Technical Note | Ammunition Traceability in Brazil: Legal Foundations, Institutional Challenges and Humanitarian Implications
DHESARME and Viva Rio present this joint Technical Note with the aim of contributing to the public debate on ammunition traceability in Brazil. The document brings together legal foundations, international references and empirical evidence related to the mechanisms for identifying, monitoring and controlling these materials. The analysis adopts a technical, independent and non-partisan perspective, based on official documents, research and national and international instruments. Its content considers the implications of ammunition circulation for public security, the prevention of armed violence, the protection of civilians and the safeguarding of human rights.
In this Technical Note
Introduction
Ammunition is the element of an arsenal that most directly connects public procurement to lethal violence. A firearm can circulate for decades; ammunition is consumed in seconds. When a casing left at a crime scene bears an institutional marking, it may reveal the agency and lot to which the projectile belonged. When it does not, or when the marking cannot be checked, the investigation loses the main thread connecting the shot to the material’s origin. Ammunition traceability is one component of arms-control and diversion-prevention mechanisms aimed at preventing materials from entering illicit channels. Through the physical identification of ammunition, the recording of purchases and stock management, tracing systems make it possible to reconstruct supply routes and identify possible inconsistencies in the circulation of these materials. Its relevance extends beyond administrative monitoring procedures to dimensions related to criminal investigations, institutional accountability and the protection of fundamental rights. In contexts of armed violence, reliable information also helps clarify the circumstances of violent incidents and identify potential weaknesses in control mechanisms.
In Brazil, the debate on traceability has gained renewed visibility amid controversies surrounding the rules for identifying ammunition purchased by public security institutions. These discussions take place in a context in which audits and independent research have identified limitations in the capacity to record, monitor and retrieve information about firearms and ammunition. The findings of these assessments demonstrate the importance of examining the relationship between existing regulatory requirements and the conditions under which they are implemented. They also highlight the need to understand how record quality affects the ability to identify the origin of materials seized during investigations.
In this context, DHESARME and Viva Rio present this joint Technical Note to set out and discuss the current legal and operational foundations of ammunition traceability in Brazil. The document examines evidence concerning the operation of national control mechanisms and places recent discussions in the context of international instruments for managing conventional ammunition. The analysis considers how these mechanisms contribute to preventing diversion, supporting investigations and producing verifiable information. It also addresses their humanitarian implications, particularly with regard to civilian exposure to armed violence and the protection of human rights.
1. International Context and the Development of Ammunition Management Mechanisms
1.1. Development of International Standards
The development of international instruments for the management of conventional ammunition took place gradually and was initially associated with concerns about the improper storage of surplus stocks. Historically, institutional instruments have focused on weapons themselves, rather than on what makes an object lethal: ammunition. These materials pose risks to human security because of the possibility of accidental explosions, losses, theft and diversion to unauthorised recipients. In 2008, a Group of Governmental Experts established within the United Nations examined the problems arising from the accumulation of these stocks. The group’s report, identified as A/63/182, highlighted the need to improve national storage procedures and develop international technical standards.
The United Nations General Assembly continued its consideration of the issue through Resolution 63/61, adopted in December 2008. The document recognised the importance of international cooperation and encouraged the implementation of the recommendations put forward by the experts. This process contributed to the development of the International Ammunition Technical Guidelines (IATG), prepared under the United Nations SaferGuard Programme. The guidelines provide voluntary references for the safe management of stocks, covering storage, physical security, inventories, transportation, maintenance and disposal. Their application takes differing institutional capacities into account and allows technical procedures to be adapted to each State’s operational circumstances.
This process gradually broadened international understanding of the risks associated with the management of conventional ammunition. Discussions also began to address illicit circulation, the prevention of diversion and the monitoring of materials throughout their life cycle. This approach recognises the relationship between stockpile security, the quality of administrative records and the ability to identify irregular movements. It also helps explain how management difficulties can affect public security and contribute to communities’ exposure to armed violence.
