Published by the Brazilian National Mining Agency (ANM) on July 2, the “Easy Guide – Extraction Register” aims to translate the formal guidelines of ANM Resolution No. 225/2025 into practical orientations.
Published in 2025, the regulation established the rules, requirements, and restrictions for the Extraction Register. The Easy Guide was recently introduced as an instructional manual to guide the completion of electronic forms and the tracking of administrative processes.
1. Outsourcing Limits and Restrictions
Resolution No. 225/2025 sets clear rules regarding public work operations and deposit exploitation:
- Public Work: Must be executed directly by the public agency holding the registration. If the project is tendered and awarded to a private construction firm, the use of the Extraction Register is strictly prohibited.
- Extraction Activity: The public agency may hire a specialized company to extract the mineral material on-site. To do so, the service contract must be formally filed with the ANM accompanied by the required Technical Responsibility Annotation (ART).
- Mineral Allocation: Any commercialization of the extracted material is prohibited. The resource must be used exclusively in the public work designated in the process. Its use in a different project within the same municipality requires a prior application for a registration amendment.
2. Spatial Boundaries and Pre-existing Rights
Defining the requested area requires spatial analysis via SIGMINE:
- Area Limit: The requested perimeter polygon cannot exceed 5 hectares.
- Overlapping Encumbered Areas: If the intended area already has an active mineral right, registration is granted only with the prior and express authorization of the original titleholder. The ANM waives this consent requirement only under exceptional circumstances, subject to technical proof showing the absence of other viable deposits in the region.
3. Environmental Licensing and Deadlines
ANM proceedings run in parallel with the requirements of the competent environmental authority:
- Proof Deadline: The applicant has up to 60 days following the ANM filing to prove that environmental licensing has been requested, and must demonstrate progress every 6 months.
Note: deadlines to fulfill ANM official requests begin upon publication in the Official Gazette of the Union (DOU).
- Start of Extraction: Although the ANM may issue a statement of eligibility while environmental review is ongoing, physical mineral extraction can only begin after the issuance of both the Environmental License and the formal Extraction Register title.
- Extension: If the public work experiences delays, the request to extend the registration must be officially filed prior to its expiration date.
4. Two-Year Transition Period for Regularization
Resolution No. 225/2025 established a two-year transition period for regularizing extraction operations that were already active without a formal title. This timeframe is counted from the date the regulation came into effect (December 1, 2025).
Filing a regularization request does not authorize the continuation of extraction activities: operations must remain strictly suspended until the definitive grant of the registration by the ANM, under penalty of operational stoppage and administrative sanctions for the responsible parties.
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