Brazil has published CONAMA Resolution No. 516, a new regulation restricting the use of ten hazardous substances in electronic and electrical equipment sold nationwide. Issued by the National Council for the Environment (CONAMA) on July 8, 2026 and published in the Official Gazette two days later, the resolution mirrors the restricted-substance approach used in RoHS style regulations around the world. It introduces phased compliance deadlines, a mandatory national registry, and new self-declaration of conformity requirements for manufacturers and importers. For companies selling electronics into Brazil, this is one of the country’s most significant product compliance updates in years.
What Products Fall Under Brazil's New Hazardous Substance Restrictions
Resolution 516 applies broadly to “electroeletronic equipment,” defined as any product whose proper function depends on electric current or electromagnetic fields, with a rated voltage not exceeding 1000V AC or 1500V DC. In practice, this covers:
- Household appliances and consumer electronics
- IT, telecom, and networking equipment
- Lighting equipment
- Power tools, toys, and sporting and leisure equipment
- Electronic medical devices and in vitro diagnostic instruments
- Electronic veterinary devices
- Monitoring and control instruments
- Vending machines, plus related wires, cables, and spare parts
The resolution excludes several categories, including defense and security equipment, space equipment, components engineered exclusively for excluded products, large fixed industrial installations, transport vehicles (apart from personal mobility devices), off-road professional machinery, implantable electronic medical devices, permanently installed solar photovoltaic panels, batteries, and equipment developed solely for research and development.
Restricted Substances and Maximum Concentration Limits
Under Article 4, electroeletronic equipment, along with related wires, cables, and spare parts, may not contain the following substances above these concentration limits by weight of homogeneous material:
- Polybrominated biphenyls (PBB): 0.1%
- Polybrominated diphenyl ethers (PBDE): 0.1%
- Mercury (Hg): 0.1%
- Cadmium (Cd): 0.01%
- Hexavalent chromium (Cr-VI): 0.1%
- Lead (Pb): 0.1%
- Di(2-ethylhexyl) phthalate (DEHP): 0.1%
- Benzyl butyl phthalate (BBP): 0.1%
- Dibutyl phthalate (DBP): 0.1%
- Diisobutyl phthalate (DIBP): 0.1%
Compliance Deadlines: Brazil's Phased Rollout Timeline
Rather than a single cutover date, the resolution sets staggered deadlines by substance group:
- PBB and PBDE: restricted immediately upon entry into force
- Mercury: 180 days from entry into force
- Cadmium, hexavalent chromium, and lead: 3 years from the publication date
- DEHP, BBP, DBP, and DIBP (the four restricted phthalates): 4 years from the publication date
Products designed and manufactured before these deadlines, and repair or reuse parts for them, are exempt from the corresponding restriction.
Registration and Self-Declaration of Conformity Requirements
CONAMA Resolution 516 creates a new National Registry of Electroeletronic Equipment with Restrictions on Hazardous Substances, to be regulated by Brazil’s Ministry of Environment and Climate Change. Manufacturers and importers must register each product model or family before manufacturing or importing it, and generate a self-declaration of conformity confirming compliance with the restrictions (or applicable exemptions).
Key requirements include:
- Registration is mandatory and must occur before fabrication or import
- The self-declaration must accompany the product’s packaging, in full or through an easily accessible redirect tool such as a QR code, and be published online
- All required information must be provided in Portuguese
- Legal representatives who submit declarations are personally responsible, administratively and criminally, for their accuracy
- The registry system must be made available within one year of the resolution’s publication, with a further one-year window for companies to complete registration once it launches
Exemptions to the Substance Restrictions
Companies may request temporary exemptions from the restrictions under Article 5 where at least one of the following applies:
- It is technically or scientifically impossible to eliminate or substitute the substance
- There is no guarantee of reliability for an alternative substance
- Eliminating or substituting the substance would create environmental, health, or safety impacts across the product’s life cycle that outweigh the benefits of substitution
Exemption requests can be submitted at any time, and the Ministry of Environment and Climate Change must publicize all exemption decisions, renewals, and revocations. Renewal requests must be filed at least 18 months before an exemption expires, and an active exemption remains valid while a renewal request is under review.
Labeling, Traceability, and Enforcement
Manufacturers and importers also take on new documentation and marking obligations, including:
- Maintaining technical documentation and self-declarations of conformity in Portuguese for 5 years after a product is discontinued
- Keeping traceability records for 5 years after manufacture or import
- Marking each product with its model, batch or serial number, registered trademark with a single Brazilian contact address, and manufacturer or importer identification
- Displaying the selective-disposal symbol (a crossed-out waste bin) on products subject to reverse logistics, unless it appears on the packaging or accompanying documentation instead
Brazil’s federal environmental authority may request product samples at any stage of the supply chain and order testing at laboratories accredited under the International Laboratory Accreditation Cooperation (ILAC) or InterAmerican Accreditation Cooperation (IAAC). Companies found in violation must notify the authority, halt sales, and recall affected products where technically feasible.
For this article’s source information and any product certification guidance, please contact Global Validity.
Quick Country Facts
Brazil
Certification Body: Agencia Nacional de Telecomunicaciones (ANATEL)
Certification Type: Mandatory
License Validity: 24/36 Months
Application Language: Portuguese
Legal License Holder: Local Representative
In-Country Testing Requirement: In-Country Testing
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