1.2. The Global Framework for Through-life Conventional Ammunition Management
On 4 December 2023, the United Nations General Assembly adopted Resolution A/RES/78/47 on the management of conventional ammunition throughout its life cycle. The resolution received 176 votes in favour, no votes against and five abstentions. Its adoption endorsed the Global Framework for Through-life Conventional Ammunition Management (GFA). The instrument brings together voluntary political commitments organised around fifteen objectives relating to stockpile security, inventory management, the prevention of diversion and the development of international cooperation mechanisms.
The Global Framework covers procedures for marking, tracing ammunition and documenting transfers carried out along the circulation chain. Its approach recognises that risks can arise from manufacture and initial sale through storage and use to final disposal. The effectiveness of control mechanisms depends on the continuity of records and institutional capacity to identify movements, inconsistencies and possible losses. These elements connect administrative management procedures with international concerns about preventing illicit circulation and reducing humanitarian risks.
The voluntary nature of the GFA reflects the diversity of national capacities and existing legal frameworks. Implementation depends on States incorporating the commitments into their domestic procedures, making resources available and developing monitoring mechanisms. In this context, technical cooperation and international assistance are important for countries facing institutional or financial constraints. The General Assembly has kept the issue on its agenda through subsequent resolutions, including Resolution A/RES/80/43, adopted in 2025. The continuation of these discussions forms part of the international process for monitoring the management of conventional ammunition.
1.3. Legal Instruments and Implementation Gaps
The international regime governing conventional ammunition consists of legal instruments with different material scopes and obligations. The Arms Trade Treaty establishes provisions applicable to the export of ammunition for the conventional arms covered by the treaty. The Protocol against the Illicit Manufacturing of and Trafficking in Firearms, Their Parts and Components and Ammunition includes these materials among the measures aimed at combating illicit trade. This instrument supplements the United Nations Convention against Transnational Organized Crime and establishes standards for cooperation among participating States.
Protocol V to the Convention on Certain Conventional Weapons establishes provisions concerning explosive remnants of war. Its content addresses humanitarian risks associated with the persistence of certain explosive materials after the end of hostilities. These instruments contribute to different dimensions of arms control, although they differ in scope and in the coverage of the obligations that apply. The 2023 Global Framework complements these references by addressing conventional ammunition management throughout its life cycle.
The relationship between international commitments and national mechanisms requires consideration of actual implementation conditions. The existence of regulatory provisions is one stage in the development of control systems; their effectiveness also depends on resources, monitoring and record quality. In this regard, monitoring institutional capacities makes it possible to examine how international standards are incorporated into national practice. This analysis also helps identify difficulties related to preventing diversion and retrieving information during investigations.
2. The Brazilian Context and Traceability Mechanisms
2.1. Legal and Institutional Foundations
In Brazil, Law No. 10,826 of 22 December 2003, known as the Disarmament Statute, establishes provisions relating to the registration, sale and control of firearms and ammunition. Article 23, paragraph 1, requires ammunition sold in the country to be packaged in containers identified by a barcode system. This requirement is intended to make it possible to identify the manufacturer and purchaser, as well as other information specified in the regulations. Paragraph 2 establishes specific requirements for purchases made by the agencies covered by Article 6, including identification of the lot and purchaser on the base of the projectiles.
In 2019, presidential decrees changed the categories of firearms and ammunition classified as restricted or prohibited for use, as well as traceability requirements then in force. In 2020, Ordinances 46, 60 and 61 issued by the Army’s Logistics Command were revoked by Ordinance 62; that same year, the government in office revoked Army ordinances that required new ammunition codes. In September 2021, the Federal Supreme Court reinstated these ordinances. Administrative regulations also provide for procedures to identify and mark these materials. Ordinance No. 214-COLOG/C Ex, of 15 September 2021, approved rules relating to the identification of ammunition and packaging within the Army’s Controlled Products Inspection System. These instruments form part of the national regulatory framework and establish procedures intended to link manufactured materials to sales and purchase records. Their application involves maintaining information that can help identify the origin of ammunition and retrieve data during monitoring activities.
