Brazil’s National Council for the Environment (CONAMA) issued Resolution No. 516, establishing an EU RoHS-style regulatory framework that restricts ten categories of hazardous substances in electrical and electronic equipment (EEE), introduces a national registration/self-declaration system, and sets marking and supply-chain compliance duties.
What Happened
On July 10, 2026, CONAMA issued Resolution No. 516, modeled closely on the EU RoHS Directive. It sets maximum concentration limits for ten hazardous substance categories in homogeneous materials within EEE, cables, and spare parts, and establishes a phased compliance transition, a national registration system, and detailed marking, documentation, and recall obligations.
What’s New
- PBB/PBDE: 0.1% limit, immediate.
- Mercury: 0.1% limit, 180 days after entry into force.
- Cadmium: 0.01% limit, 3 years after entry into force.
- Hexavalent chromium and lead: 0.1% each, 3 years after entry into force.
- Four phthalates DEHP/BBP/DBP/DIBP: 0.1% each, 4 years after entry into force.
- New National Registration System: mandatory pre-registration per model/product family before production or import.
Key Dates & Compliance Deadlines
CONAMA Resolution No. 516 published and took effect.
180 days after entry into force.
3 years after entry into force.
4 years after entry into force.
Enterprises must complete national registration within 1 year of system launch.
Affected Industries
Electrical and electronic equipment manufacturers, importers, distributors, and retailers selling into Brazil. Excludes defense/military, aerospace, large stationary industrial equipment, road vehicles, implantable medical devices, fixed solar PV modules, batteries, and R&D-only equipment.
Who Is Affected
Manufacturers and importers (full compliance/documentation/traceability duties); distributors/retailers (must obtain supplier compliance declarations before sale); private-label sellers or unauthorized modifiers (deemed manufacturers with full obligations).
Substances / Products in Scope
PBB, PBDE, mercury, cadmium, hexavalent chromium, lead, and four phthalates (DEHP, BBP, DBP, DIBP) — the same ten-substance list as EU RoHS.
Prohibitions, Restrictions & Exemptions
Concentration limits per substance phased in over 180 days to 4 years; retroactive application excluded for products designed/manufactured before the relevant transition period; temporary exemptions available on application, renewable 18 months before expiry.
What Companies Should Do
- Conduct supply-chain screening against the ten restricted-substance limits as early as possible.
- Plan for phased 180-day to 4-year transition windows by substance category.
- Prepare Portuguese-language technical documentation (retained 5 years post-market withdrawal) and traceability records.
- Complete national pre-registration once the system launches, within the 1-year enterprise compliance window.
- Update product/packaging marking to include required Portuguese labeling and the reverse-logistics wheeled-bin symbol.
This is a major new compliance regime for EEE exporters to Brazil — private-label importers should note they are deemed manufacturers and bear full obligations; the multi-year transition windows provide planning time, but registration, documentation, and marking preparation should begin now.
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