The Ministry of Agriculture and Livestock (MAPA) in Brazil has said that new protocols will be implemented to further ensure exports of Brazilian beef adhere to EU standards.

It follows an audit by the EU's Directorate-General for Health and Food Safety (DG Sante) carried out in October 2025 and published this week.

The audit took place from October 14-31, 2025 as a follow-up to a 2024 audit of Brazil with the objective to evaluate controls on residues of pharmacologically active substances, pesticides and contaminants in animals and animal products.

The 2024 audit had two recommendations:

To ensure that the validation of analytical methods incorporates a sufficient number of fortification concentrations including the EU level(s) of interest;
Critical to ensure that products from cattle that have been treated with oestradiol for therapeutic or zootechnical purposes are not exported to the EU.

The 2025 audit team comprised two auditors from the European Commission.

The audit was conducted in a hybrid format consisting of remote (videoconference) meetings with the competent authority and visits to selected sites in Brazil.

For the onsite component of the audit, the audit team was accompanied by three representatives from MAPA.

Audit

After the audit in 2024 and the recommendation about the standards expected around the use of oestradiol, MAPA outlined an action plan.

The audit a year later in October 2025, was to inspect the progress of that action plan in addressing the concern.

In the action plan at the time, MAPA committed to align the method validation approach with EU legislation and ensure that the levels of (EU) interest was considered.

The audit team noted that for the vast majority of the analyte/matrix combinations, the sensitivity of the methods was satisfactory.

The audit report states: "Notwithstanding this overall positive finding, in one laboratory, for 1.3% of the analyte/matrix combinations (pesticides only e.g., chlormequat chloride, disulfoton and prothiofos in muscle of bovine, porcine and equine animals, and poultry), the sensitivity of pertinent methods has still exceeded (up to five times) the relevant EU maximum residuelevels (MRLs)."

The laboratory representative explained that this was most likely due to technical limitations of old analytical equipment, and that a public tender had been initiated to purchase more suitable instrumentation.

In relation to the use of the oestradiol hormone, the Association of Auditing and Traceability Certification Companies in Brazil (ABCAR) designed a protocol.

The main objective of the protocol is to ensure adequate traceability of the female bovine animals treated with oestradiol at any time of their life to ensure that only female bovine animals never treated with oestradiol are slaughtered for export to the EU.

Beef

On January 21, 2025, MAPA announced that only female bovine animals not treated with oestradiol, and male bovine animals would be eligible for export to the EU.

Following this, on February 13, 2025, MAPA issued a Circular Letter imposing complete suspension of export to the EU of meat from female bovine animals.

The ministry stated that the resumption of export to the EU of female bovine animal products could be possible only after complete implementation of the new protocol around oestradiol.

The provisional timeframe for the rollout of the protocol declared in the action plan was 12 months.

However, on October 14, 2025, during the opening meeting of the audit, MAPA informed the audit team that on April 3, 2025, MAPA recognised the full operational status of the new oestradiol protocol and resumed export of products from female bovineanimals enrolled in the protocol from that date.

The European Commission stated that this decision constituted a "substantial deviation from the commitments made in the action plan" and had not been communicated to the commission itself.

What is the protocol?

According to the 'Protocol for Exporting Female Bovines' (PEFB), a farm interested in supplying female bovine animals for the EU market must first be listed in the protocol's BD-ABCAR database.

The farm must apply for the listing with a certifying entity (accredited by the ABCAR) of their choice.

A positive enrolment decision may then be made only after a visit on farm by the certifying entity to verify compliance with all requirements of the protocol.

The certification inspections include:

Verification of sanitary management plan;
Controls on oestradiol use;
Capacity to ensure segregation of female cattle based on oestradiol treatment status;
Controls on the movement of female cattle;
Verification of age compliance for incoming female bovine animals.

By the time of the audit in October 2025, there were 13 certifying entities accredited by the ABCAR and authorised to operate across all the states of Brazil.

Once listed in the PEFB, the farm must apply to the certifying entity every time the farm intends to send female bovine animals to slaughter, where meat of which is destined for export to the EU.

The certifying entity must verify the correctness of the information provided and issue a Transaction Certificate when all of the PEFB requirements are complied with.

The receiving slaughterhouse must ensure that the Transaction Certificate accompanied the lot of the female animals and send a copy of the Transaction Certificate to MAPA officials present at the slaughterhouse.