Effective tracing depends on the integrity of records and the continuity of information during the distribution, storage and use of materials. Markings on cartridges may make it possible to identify manufacturers, lots and original purchasers, in accordance with the applicable requirements. Reconstructing subsequent stages of circulation requires additional information, including stock-movement records, internal distribution and any transfers. Identifying a lot can guide an investigation, but determining who fired a shot or who is responsible for a diversion requires complementary procedures. Tracing therefore involves linking physical identification features with the administrative systems responsible for preserving information.
2.2. Information Systems, Monitoring and Auditing
Marking ammunition is necessary, but not sufficient. An investigation depends on three linked elements: the marking engraved on the casing; the administrative record connecting the code to the lot, agency and delivery date; and the forensic examination documenting the chain of custody. Traceability also depends on the operation of systems responsible for storing and retrieving information about ammunition sold and purchased. At the federal monitoring level, the Ammunition Sales and Stock Control System (Sicovem) and its identification and tracing submodules are particularly relevant. These include the Personalised Ammunition Identification System (SIP) and the Ammunition Packaging Tracking System (Sirem). These mechanisms were examined by the Federal Court of Accounts during an audit of the control of firearms and ammunition under the responsibility of the Brazilian Army.
Proceeding TC 007.869/2023-1, which resulted in Decision No. 949/2024, analysed aspects of monitoring carried out between 2019 and 2022. The audit identified problems relating to system governance and the quality of available records. Among its findings, the Court recorded inconsistencies in information used to identify purchasers and monitor ammunition transactions. It also examined issues relating to system administration and the institutional capacity to ensure the integrity of stored data.
Among its determinations, the Federal Court of Accounts required the Army Command to take steps to grant duly designated Federal Police officers access to the Sicovem, SIP and Sirem systems. The decision also included measures relating to information management and the development of mechanisms to monitor record quality. These determinations demonstrate the importance of coordination between institutions responsible for oversight and investigation. The availability of up-to-date and consistent information is an important condition for identifying possible irregularities and reconstructing circulation routes.
The audit findings demonstrate the importance of examining how traceability systems operate in practice. Record quality, compatibility between databases and the preservation of historical information affect the ability of the competent authorities to consult them. Identifying inconsistencies also depends on verification procedures and mechanisms capable of detecting incomplete or incompatible information. These elements form part of the administrative structure needed to monitor ammunition circulation and enable institutions to exercise their oversight powers.
2.3. Evidence on Ammunition Circulation and Possible Diversion
The study “Where Does the Shot Come From?”, conducted by the Sou da Paz Institute, provides evidence on the origin of ammunition seized in investigations associated with the Comando Vermelho criminal organisation. The survey examined 31,699 cartridges from 29 seizure cases carried out between 2018 and 2025. According to findings released in 2026, 40.9% of the factory-original cartridges analysed were manufactured in Brazil. Among this Brazilian-made ammunition, 51.9% bore markings indicating that it had originally been purchased by military or public security institutions. These findings help identify characteristics related to the materials’ origins and raise questions about the mechanisms responsible for monitoring their circulation.
The study identified more than one hundred traceability codes on the Brazilian-made ammunition examined, but was able to link only 34 of them to the institutions that originally purchased it. This difference reveals limitations in retrieving information and reconstructing supply routes. Identifying codes can establish links to particular purchases, provided that reliable records are available. When such information is incomplete or cannot be retrieved, investigative capacity may be compromised. The findings demonstrate the importance of linking physical markings to the systems responsible for storing the corresponding data.
The presence of ammunition originally purchased by public institutions among seizures associated with criminal organisations also raises questions about possible diversion channels. Identifying these routes requires examination of purchase, distribution, storage and use records, alongside other investigative information. The findings presented relate to the specific set of cases analysed and do not represent an estimate of all illicit ammunition circulating in Brazil. They should be interpreted in light of the sample’s characteristics and the study’s methodological limitations.
