The proposal introduces a unit-specific 'Physical Digital Unit Identity' integrating inseparable physical and digital elements for each homologated product unit, with authentication, traceability and verification against an official database of unique identifiers.

The proposed model is intended to combine a physical ANATEL security element with linked digital verification mechanisms, including QR/token-type approaches described in the consultation materials, and to support verification of products offered through digital marketplaces.

The draft also covers parties commercializing covered products, authorized security-label suppliers and digital-governance entities.

It is not yet binding: detailed security mechanisms, graphic standards, digital-governance procedures and implementation/transition rules would be defined through a subsequent Act before the proposal produces effects. Comments remain open until August 26, 2026 at 23:59.

Impact assessment: Medium.

The proposal is still under consultation, but if adopted it would materially change ANATEL product identification from a model-level marking approach toward unit-level physical/digital traceability.

Key reasons:

Unique identifiers, official-database validation, security-label controls and marketplace verification would require changes to manufacturing, labeling, data and retail workflows.

Who is affected?

Mobile-phone manufacturers/importers, battery and charger suppliers, security-label providers, distributors and e-commerce platforms.

Conclusion:

Stakeholders should assess implementation impacts now and submit comments before the August 26 deadline; final security, graphic and transition details remain pending.