The General Superintendence of the Administrative Council for Economic Defense (SG/Cade) has officially opened an investigation into alleged anti-competitive behavior within the international fragrance industry. The administrative probe centers on activities that carry significant economic implications for the Brazilian market.
At the heart of the investigation are three companies, Firmenich, Givaudan, and International Flavors & Fragrances, and six current and former executives. The defendants are accused of establishing collusive, anti-competitive agreements explicitly designed to exchange competitively sensitive information with one another. Following the formal initiation of the administrative process, all named defendants will be formally notified to submit their legal defenses.
The investigation relies heavily on evidence secured through Leniency Agreement No. 02/2025, which marks the 115th leniency agreement signed under the umbrella of the Brazilian Competition Defense System. Individuals and companies who signed the agreement stand to receive total immunity from administrative fines, and any pending criminal liabilities related to economic order violations will be entirely dismissed, provided the CADE Tribunal ultimately confirms that all leniency obligations were successfully met.
For those facing conviction, the stakes are remarkably high. If found guilty, the involved corporations face strict administrative fines ranging from 0.1% to 20% of their respective corporate revenues, alongside potential accessory penalties. The individual executives implicated in the scheme face hefty personal fines spanning from R$ 50,000 (approximately 9,780USD)to a staggering R 2 billion (about $391.1 million USD). For company administrators specifically, personal fines will be calibrated between 1% and 20% of the total financial penalty slapped on their respective employers.
Once the SG/Cade concludes its deep dive into Administrative Process No. 08700.011623/2025-99, it will issue a formal opinion recommending either the absolute conviction or the complete dismissal of the case. That final evaluation will be handed over to the upper CADE Tribunal, which holds the definitive authority to hand down a final judgment.