On July 10, 2026, Brazil published CONAMA Resolution No. 516/2026, establishing restrictions on hazardous substances in electrical and electronic equipment marketed within the country. This new regulation aligns Brazil with major international environmental compliance frameworks and introduces new obligations for manufacturers, importers, distributors, and retailers.
Which Products Are Affected?
The regulation applies to a broad range of electrical and electronic equipment, including:
- Information technology and telecommunications equipment
- Household appliances
- Lighting equipment
- Consumer electronics
- Electrical and electronic tools
- Toys and leisure equipment
- Medical electrical devices
- Monitoring and control instruments
- Other electrical and electronic products covered by the Resolution
Restricted Substances
The Resolution establishes concentration limits for the following substances:
- Lead (Pb)
- Mercury (Hg)
- Cadmium (Cd)
- Hexavalent Chromium (Cr VI)
- Polybrominated Biphenyls (PBB)
- Polybrominated Diphenyl Ethers (PBDE)
- DEHP
- BBP
- DBP
- DIBP
Manufacturers and importers must ensure that their products comply with the maximum concentration limits established for each substance.
Compliance Timeline
The implementation schedule is phased as follows:
Immediate Effect
- PBB
- PBDE
Within 180 Days
- Mercury (Hg)
Within 3 Years
- Cadmium (Cd)
- Lead (Pb)
- Hexavalent Chromium (Cr VI)
Within 4 Years
- DEHP
- BBP
- DBP
- DIBP
This phased approach was designed to allow companies sufficient time to adapt their products, supply chains, and compliance processes.
National Registry and Self-Declaration of Conformity
The Resolution establishes the National Registry of Electrical and Electronic Equipment Subject to Hazardous Substance Restrictions, which will be implemented and regulated by the Brazilian Ministry of Environment and Climate Change.
Each product, model, or product family must have its own individual registration and corresponding Self-Declaration of Conformity, linked to the responsible manufacturer or importer.
For imported products, the importer is responsible for product registration and issuance of the Self-Declaration of Conformity, while also maintaining the relevant information regarding the foreign manufacturer and supporting technical documentation.
The Self-Declaration of Conformity must accompany the product, either directly on the packaging or through electronic means such as a QR code or online access link.
Responsibilities of Manufacturers and Importers
Although the regulation adopts a self-declaration approach, manufacturers and importers remain fully responsible for:
- The accuracy of the information declared;
- Maintaining technical documentation;
- Product traceability;
- Demonstrating compliance to competent authorities;
- Taking corrective actions and managing recalls when non-compliance is identified.
In addition, manufacturers and importers must retain compliance records and technical documentation in accordance with the requirements established by the regulation.
What Still Needs Further Regulation?
Although the Resolution is already in force, several operational aspects still require additional guidance from the Ministry of Environment and Climate Change, including:
- Availability of the national registration platform;
- Definition of the minimum technical documentation requirements;
- Procedures for exemption requests;
- Additional compliance and verification criteria.
For this reason, manufacturers and importers are encouraged to begin reviewing product composition, supplier declarations, technical documentation, and existing compliance evidence as early as possible.
How NCC Can Support Your Company
Compliance with Brazil’s RoHS regulation involves much more than issuing a self-declaration. Companies must be able to demonstrate, through robust technical evidence, that their products fully comply with the applicable requirements.
To support manufacturers and importers in this process, NCC Certifications offers Voluntary RoHS Certification, an independent third-party assessment designed to verify full compliance with the applicable regulatory requirements.
The certification process may include:
✅ Review of product technical documentation
✅ Verification of compliance with CONAMA Resolution No. 516/2026
✅ Assessment of available test reports
✅ Evaluation of supply chain compliance evidence
✅ Review of manufacturer and importer compliance controls
✅ Issuance of an independent Voluntary RoHS Certificate
Voluntary certification provides additional regulatory confidence, enhances market credibility, and demonstrates a company's commitment to environmental compliance and sustainability.
Prepare for Brazil’s RoHS Requirements
The publication of CONAMA Resolution No. 516/2026 represents a major milestone for the Brazilian electrical and electronics industry and will require careful attention from manufacturers and importers in the coming years.
NCC is ready to support your organization in understanding the new requirements, evaluating technical documentation, and obtaining Voluntary RoHS Certification, helping ensure a smooth and reliable transition to Brazil’s new environmental compliance framework.
Contact our team to learn how NCC can help your company demonstrate compliance with Brazil’s RoHS Regulation.