On July 10, 2026, Brazil officially published CONAMA Resolution No. 516/2026, introducing the country’s new Hazardous Substances Framework for electrical and electronic equipment (EEE). The regulation establishes mandatory restrictions on ten hazardous substances and creates a new compliance framework that manufacturers and importers must follow before placing products on the Brazilian market.
This resolution marks Brazil’s transition from a previously unregulated chemical restriction framework for electronic products to a mandatory environmental compliance system. While the National Registry platform is still under development, companies should begin preparing their compliance documentation and internal processes ahead of its launch.
What the Hazardous Substances Framework Introduces
The Hazardous Substances Framework establishes concentration limits for ten hazardous substances used in electrical and electronic equipment commercialized in Brazil. These include:
- Polybrominated Biphenyls (PBB)
- Polybrominated Diphenyl Ethers (PBDE)
- Mercury (Hg)
- Cadmium (Cd)
- Hexavalent Chromium (CrVI)
- Lead (Pb)
- Four Phthalates (DEHP, BBP, DBP, and DIBP)
The regulation also establishes phased implementation deadlines instead of requiring immediate compliance for every restricted substance.
Staggered Compliance Timeline
Manufacturers and importers should pay close attention to the implementation schedule established by the resolution.
Immediate requirements
Immediately upon the regulation entering into force:
- PBB ≤ 0.1%
- PBDE ≤ 0.1%
After 180 days
- Mercury (Hg) ≤ 0.1%
Three years after publication
- Cadmium (Cd) ≤ 0.01%
- Hexavalent Chromium (CrVI) ≤ 0.1%
- Lead (Pb) ≤ 0.1%
Four years after publication
Restrictions become applicable for:
- DEHP ≤ 0.1%
- BBP ≤ 0.1%
- DBP ≤ 0.1%
- DIBP ≤ 0.1%
These concentration limits apply to homogeneous materials as defined by the resolution.
National Registry and Self-Declaration of Conformity
Additionally, the regulation creates the National Registry of Electrical and Electronic Equipment with Hazardous Substance Restrictions.
Although the Ministry of Environment (MMA) is still developing the registry platform, the resolution specifies that manufacturers and importers will have one year from the official availability of the system to complete product registration and issue the required Self-Declaration of Conformity (sDoC).
The regulation also permits similar products to be grouped under a single Product Family registration, helping reduce administrative effort.
Furthermore, the Self-Declaration of Conformity must accompany products either:
- Physically within the packaging, or
- Through a digital solution, such as a QR code directing users to the declaration online.
Documentation Requirements
The framework introduces additional documentation obligations.
Manufacturers and importers must maintain a complete technical dossier in Portuguese supporting compliance with the regulation. This documentation, together with the Self-Declaration of Conformity, must be retained for at least five years after the product model is discontinued from the Brazilian market.
Current ANATEL and INMETRO certificates remain legally valid. However, once the National Registry becomes operational and applicable, product registration under the new system will become part of the regulatory framework for market commercialization and importation.
Impact Assesment
Technical Standards? 
Yes
Type Approval & Market Access? Yes
Imports, Customs, Trade, or Market Surveillance? Yes
Spectrum Management? 
No
