many kombucha producers already follow, is exactly that kind of base.
The program's seven blocks
Article 119 lists what the program must cover, in documented form. In producer language: a safety policy with a technical responsible and measurable goals; a management system with good manufacturing practice, prerequisite programs, traceability and monitoring; systematized, auditable records of the production process, from raw-material receipt to product dispatch; staff training; sampling and analysis; waste, corrective actions and complaints; and a lot-recall provision.
The third block is the spine. Tea received, sugar received, brew day, readings, packaging, dispatch: every step leaves a dated record, tied to the lot, that an auditor can follow.
Eighteen months on file
One concrete number worth writing down: the information and records that make a lot traceable must stay available to the authorities for 18 months counted from the product's expiry date (or from dispatch, if it has none), per art. 123. Add your kombucha's shelf life to those 18 months and that is how long every record must remain findable. A box of paper ages badly over that span; a searchable system does not.
A recall is not improvised
The program must provide for lot recalls before any problem exists (art. 119, VII). If one happens, it runs at the responsible party's expense, with immediate sales stop and lot segregation (arts. 124 and 125). It is the legal version of what a good producer already practices as a mock recall: knowing, in minutes, which lots and which customers a problem reached.
Small producer, guidance-first inspection
Another article that deserves to be better known: for individual micro-entrepreneurs, micro and small companies, inspection must be "primarily orientational in nature", with a two-visit criterion before an infraction notice, except under imminent sanitary risk (art. 140). The decree is not hunting small producers; it is asking for order. And article 141 says explicitly what inspection verifies: the self-control programs and their records, including electronic records and computerized systems. A digital record is a first-class answer, not a workaround.
A scope note: self-control is not compulsory for primary production and family farming (art. 118). A registered kombucharia is a beverage-processing establishment, and therefore covered. If your own classification is in doubt, the norm and your technical responsible answer that, not a blog.
Where to start
You probably have most of these records already; what changes is their shape. Dated, tied to the lot, covering raw material to dispatch, findable in minutes. It is the same discipline that stands behind the label and the IN 41/2019 parameters. If you produce kombucha in Brazil, the whole path is here: BrauMo for producers in Brazil.
Official source: the full text of Decree 12,709/2025. This text is producer-to-producer orientation, not legal advice: the norm's own text is the reference.
Related reading
- How to register your kombucha with MAPA: the SIPEAGRO walkthrough
- The words you can't put on a kombucha label in Brazil
- Kombucha batch tracking and recall-ready records
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