By Hemanth sPublished: 2 min read

Table of Contents

Brazil's electronics regulatory landscape has changed. On 10 July 2026, the Brazilian National Council for the Environment (CONAMA) published Resolution No. 516/2026 in the Federal Official Gazette, establishing Brazil's national framework for restricting hazardous substances in electrical and electronic equipment. The Resolution entered into force on the date of publication. This is no longer a draft — it is enforceable Brazilian law.

Progression timeline for context:

  • 8 August 2025: CONAMA opened public consultation on the draft
  • 24 September 2025: consultation closed
  • March 2026: technical committee approved revised text following consultation
  • 10 June 2026: CONAMA plenary approved the Resolution at its 150th Ordinary Meeting
  • 10 July 2026: Resolution No. 516/2026 published and in force

What Is Brazil RoHS?

Resolution 516/2026 applies to electrical and electronic equipment operating at nominal voltages not exceeding 1,000 V AC or 1,500 V DC, including wires, cables, and spare parts intended for repair, reuse, functional upgrade, or capacity enhancement.

Product categories in scope include: household appliances, IT and telecommunications equipment, lighting equipment, consumer electronics, photovoltaic modules, electrical tools, toys, medical devices, and monitoring and control instruments.

Batteries and accumulators are explicitly excluded from scope. Existing ANATEL and INMETRO certificates remain legally valid but do not replace the new environmental compliance obligations under Resolution 516/2026. It aligns with the EU RoHS Directive but includes region-specific timelines, obligations, and exemptions.

This draft is under final review — but its core structure is unlikely to change.

Regulated Substances Under Brazil RoHS

Brazil’s draft RoHS regulation restricts the following 10 hazardous substances, consistent with EU thresholds:

brazil rohs regulated substances.PNG

Brazil RoHS Compliance Timelines: What You Need to Prepare For

  • Mercury: Already restricted under existing Brazilian lighting laws (since 2020)
  • PBB and PBDE: Banned immediately upon final publication of the new RoHS resolution
  • All Other Substances: Grace period of 4–7 years, depending on product category (to be defined in annexes)

Implementation schedules will be defined per product type in upcoming resolutions — monitor CONAMA and INMETRO channels closely.

Regional substance restrictions are easier to manage with RoHS compliance software that helps centralize supplier data, product information, and compliance tracking.

Brazil RoHS Labeling & Documentation Requirements

Resolution 516/2026 imposes obligations across five compliance dimensions:

1. Substance limits: Maximum concentration values by mass of homogeneous material for the ten restricted substances, aligned with EU RoHS thresholds (0.1% general; 0.01% for cadmium).

2. Product registration: Products must be registered in a national database.

3. Self-declaration of conformity: Manufacturers, importers, and distributors must issue a Brazil-specific self-declaration of conformity, distinct from ANATEL or INMETRO certification.

4. Traceability and labelling: Equipment must bear clear information in Portuguese enabling identification and traceability, including model, batch, serial number, trademark, contact address in Brazil, and identification of the manufacturer or importer. Equipment subject to reverse logistics obligations must display a symbol indicating separate disposal.

5. Technical documentation: Product descriptions, model identifiers, BOM, test reports or supplier declarations, and risk assessments must be maintained and made available on request.

Brazil RoHS Market Surveillance and Enforcement

Enforcement operates through a multi-layered market surveillance framework: IBAMA at the federal level, state environmental agencies at the sub-federal level, and additional oversight tied to the national registration database. Non-compliance may result in monetary fines, product withdrawal, import bans, public recalls, and in cases of environmental harm or falsified documentation criminal liability. Compliance timelines and enforcement priorities are being defined through subsequent CONAMA and INMETRO acts.

Brazil RoHS Key Takeaways for Manufacturers & Importers

  • Don’t underestimate Brazil RoHS just because it’s in draft form — it will become enforceable.
  • Align your substance controls with EU RoHS best practices today.
  • Start compiling a centralized technical documentation library for your affected SKUs.
  • Automate compliance tracking across suppliers to reduce risk.

Get Ahead with Regilient RoHS Compliance Automation

Regilient's RoHS compliance software helps manufacturers and importers eliminate compliance uncertainty across markets, including Brazil RoHS under Resolution 516/2026.

Automated supplier outreach & data collection Real-time tracking of hazardous substance levels Brazil-ready declaration & documentation workflows AI-powered alerts for updates & deadlines

Book a demo today and see how Regilient keeps you audit-ready across every market — Brazil included.

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Brazil RoHS Draft Regulation: What You Need to Know to Stay Compliant

What is Brazil RoHS and how does it relate to EU RoHS?
Brazil RoHS is a technical regulation introduced by Brazil's National Council for the Environment (CONAMA) that restricts hazardous substances in electrical and electronic equipment. It closely mirrors the EU RoHS Directive in structure and substance scope, but applies its own region-specific timelines, obligations, and exemptions rather than adopting the EU framework directly. Manufacturers already compliant with EU RoHS have a strong starting point for Brazil, but should not assume automatic equivalence, since documentation, labelling, and enforcement requirements differ.
Which substances does Brazil RoHS restrict?
Brazil RoHS restricts the same 10 substances as EU RoHS: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and the four phthalates DEHP, BBP, DBP, and DIBP. Mercury in lighting products has already been restricted under existing Brazilian law since 2020, ahead of the broader RoHS framework.
What compliance timeline applies under Brazil RoHS?
Mercury: already restricted under existing Brazilian lighting law since 2020 PBB and PBDE: banned immediately upon final publication of the regulation All other substances: a grace period of 4 to 7 years, depending on product category, with exact schedules to be defined in product-specific annexes Manufacturers should monitor CONAMA and INMETRO channels directly for the finalised implementation schedule per product category.
What documentation and labelling does Brazil RoHS require?
Companies must affix hazardous substance labelling on packaging and products, and issue a Declaration of Conformity under Article 12. The supporting technical file should include product descriptions and model identifiers, a full bill of materials, lab test reports or supplier declarations, and risk assessments for restricted substances. These records must be retained for at least 5 years after the product is placed on the market.
Who enforces Brazil RoHS and what are the penalties for non-compliance?
Enforcement is led by IBAMA, the Brazilian Institute of Environment and Renewable Natural Resources, alongside state environmental agencies acting under national environmental law. Violations can result in monetary fines, product withdrawal or import bans, public recalls, and in cases involving environmental harm or falsified documentation, criminal liability.
How does Regilient help manufacturers prepare for Brazil RoHS compliance?
Regilient's agentic sustainability platform supports Brazil RoHS readiness through automated supplier outreach and data collection, real-time tracking of hazardous substance levels across the bill of materials, Brazil-specific declaration and documentation workflows, and AI-powered alerts when CONAMA or INMETRO publish updates or finalise deadlines.