Brazil’s National Telecommunications Agency, ANATEL, has opened Public Consultation No. 26 concerning a proposed identification system for mobile phones, lithium batteries, and chargers used with mobile phones.
The ANATEL labeling proposal would introduce unit-level authentication requirements intended to strengthen the verification, traceability, and integrity of the identification used for homologated products. Consequently, manufacturers, importers, certificate holders, labeling suppliers, and digital sales channels should review the proposal and assess its potential operational impact.
What the ANATEL Labeling Proposal Would Change
Under the draft procedure, ANATEL’s homologation identification would use a Hybrid Authentication System. This system would combine two elements assigned to each individual product unit:
- A physical security element applied to the product, manual, or packaging, as applicable.
- A linked digital identifier, such as a code, QR code, token, or another individualized digital mechanism.
Both elements would need to be logically associated with the same product unit. Additionally, the digital identifier would be validated through an official database of unique identifiers maintained or authorized by ANATEL.
The proposal establishes principles including unit-level authenticity, digital traceability, broad verification, and protection against reproduction, alteration, or counterfeiting. Therefore, the homologation identification could no longer rely solely on an informational or self-declared marking.
Potential Impact on Manufacturing and Labeling
The proposed framework may require affected companies to adapt their labeling and packaging processes to support individualized identifiers instead of relying exclusively on non-unit-specific applications.
Manufacturers should evaluate whether their production lines can generate, print, apply, and associate a different digital identifier with each product unit. Moreover, internal systems may need to preserve the relationship between the physical security element, the digital identifier, and the relevant homologated product.
However, the consultation does not yet establish the complete technical implementation. A future supplementary Act is expected to define matters such as:
- Physical security technologies and printing or generation methods.
- Graphic layouts, dimensions, and application requirements.
- Digital governance procedures.
- Standardization of the linked digital identifier.
- Integration with automated regulatory verification mechanisms.
The transition schedule will also be established through a supplementary Act.
Verification in Digital Sales Channels
The proposal also addresses products offered through digital commercial channels.
Online listings for products subject to ANATEL homologation would need to allow verification of the product’s regulatory status through a Digital Homologation Identifier linked to ANATEL’s official database.
Digital sales channels would be expected to implement compliance-verification mechanisms. Public authenticity checks could take place through an official ANATEL domain or an authorized public API.
Importantly, the draft does not state that every non-compliant listing would be automatically blocked. Instead, the absence of the required digital identifier could result in communication with the sales channel for verification and appropriate action, including the possible suspension or removal of the specific listing.
ANATEL could also monitor online advertisements through automated mechanisms or institutional cooperation.
Requirements for Manufactured and Imported Products
Once the future transition period has ended, each newly manufactured or imported product unit covered by the procedure would need to comply with the final identification requirements.
This creates a potential impact on market access, post-certification compliance, product traceability, and market surveillance. Nevertheless, the exact transition dates and detailed technical mechanisms remain pending.
Companies should therefore avoid implementing a final technical solution before the supplementary Act is published. Instead, they should begin assessing operational readiness and identify concerns that may need to be raised during the consultation.
Public Consultation Deadline
Industry stakeholders may submit comments through the Participa Anatel platform until:
Deadline for comments: August 26, 2026, at 23:59 BRT
Process number: SEI No. 53500.091936/2025-23
Consultation ID: 20406
Manufacturers, importers, certificate holders, marketplaces, and other affected stakeholders should review whether the proposed unit-level identification model is technically feasible within their current production, data-management, and packaging processes.
Where appropriate, stakeholders may submit comments addressing technical feasibility, system integration, implementation timelines, or the need for an extended transition period.
Organizations assessing the certification and labeling implications of this proposal can learn more about Entirety’s Product Certification Service.
