On 10 July 2026 Brazil published CONAMA Resolution No. 516/2026, restricting the use of certain hazardous substances in electrical and electronic equipment manufactured, imported, distributed and sold in Brazil. The new requirements mirror the European RoHS Directive and set maximum concentration limits for ten hazardous substances in homogeneous materials.

Restricted substances and timetable

Substance  |  Maximum concentration  |  Compliance deadline

Polybrominated biphenyls (PBB)  |  0.1%  |  10 July 2026

Polybrominated diphenyl ethers (PBDE)  |  0.1%  |  10 July 2026

Mercury (Hg)  |  0.1%  |  6 January 2027

Cadmium (Cd)  |  0.1%  |  10 July 2029

Hexavalent chromium (Cr-VI)  |  0.1%  |  10 July 2029

Lead (Pb)  |  0.1%  |  10 July 2029

Bis(2-ethylhexyl) phthalate (DEHP)  |  0.1%  |  10 July 2030

Butyl benzyl phthalate (BBP)  |  0.1%  |  10 July 2030

Dibutyl phthalate (DBP)  |  0.1%  |  10 July 2030

Diisobutyl phthalate (DIBP)  |  0.1%  |  10 July 2030

Which products are affected?

The resolution has broad scope and applies to electrical and electronic equipment rated at not more than 1,000 V AC or 1,500 V DC, including their components.

Examples of products covered include:

· Telecommunications equipment such as smartphones, routers, access points, modems, gateways, IoT devices and other products that generally require ANATEL approval;

· IT equipment such as computers, laptops, monitors, servers and related equipment;

· Household appliances and other electrical equipment;

· Electrical and electronic medical devices and in vitro diagnostic equipment;

· Lighting equipment;

· Electrical and electronic tools;

· Monitoring and control instruments;

· Consumer electronics;

· Toys and electronic sports and leisure equipment;

· Photovoltaic modules, subject to the exceptions set out in the resolution; and wires, cables, components and replacement assemblies.

Which products are excluded?

CONAMA Resolution No. 516/2026 also provides for specific exclusions, for example:

· Equipment intended exclusively for national defence and security;

· Equipment designed to be sent into space, together with ground equipment required for the operation of satellites and space systems;

· Large-scale stationary industrial equipment and installations;

· Certain means of transport;

· Professional non-road mobile machinery;

· Implantable electronic medical devices;

· Batteries and cells as products in their own right;

· Certain photovoltaic modules installed as part of a permanent solar system;

· Equipment designed solely for research and development and supplied only on a business-to-business or institutional basis.

Does this affect ANATEL or INMETRO certification?

At this stage, CONAMA Resolution No. 516/2026 does not directly change the existing ANATEL or INMETRO certification procedures.

ANATEL/INMETRO certification and CONAMA hazardous substances compliance should therefore be treated as two separate regulatory requirements.

However, many products subject to ANATEL or INMETRO requirements — including telecommunications equipment, IT equipment, household appliances and electrical or medical devices — also fall within the scope of CONAMA Resolution No. 516/2026.

Products may therefore need to meet both the applicable ANATEL/INMETRO requirements and the new CONAMA environmental requirements before being placed on the Brazilian market.

What do manufacturers and importers need to do?

The resolution establishes a National Register of Electrical and Electronic Equipment subject to Restrictions on Hazardous Substances, to be implemented and supervised by Brazil's Ministry of the Environment and Climate Change (MMA).

All applicable equipment, models or product families must be registered, and the responsible Brazilian manufacturer or importer must issue a self-declaration of conformity.

The MMA registration information will include:

· Identification of the manufacturer and the Brazilian importer;

· Identification and traceability information for the product, model or product family;

· A declaration of compliance with the applicable substance restrictions;

· Applicable exemptions, where relevant;

· A statement of responsibility for the information provided.

The MMA registration system is not yet operational, and the resolution does not set a specific deadline for it to go live. Once the system is available, manufacturers and importers will have a one-year transition period to enter the required information in the register and issue the self-declaration of conformity.

Technical documentation and the EU RoHS Directive

Manufacturers and importers will be required to keep technical documentation supporting their self-declaration of conformity.

For products that already comply with the EU RoHS Directive, we expect the technical impact to be significantly reduced, because the Brazilian resolution adopts the same ten main restricted substances and equivalent maximum concentration limits.

Existing EU RoHS documentation, declarations of conformity, technical files and test reports can therefore serve as the technical basis for Brazilian compliance. Which documents Brazil ultimately accepts will, however, depend on supplementary regulations issued by the MMA.

Product marking and consumer information

The resolution also introduces identification, traceability and environmental information requirements.

Applicable equipment must carry identifiable and traceable information, including:

· Product model, serial number, batch number or other identifier;

· Registered trade name or trademark and a contact address in Brazil;

· Identification of the Brazilian manufacturer or, for imported products, of the Brazilian importer.

Equipment subject to reverse logistics requirements must also bear the crossed-out wheeled bin symbol indicating that it must be disposed of separately. The resolution allows some information to be provided through a redirect tool, and — where technically infeasible or impractical — on the packaging, in accompanying documents or by other permitted means.

These marking requirements have specific transition periods linked to the issue of the Brazilian self-declaration of conformity.

What should manufacturers do now?

Manufacturers planning to sell electrical or electronic products in Brazil should begin reviewing their existing RoHS compliance documentation to confirm whether their products already meet the Brazilian RoHS limits, in particular the PBB and PBDE limits that are already in force and the mercury limit that applies from January 2027. For products that already comply with EU RoHS, we recommend preparing the applicable declarations of conformity, technical documentation and existing test reports so that they can be assessed once the MMA publishes its supplementary requirements.

At this stage, no changes to existing ANATEL or INMETRO certification projects are required as a result of this resolution alone.

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