These officials from the Federal Inspection Service (SIF) must then scrutinise it by comparing the Transaction Certificate with the corresponding Animal Movement Permit (GTA) for at least 10% of the female bovine animals, where meat of which is destined for the EU.

During slaughter 100% of the identities of the animals are assessed against the documentation submitted, according to Brazilian authories.

In case of any discrepancies and/or ambiguities, the female bovine animals that presented the discrepancies and/or ambiguitieswill be disqualified from slaughter for the EU.

During the audit process by MAPA officials of farms signed up to the oestradiol protocol database of farms wishing to supply beef to the EU market, "deficiencies" were identified in some cases which were "promptly rectified by the farm".

EU audit

The audit team visited five farms enrolled in the PEFB (protocol) and scrutinised the records of certifying entities supervising the farms.

Of the five farms visited, three declared that they used oestradiol.

The audit team noted that at all three farms, there were comprehensive treatment records consistent with the requirements of the protocol, and handling plans for the use of oestradiol endorsed by the supervising vet.

As required by the protocol, the farms provided to the certifying entity a list of the female bovine animals treated with oestradiol, signed by the supervising vet.

The farms could not provide the audit team with prescriptions for the oestradiol-17-containing veterinary medicinal products observed during the audit, which the EU said is inconsistent with the action plan commitments.

The EU added that this was not noted as a deficiency either by the certifying entity or by the MAPA controls.

At one farm visited, which had declared use of oestradiol, the audit team noted that the MAPA control, carried out on-farm on August 21, 2025, had identified that 179 female bovine animals treated with oestradiol during autumn 2024 had been wrongly enrolled in the PEFB (due to an administrative mistake by the farm).

For 174 of those animals, the supervising certifying entity issued transaction certificates making the 174 animals eligible for slaughter for the EU in May and July 2025 (about nine months after the treatment).

The European Commission outlined that this was not in line with EU requirements.

The audit team visited four slaughterhouses enrolled in the PEFB and requested a full traceability exercise for a significant number of health certificates (about 10 per slaughterhouse) randomly chosen.

The audit team noted that between February 13 and April 2, 2025, the period during which MAPA committed to suspend export to the EU of products from any female bovine animals, a significant number of consignments did contain meat from female bovine animals.

The audit team observed that while sufficient efforts were made to exclude female bovine animals from slaughter for the EU, the certification procedures did not ensure that meat on stock from female bovine animals slaughtered before the start of the PEFB was excluded from the export to the EU.

Conclusions

The EU concluded that while the private protocol for export of female bovines was devised and rolled out as committed to, its functioning at the initial stage of the rollout did not ensure that ineligible products from female bovine animals were excluded from certification for export to the EU.

The competent authority failed to inform the commission about ineligible products supplied to the EU.

"The actions proposed were not fully implemented as committed to," the EU stated.

According to the EU, as a whole, these deficiencies undermine the trust in MAPA’s ability to ensure adequate implementation of the commitments made in the action plan.

Response

In response to the EU's audit, Brazilian authorities stated that the latest version of the protocol added several tools and commands that provide more security to the certification of the farms that supply animals.

They say that such tools provide more robust guarantees on the non-use of oestradiol esters in the females certified under the PEFB.

Only females whose age is no greater than 12 completed months at the moment of their inclusion may be included in the PEFB on those holdings that declare the use of oestradiol.

In the case of those holdings that declare that they do not use oestradiol, beyond the original rule obliging them to identify animals and stipulating ingress onto the holding at an age not greater than 12 months, there is a new determination imposing a maximum age at inclusion of 24 completed months.

The Coordination Office for Traceability, Private Protocols and Third-Party Certification (COPC) in Brazil said the suppression of the possibility of initial stocking balance in holdings that declare the use of oestradiol "eliminates potential errors of the inappropriate certification of females" that, in periods prior to the accession to the protocol, may have been treated with the referred hormone but the treatment has not been recorded correctly.

Prescriptions for oestradiol

The new version of measures adds a specific command for the control of the acquisition of oestradiol-based medications.

The document determines the mandatory filling of the form with: trade name of the product; active ingredient; quantity purchased; date of purchase; purpose of use; establishment of purchase; and invoice number.

The same form requires the attachment of the veterinary prescription, a document required for the purchase of the medication.

Another measure now included is that 20% of holdings that declare the use of oestradiol must be audited annually.