Brazil has introduced a mandatory compliance framework for hazardous substances in electrical and electronic equipment. CONAMA Resolution No. 516/2026 was published on July 10, 2026. It sets concentration limits for ten substances. It also creates new registration, documentation, traceability, and self-declaration duties.
The Brazil RoHS framework follows CONAMA’s approval of the proposal on June 10, 2026. The final resolution is dated July 8, 2026. It entered into force on the date of publication.
What the Brazil RoHS Framework Changes
Covered electrical and electronic equipment must meet the applicable hazardous-substance limits. Otherwise, the products cannot be manufactured, imported, distributed, or commercialized in Brazil.
The requirements also cover certain wires, cables, and replacement parts. However, the resolution includes defined exclusions and allows temporary exemptions for specific applications.
Existing ANATEL and INMETRO certificates remain legally valid. However, they do not replace the new environmental compliance obligations. Manufacturers and importers must also complete the required registry and self-declaration procedures.
Phased Restrictions for Hazardous Substances
The restrictions will apply through a staggered implementation schedule:
- Immediate: PBB and PBDE are limited to 0.1% in homogeneous materials.
- After 180 days: Mercury is limited to 0.1%.
- After three years: Cadmium is limited to 0.01%.
- After three years: Lead and hexavalent chromium are limited to 0.1%.
- After four years: DEHP, BBP, DBP, and DIBP are each limited to 0.1%.
Additionally, another Brazilian regulation may already control one of these substances. In that case, companies must follow the stricter requirement.
National Registry and Self-Declaration Requirements
The resolution creates a National Registry for covered electrical and electronic equipment. The Ministry of Environment and Climate Change will establish and regulate the system.
The registry platform is still under development. Therefore, the one-year registration period has not yet started. That countdown will begin when the government makes the system publicly available.
Registration will be mandatory before covered products are manufactured or imported into Brazil. Each equipment item, model, or product family must be registered.
The regulation allows companies to group similar models as a product family. This option may reduce registration work and administrative costs. However, the grouped products must meet the resolution’s product-family criteria.
After registration, manufacturers or importers must issue a Self-Declaration of Conformity. The declaration must confirm compliance with the substance restrictions or an applicable exemption.
The declaration must also accompany the product packaging. Companies may include the complete document or use a digital redirection tool. For example, a QR code may direct consumers to the electronic declaration.
Documentation and Traceability Obligations
Manufacturers and importers must maintain the required technical documentation in Portuguese. They must also provide it to the competent federal authority when requested.
The documentation must support the accuracy of the Self-Declaration of Conformity. However, the Ministry will define the minimum technical documentation through a separate regulatory act.
Companies must retain the declaration and technical records for at least five years. This period begins when the product is discontinued in the Brazilian market.
Moreover, covered equipment must include clear identification and traceability information in Portuguese. The information may include the model, lot number, serial number, manufacturer, or importer.
Direct marking may not always be technically possible. In those cases, the information may appear on the packaging or accompanying documents. A permitted digital redirection tool may also be used.
The resolution also introduces federal inspection and market-surveillance powers. Authorities may request documents, collect product samples, and verify restricted-substance concentrations. Testing may be required when authorities identify possible irregularities.
Companies should now review product materials, supplier declarations, technical files, and registration strategies. They should also monitor the launch of the National Registry.
Impact Assesment
Technical Standards? 
Yes
Type Approval & Market Access? Yes
Imports, Customs, Trade, or Market Surveillance? Yes
Spectrum Management? 
No
