Brazil adopts long-awaited RoHS framework for electrical and electronic equipment (EEE)
BRASÍLIA, Brazil,July 10, 2026 — Brazil has adopted its long-awaited restrictions on hazardous substances in electrical and electronic equipment through CONAMA Resolution No. 516/2026.
The regulation, often described as the “Brazilian RoHS,” restricts ten substances in electrical and electronic equipment manufactured, imported, distributed, or sold in Brazil. It also introduces product registration, self-declarations of conformity, Portuguese-language technical documentation, and supply-chain compliance duties.
EU-style substance restrictions introduced in phases
The regulation establishes concentration limits at the homogeneous-material level for ten substances already restricted under RoHS-style frameworks in the European Union, China, and other jurisdictions.
| Substance | Limit | Compliance date |
|---|---|---|
| Polybrominated biphenyls (PBB) | 0.1% | July 10, 2026 |
| Polybrominated diphenyl ethers (PBDE) | 0.1% | July 10, 2026 |
| Mercury (Hg) | 0.1% | January 6, 2027 |
| Cadmium (Cd) | 0.01% | July 10, 2029 |
| Hexavalent chromium (Cr-VI) | 0.1% | July 10, 2029 |
| Lead (Pb) | 0.1% | July 10, 2029 |
| Bis(2-ethylhexyl) phthalate (DEHP) | 0.1% | July 10, 2030 |
| Benzyl butyl phthalate (BBP) | 0.1% | July 10, 2030 |
| Dibutyl phthalate (DBP) | 0.1% | July 10, 2030 |
| Diisobutyl phthalate (DIBP) | 0.1% | July 10, 2030 |
The limits apply to electrical and electronic equipment operating at nominal voltages of no more than 1,000 volts alternating current or 1,500 volts direct current. Covered products include household appliances, information technology and telecommunications equipment, lighting, consumer equipment, tools, toys, medical and veterinary devices, monitoring instruments, and automatic dispensers.
Products outside the scope
The regulation excludes several categories, including defense and space equipment, large fixed industrial installations, certain transport vehicles, implantable medical devices, and equipment manufactured exclusively for research and development.
Unlike the European Union framework, Brazil also excludes photovoltaic modules and batteries from the scope of this regulation.
Temporary exemptions may be granted where substitution is technically impossible, alternatives are unreliable, or substitution would create greater environmental, health, or safety impacts.
Renewal requests must be filed at least 18 months before an exemption expires. Existing exemptions remain valid while renewal applications are pending. If renewal is denied, companies receive a transition period of between 12 and 18 months.
Registration required before manufacture or import
In addition to restricting hazardous substances, Brazil’s framework introduces a product-registration scheme.
Each product, model, or product family must be registered and linked to an individualized self-declaration of conformity issued by the manufacturer or importer. Registration must occur before manufacture or import, subject to the applicable implementation period.
Companies will have one year from the date the registry becomes available to submit product information and issue the required declarations. The one-year period will begin when the government launches the system, rather than from the publication date of the resolution.
Portuguese technical files and five-year retention
Manufacturers must maintain technical documentation supporting product conformity. Importers must obtain equivalent documentation from foreign manufacturers, and all technical files must be available in Portuguese.
Manufacturers and importers must retain declarations and supporting documents for five years after a product is discontinued. Traceability records must also be maintained for five years after manufacture or import.
Declarations and technical files must be updated when changes to a product, its design, or applicable technical standards affect compliance.
Distributors and retailers have direct duties
Distributors and retailers must obtain the applicable self-declaration before distributing or selling covered equipment and provide it to federal authorities when requested.
Importers, distributors, and retailers may also be treated as manufacturers if they sell products under their own name or trademark, modify products in a way that could affect compliance, or fail to require the declaration from the manufacturer or importer.
Distributors and retailers are not automatically subject to every manufacturer's obligation. However, private-label sales, product modifications, or failure to obtain the declaration can significantly expand their responsibilities.
Declarations must be accessible
The self-declaration must accompany the product or its packaging, either in full or through an accessible digital tool, and must also be available online.
Where the declaration cannot appear on the packaging, the manufacturer or importer must provide it within five business days of receiving a request.
Products must also carry durable Portuguese-language information allowing identification and traceability, including the model, lot or serial number, responsible company, and Brazilian contact details.
Noncompliance may trigger recalls
Manufacturers and importers that identify noncompliance after a product reaches the market must notify the authorities, inform distributors and retailers, stop further sales, and recall affected products.
Public notices may also be required. Products that cannot be corrected must be disposed of appropriately. Companies will therefore need coordinated procedures covering regulatory reporting, sales suspensions, customer communications, and recalls.
Further rules are still coming
Within 180 days of publication of the resolution, the ministry is expected to issue the initial temporary-exemption list, exemption procedures, and minimum technical-documentation requirements.
Resolution No. 516 establishes the primary framework, but important operational details will depend on further government measures.
Implications for industry
The concentration limits will be familiar to companies already operating under EU RoHS. However, compliance with Resolution No. 516 alone may not be sufficient where another Brazilian law imposes stricter controls.
For mercury, companies must assess the limits under Resolution No. 516 alongside Decree No. 9,470/2018, which regulates mercury in products. The more restrictive requirement will apply.
Brazil’s larger compliance challenge lies in its product-level registration, Portuguese-language technical records, five-year retention rules, declaration-access requirements, product marking, and post-market corrective-action duties.
Manufacturers and importers should review their market-entry strategies and determine which party will assume registration and documentation responsibilities. In some cases, manufacturers or importers may prefer to register products directly rather than rely on distributors or retailers to manage these obligations.
Supply agreements may also need to specify responsibility for registration, technical-document sharing, translations, and updates so that each party receives the information needed to comply on time.
Even companies familiar with RoHS requirements in other jurisdictions will need to adapt their documentation to Brazil’s framework or, at a minimum, obtain accurate Portuguese translations.
The greatest implementation challenge may fall on Brazilian distributors and retailers encountering these obligations for the first time. Although the framework is intended to strengthen regulatory oversight and consumer access to compliance information, it will also increase administrative demands and compliance costs across the supply chain.