The survey also draws attention to the unequal availability of information on seized ammunition across Brazilian states. The absence of standardised public records makes territorial comparisons difficult and limits the identification of possible circulation patterns. This also affects the ability to monitor changes in ammunition diversion and assess the results of oversight mechanisms. In addition, oversight of the administrators of firearms and ammunition systems, such as Sigma, is crucial. According to a report by Intercept Brasil, an Army major used the Military Firearms Management System (Sigma) to register firearms and ammunition of unknown origin and subsequently divert them. The scheme was based on the falsification of documents relating to seized firearms and ammunition. In total, 1,200 rounds of ammunition and seven firearms had been seized. Producing consistent data contributes to understanding armed violence and identifying issues requiring institutional investigation.
There is also a question of scale. Very large lots make markings less informative. The Federal Public Prosecutor’s Office in Paraíba identified old lots containing more than 10,000 rounds with the same code, some containing more than one million, making an effective investigation into their origin unfeasible. An Army ordinance from 2004 already provided for lots of no more than 10,000 rounds, but the Federal Public Prosecutor’s Office argues that marking technology could be used for much smaller lots.
3. Recent Debate on Ammunition Identification in Brazil
In October 2026, the identification of ammunition purchased by public security institutions once again became part of Brazil’s public debate. The controversies involved legislative proposals, public statements and different interpretations of the effects of potential changes to marking rules. A report published by Folha de S.Paulo on 20 October 2026 addressed claims concerning the possible removal of requirements to identify these materials. The discussion brought public attention to questions about the ability to reconstruct the origin of ammunition and identify possible points of diversion.
A technical analysis of these controversies requires consideration of the content of the proposed regulatory measures and the conditions under which they would be implemented. It also requires distinguishing physical marking requirements from the administrative procedures used to record production, sale and distribution. Packaging codes, markings engraved on cartridges and electronic systems perform related but different functions. Understanding these distinctions makes it possible to examine the operational effects of potential changes without presuming outcomes that depend on the wording and implementation of the measures under discussion.
Assessing changes to identification procedures also involves considering the availability of information used by the competent authorities. The ability to retrieve manufacturing, purchase and distribution records affects the reconstruction of the routes taken by materials found during investigations. In this context, analysis should consider the coverage of existing systems, data integrity and institutional monitoring capacity. Documenting these characteristics contributes to an evidence-based debate on ammunition management and its implications for public security and civilian protection.
4. Humanitarian Implications of Ammunition Traceability
Armed violence has consequences that extend beyond the direct victims of gunfire, affecting families, communities and institutions responsible for safeguarding fundamental rights. Deaths, permanent injuries, displacement, the interruption of educational activities and restrictions on movement are among the impacts associated with continued exposure to violence. In some territories, these incidents also make it harder to access healthcare, social assistance and other essential services. The humanitarian disarmament perspective recognises the need to understand these effects through the experiences of affected populations, including children and adolescents.
In this context, traceability mechanisms can help investigate the circumstances of violent incidents and recover information about the materials used. Identifying their origin can guide investigative steps concerning ammunition circulation and possible inconsistencies in institutional records. These procedures can also provide evidence for determining responsibility and understanding factors associated with the availability of materials in illicit channels. Their contribution depends on the preservation of physical evidence, the quality of information and complementary forensic and investigative analysis.
