Reference source : CONAMA Resolution No. 516 of 8 July 2026
Brazil's National Environment Council (CONAMA) has adopted Resolution No. 516 of 8 July 2026, establishing national restrictions on the use of hazardous substances in electrical and electronic equipment (EEE). The Resolution was published in the Official Gazette (DOU) on 10 July 2026 and entered into force on the same date. The new framework aligns Brazil with international RoHS principles and establishes compliance obligations for manufacturers, importers, distributors, and retailers placing EEE on the Brazilian market.
Key Highlights
Restricts the use of ten hazardous substances in electrical and electronic equipment, including lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (Cr VI), polybrominated biphenyls (PBBs), polybrominated diphenyl ethers (PBDEs), and phthalates (DEHP, BBP, DBP, and DIBP).
Establishes maximum concentration limits for restricted substances based on homogeneous material.
Introduces a National Register of Electrical and Electronic Equipment with Hazardous Substance Restrictions, requiring manufacturers and importers to register products before manufacturing or importing them.
Requires manufacturers and importers to issue a product-specific Declaration of Conformity (DoC) and maintain supporting technical documentation.
Introduces traceability and record-keeping requirements to demonstrate product compliance.
Provides temporary exemptions for certain applications through dedicated annexes, subject to specified validity periods.
Strengthens market surveillance and enforcement, allowing authorities to verify compliance and take action against non-compliant products.
Important Dates
8 July 2026: CONAMA Resolution No. 516 adopted.
10 July 2026: Resolution published in the Official Gazette (DOU) and entered into force.
6 January 2027 (180 days after entry into force): mercury (Hg) restriction comes into effect.
By 6 January 2027 (within 180 days of publication): the Ministry will publish the initial exemption list, exemption procedures, and minimum technical documentation requirements.
10 July 2029 (three years after publication): compliance deadline for cadmium (Cd), lead (Pb), and hexavalent chromium (Cr VI).
10 July 2030 (four years after publication): compliance deadline for DEHP, BBP, DBP, and DIBP.
Business Impact
Companies manufacturing, importing, or distributing electrical and electronic equipment in Brazil should:
Review product compositions against the new substance restrictions.
Prepare for product registration under the National Register once the registration system becomes operational.
Obtain supplier compliance declarations.
Prepare and maintain technical documentation and conformity records.
Assess whether any products rely on exemptions and monitor their expiry dates.
Plan for compliance with the transition deadlines applicable to the restricted substances in 2029 and 2030 to ensure uninterrupted market access.