The Annual Report of Potentially Polluting Activities and Users of Environmental Resources (RAPP) is a fundamental ancillary obligation, intrinsically linked to the TCFA (Environmental Control and Oversight Fee). Established by the National Environment Policy (Law 6,938/81) and regulated by Ibama Normative Instruction No. 22/2021, the RAPP is the main instrument for validating operational regularity in the mineral sector.
1. Applicability and Obligation
The submission of the report is mandatory for all enterprises performing activities listed in Annex VIII of Law 6,938/81. In the context of the mineral industry, this encompasses:
- Almost all mineral extraction operations;
- Processing and transformation activities;
- Enterprises with active registration in the CTF/APP (Federal Technical Registry).
2. The RAPP as a Vector of Inspection Intelligence
From a strategic management perspective, the RAPP functions as an intelligence vector, providing Ibama with crucial supporting data for environmental monitoring and information crossing. The declared data are used to audit the compatibility between the actual operation and the authorizations granted.
3. The Critical Point: Data Consistency (RAPP vs. RAL)
One of the greatest risks for the holder of mining rights lies in the divergence of information provided to different authorities. It is imperative to ensure technical consistency between:
- RAPP (Ibama): Focus on inputs, waste, and environmental control.
- RAL (ANM): Annual Mining Report, focused on production and mineral utilization.
Discrepancies in produced volumes, inputs used, or waste generated can trigger cross-audits and result in severe administrative and fiscal sanctions.
4. Schedule and Operational Procedures
To ensure compliance and avoid fines, the technical staff must strictly observe the following parameters:
- Delivery Period: Between February 1st and March 31st.
- Reference Fiscal Year: The report must strictly report the operational period from January 1st to December 31st of the previous year.
- Submission Channel: Ibama Services System.
- Typology: Attention to filling out the specific forms applicable to each typology of mineral activity developed.
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