The murder of Marielle Franco and Anderson Gomes, which took place in March 2018, is among the Brazilian cases in which information related to the ammunition used received attention during the investigation. The episode demonstrates the importance of preserving material records when reconstructing complex investigative circumstances. In the 2011 murder of Judge Patrícia Acioli in Niterói, the ammunition found at the scene made it possible to identify the origin of the projectiles: they were bullets purchased by the Rio de Janeiro Military Police and diverted from the São Gonçalo Battalion. Eleven police officers were convicted. The case of Ana Clara also returned to public attention. The five-year-old girl was killed by a military police officer with a rifle shot. The corporal’s defence argued that there had been an exchange of fire with armed criminals. However, ballistic analysis concluded that the ammunition bore markings identifying the police unit. In addition, no pistol casings or other traces substantiating the alleged shootout were found. Identifying the origin of ammunition can help clarify certain stages of its circulation, subject to the limits of the available evidence. Establishing responsibility requires an integrated analysis of different items of evidence and compliance with the applicable legal procedures.
From a humanitarian perspective, traceability is relevant to producing information about the risks associated with the illicit circulation of ammunition. Such data can support investigations into incidents of armed violence and help identify weaknesses in control mechanisms. Understanding supply routes can also inform studies of communities’ exposure to violence and its social consequences. Ammunition management is therefore part of a broader discussion about civilian protection, access to justice and the safeguarding of human rights.
5. Links Between International Commitments and the National Context
Brazilian legislation corresponds to objectives established by the Global Framework for Through-life Conventional Ammunition Management, particularly with regard to material identification and purchase records. Ordinance No. 214-COLOG/C Ex, issued in 2021, predates the adoption of the GFA and serves as a national regulatory reference for ammunition-marking procedures. The relationship between these instruments makes it possible to examine how Brazilian mechanisms align with practices covered by international standards. This analysis must also consider implementation conditions and the ability of systems to produce reliable information.
Assessing international commitments involves aspects related to record coverage, oversight and data retrieval. A tracing system depends on coordination between physical marking, documentation, inventories and investigative procedures. Identifying the origin of a particular item presupposes that the corresponding records have been preserved and can be consulted by the competent authorities. This capacity also depends on up-to-date information and mechanisms for checking inconsistencies as materials circulate.
The International Ammunition Technical Guidelines and the commitments established by the GFA provide reference points for examining these different dimensions of management. International cooperation can contribute to the exchange of experience, technical training and improvements to information systems. These mechanisms are particularly relevant where administrative or financial constraints hinder the development of control procedures. In Brazil, an integrated analysis of existing rules, audits and research on seized ammunition helps identify issues relating to the operation of national mechanisms.
Final Considerations
Ammunition traceability is one of the mechanisms used to monitor the circulation of controlled materials and produce information about their origin, distribution and possible diversion. In Brazil, the Disarmament Statute and its regulations establish identification requirements that form part of the regulatory infrastructure intended to support these procedures. Audits conducted by the Federal Court of Accounts and research carried out by civil society organisations help assess the actual conditions under which these mechanisms operate. Their findings demonstrate the importance of record quality, information availability and coordination between institutions responsible for oversight and investigation.
Internationally, the development of the IATG and the adoption of the Global Framework for Through-life Conventional Ammunition Management have broadened the technical and political references for managing these materials. The instruments include measures intended to secure stockpiles, prevent diversion and monitor ammunition throughout its life cycle. Recent controversies over identification rules in Brazil reinforce the need for documentary analysis that considers the operational effects of the proposals under discussion. Such assessments depend on understanding existing regulatory requirements and the institutional conditions necessary to retrieve records.
From a humanitarian perspective, the availability of reliable ammunition information contributes to the investigation of armed violence and the identification of possible irregularities. Reconstructing the routes taken by these materials can provide evidence to help understand their circulation and the risks associated with civilian exposure. Consolidating this knowledge depends on continued data production, oversight of existing procedures and institutional access to the necessary information. In this sense, traceability is a technically significant component of conventional ammunition management and of understanding the humanitarian impacts of armed violence.
Dhesarme - Brazilian Action for Humanitarian Disarmament and Viva Rio
23 October 2026
Technical Team: Fernando Fiala, Giovanna Rezende, João Vitor Mercês (Dhesarme), Yafa Miriam Benyosef and Yan Grzybowski Abu Assef (Viva Rio).
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