Brazil has enacted CONAMA Resolution No. 516, dated July 8, 2026, which establishes comprehensive restrictions on the use of hazardous substances in electrical and electronic equipment (EEE) commercialized in the country. The regulation, published on July 10, 2026, aligns Brazil with international RoHS standards and aims to ensure environmentally sound disposal and enhanced protection of human health and the environment.

The resolution applies to a broad range of EEE, including household appliances, IT and telecom equipment, lighting, medical and veterinary devices, and more. It sets maximum concentration limits for ten hazardous substances, such as lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and four phthalates, with phased compliance deadlines depending on the substance.

Manufacturers and importers are required to register each product or product family in the new National Register of Electrical and Electronic Equipment with Restrictions of Hazardous Substances, issue a declaration of conformity, and maintain technical documentation in Portuguese for at least five years after product discontinuation. The declaration must accompany the product and be accessible to consumers and authorities.

The regulation also introduces labeling and traceability requirements, including durable identification and selective disposal symbols. Enforcement provisions include post-market controls, mandatory corrective actions, and public notification obligations in case of non-compliance. Temporary exemptions may be granted for specific applications where substitution is technically or scientifically unfeasible.

This regulation is classified as High Impact.

Key reasons for high impact:

• Mandatory and immediate restrictions on hazardous substances for a wide range of electrical and electronic equipment.
• Introduction of new registration, documentation, and labeling requirements for all manufacturers and importers.
• Enforcement of post-market controls and corrective actions, including product recalls and public notifications.
• Creation of a national register and requirement for product-specific declarations of conformity.

Who is affected?

All manufacturers, importers, distributors, and sellers of electrical and electronic equipment in Brazil, as well as related supply chain stakeholders and consumers.

Conclusion:

The regulation imposes significant new compliance obligations and operational changes for the entire EEE sector in Brazil, requiring urgent review and adaptation by all affected parties.