By Harshavardhan SPublished: 3 min read

Table of Contents

Brazil RoHS (CONAMA Resolution 516/2026) restricts 10 hazardous substances in electrical and electronic equipment (EEE) sold in Brazil. It's already in force, and unlike EU RoHS, it adds a mandatory national registry and product-by-product self-declarations. Here's when it applies, why it matters, what's required, and how to prepare. 

Field 

Detail 

Official name 

CONAMA Resolution No. 516/2026 

Published / in force 

10 July 2026, Federal Official Gazette 

Applies to 

Manufacturers, importers, distributors, retailers of EEE (wires, cables, spare parts) 

Framework authority 

Ministry of the Environment and Climate Change (MMA) 

Enforcement 

IBAMA and state environmental agencies 

Key deadlines 

All deadlines run from 10 July 2026, the date the Resolution took effect. 

Brazil rohs timeline

Other dates to know: 

  • Exemptions published: MMA's list, procedures, and documentation requirements due 6 January 2027 
  • Registry go-live: not fixed yet; once live, 1 year to register and self-declare 
  • Documentation & marking: enforceable once a self-declaration is issued 
  • Disposal symbol: enforceable 2 years after that 

Spare parts repairing or reusing pre-deadline equipment are excluded, as is equipment under a valid exemption. 

Why it matters 

That “monitor it later” window has closed. 

The substance list isn't the hard part: it matches EU RoHS 2. The hard part is process   a registry and self-declaration per product, with no EU equivalent. Compliant products alone won't save a team lacking a self-declaration workflow, Portuguese files, and a registration plan. 

Non-compliance risk goes beyond fines: administrative, civil, and criminal liability, plus mandatory recall and disposal  

Distributors, retailers, and private-label brands carry extra risk: you must confirm a supplier's self-declaration before selling their product. Rebrand it under your own name, alter something that affects compliance, or skip that check, and you can be treated as the manufacturer, full obligations included. 

What is required 

Scope: finished EEE, wires, cables, and spare parts (repair, reuse, upgrade), the same categories as EU RoHS 2; batteries excluded. 

Substance limits  same as EU RoHS 2: 

Substance 

Limit (by weight) 

Lead, Mercury, Hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, DIBP 

0.1% 

Cadmium 

0.01% 

Mercury is also covered by Federal Decree 9,470/2018 (Minamata Convention); the stricter rule applies. MMA reviews the list every 5 years minimum. 

Registration and self-declaration: Brazil's two big departures from EU RoHS. Register and self-declare individually per product, model, or family before manufacture/import. The declaration travels with the product (or a redirect tool) and goes online too. 

Documentation and labelling: Portuguese technical files, retained 5 years after discontinuation (not launch). Every unit needs Portuguese-language model, batch, serial number, trademark, Brazilian contact address, and manufacturer/importer ID, plus a disposal symbol under reverse-logistics rules. 

Exemptions: MMA grants one if substitution is impossible, an alternative's reliability is unproven, or life-cycle analysis shows more harm than benefit. Renewals: file 18+ months ahead. Denied/revoked: 12–18 month transition. Until MMA's list is out, EU Annex III/IV is a reference only, not a guarantee. 

How to comply

  1. Map substances against your BoM: confirm existing EU RoHS data covers all 10 substances (including the phthalates), then count the SKUs, models, and families needing registration.
  2. Localize technical documentation into Portuguese, with retention running from discontinuation, not launch.
  3. pdate labelling and traceability to Brazil's required fields, and flag products needing the disposal symbol.
  4. Track exemptions against the MMA's published list once available; don't assume EU exemptions carry over.
  5. Prepare for inspection: IBAMA and state agencies can request samples, order testing, and seize non-compliant stock; the liable party covers the costs.

How Regilient can help

The chemistry is rarely the problem. Most EU RoHS-compliant products already meet Brazil's limits the load is registry readiness, self-declarations, and Portuguese paperwork, multiplied across every SKU. Regilient handles that layer:

  • Substance tracking: automatic BoM-level checks against Brazil RoHS thresholds
  • Supplier outreach: automated requests, reminders, validated declarations
  • Self-declarations: generated from BoM data, registry-ready
  • Portuguese documentation: centralised, versioned technical files per product
  • Exemption alerts: flagged the moment the MMA acts on one
  • Disposal marking: SKUs auto-matched to reverse-logistics obligations

Already tracking EU, UK, or China RoHS? The same platform covers Brazil too no parallel process needed.

Book a Regilient demo →

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Brazil RoHS 2026: CONAMA Resolution 516/2026   Deadlines and Requirements

What is CONAMA Resolution 516/2026?
CONAMA Resolution No. 516/2026 is Brazil's RoHS regulation. It was published in the Federal Official Gazette on 10 July 2026 and entered into force the same day. The Resolution restricts 10 hazardous substances in electrical and electronic equipment placed on the Brazilian market and creates a mandatory national registry with self-declarations of compliance.
When did Brazil RoHS come into effect?
Brazil RoHS came into effect on 10 July 2026, the date CONAMA Resolution 516/2026 was published in the Federal Official Gazette. PBB and PBDE restrictions applied immediately from that date. Other substances have phased deadlines running up to four years.
What substances does Brazil RoHS restrict?
Brazil RoHS restricts 10 hazardous substances at the same numerical limits as EU RoHS 2. Lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP and DIBP are limited to 0.1% by weight in homogeneous material. Cadmium is limited to 0.01%.
What are the compliance deadlines under Brazil RoHS?
Deadlines run from 10 July 2026. PBB and PBDE are immediate. Mercury has 180 days. Cadmium, hexavalent chromium and lead have three years, so 10 July 2029. DEHP, BBP, DBP and DIBP have four years, so 10 July 2030.
Do I need to register products under Brazil RoHS?
Yes. Brazil RoHS creates a mandatory National Registry of EEE Subject to Hazardous Substance Restrictions, managed by the Ministry of the Environment and Climate Change. Every product, model or product family must be registered individually before manufacture or import. Manufacturers and importers have one year from the date the registry becomes available to complete registration and issue self-declarations.
Is EU RoHS compliance enough for Brazil RoHS?
No, not on its own. Substance limits are the same as EU RoHS 2, so your product design and supplier substance data transfer well. Brazil RoHS also requires a self-declaration of compliance per product, technical documentation in Portuguese, registration in the national registry, and Brazilian traceability marking. None of these come automatically from EU RoHS.