Brazil has established its own restriction-of-hazardous-substances regime for electronics. The National Environment Council (CONAMA) issued Resolution No. 516, dated 8 July 2026, published in an extra edition of the Official Gazette (Diário Oficial da União) on 10 July 2026. Widely referred to as the “Brazilian RoHS,” the resolution restricts certain hazardous substances in electrical and electronic equipment (EEE) placed on the Brazilian market and entered into force on the date of publication.
Modelled on the European Union’s RoHS Directive, it sets concentration limits for ten substances and introduces a self-declaration and national registration system for manufacturers and importers.
The Restricted Substances
Under Article 4, EEE, including its wires, cables, and spare parts for repair, reuse, or upgrade, may only be manufactured, imported, distributed, or sold in Brazil if it does not exceed the following maximum concentrations by mass of homogeneous material:
- Cadmium (Cd): 0.01%
- Lead (Pb), mercury (Hg), hexavalent chromium (Cr-VI): 0.1% each
- PBB and PBDE (brominated flame retardants): 0.1% each
- DEHP, BBP, DBP, and DIBP (phthalates): 0.1% each
This mirrors the EU RoHS list of restricted substances.
Phased Compliance Deadlines
Rather than a single cut-off, the resolution phases in the limits by substance:
- PBB and PBDE: from the resolution’s entry into force
- Mercury: 180 days after entry into force
- Cadmium, hexavalent chromium, and lead: 3 years from publication
- The four phthalates (DEHP, BBP, DBP, DIBP): 4 years from publication
Equipment and spare parts designed and manufactured before the applicable deadline are not caught retroactively, and temporary exemptions may apply in specific cases.
Scope and Exclusions
The resolution applies to equipment whose operation depends on electric currents or electromagnetic fields, with a rated voltage up to 1000 V AC or 1500 V DC, including parts and components. This covers a broad range of products, from household appliances and IT and telecommunications equipment to lighting, consumer electronics, and photovoltaic modules.
Several categories are excluded (Article 3), including military and security equipment, space equipment, large-scale fixed industrial installations, means of transport, implantable electromedical devices, batteries, and equipment used purely for research and development.
Self-Declaration and the National Register
Compliance is demonstrated through self-declaration of conformity rather than third-party certification. To support this, the resolution creates a National Register of Electrical and Electronic Equipment with Hazardous Substance Restrictions, to be established and regulated by the Ministry of the Environment and Climate Change (MMA). Key points:
- Registration is mandatory and must be completed before manufacture or import.
- Each item, model, or product family is registered individually, generating an individualised self-declaration linked to the manufacturer or importer.
- Manufacturers and importers will have one year from the date the registration system becomes available to enter their information and issue the corresponding self-declarations.
- The self-declaration must accompany the product or its packaging (in full or via a redirection tool) and be available online, and technical documentation must be kept in Portuguese for five years after the product is discontinued.
Products must also carry durable identification and traceability markings, along with the selective-disposal symbol (the crossed-out wheelie bin) set out in the resolution’s Annex.
Why This Matters
Businesses placing electrical and electronic equipment on the Brazilian market should:
- Confirm whether their products fall within the scope of Resolution No. 516.
- Assess their products, components, and supply chain against the ten restricted substances and their limits, noting the phased deadlines by substance.
- Prepare the technical evidence, labelling, and traceability needed to support a self-declaration of conformity in Portuguese.
- Monitor the launch of the National Register so they can meet the one-year registration window once the system is available.
To read the official documentation (Portuguese only), access below.
What This Means for Manufacturers and Importers
C-PRAV helps manufacturers and importers achieve global market access and regulatory compliance, including for the Brazilian market. Our team can support your RoHS and restricted-substance compliance through materials and substance assessment, supplier and component evaluation, and preparation of the technical documentation and traceability needed to underpin your self-declaration of conformity, helping you prepare ahead of Brazil’s registration requirements.
Have questions? We’re here to help.
How C-PRAV Can Support You
C-PRAV helps manufacturers and importers achieve global market access and regulatory compliance, including for the Brazilian market. Our team can support your RoHS and restricted-substance compliance through materials and substance assessment, supplier and component evaluation, coordination of testing at accredited laboratories, and preparation of the technical documentation, labelling, and traceability needed to underpin your self-declaration of conformity, helping you prepare ahead of Brazil’s registration requirements and phased deadlines.
Have questions? We’re here to help.