Brazil has introduced its first national RoHS regulation. On 10 July 2026, the National Environment Council (CONAMA) adopted Resolution No. 516/2026, restricting hazardous substances in electrical and electronic equipment (EEE) sold in the Brazilian market. For global manufacturers, this closes a long-standing gap. Brazil was one of the few major economies without a dedicated RoHS framework, and companies could often rely on EU RoHS conformity as a proxy. That assumption no longer holds.

Brazil RoHS compliance now requires its own scope determination, its own phase-in calendar, Portuguese-language labeling, and registration through a future National Registry. If your organization already runs an EU RoHS program, this regulation is not a copy-paste. The substance list overlaps, but the dates, documentation, and registration mechanics are distinct.

This guide breaks down what CONAMA Resolution No. 516/2026 requires, who it affects, and how manufacturers can prepare across a multi-tier supply chain. To understand your current exposure across Brazil RoHS and adjacent frameworks, you can book a compliance risk assessment with a Certivo specialist.

Key Takeaways

📌 Brazil RoHS (CONAMA Resolution No. 516/2026) is the country's first national restriction of hazardous substances in EEE, effective 10 July 2026.

⏳ Restrictions phase in over four dates: PBB and PBDE in 2026, Mercury in January 2027, three heavy metals in 2029, and four phthalates in 2030.

📊 Thresholds mirror the familiar RoHS convention: 0.1% for most substances and 0.01% for Cadmium.

🏭 Scope covers EEE, wires, cables, and spare parts. Batteries are excluded.

📄 Manufacturers and importers must register product models and submit self-declarations of conformity once the National Registry becomes operational.

🔗 Products sold in Brazil require Portuguese-language labeling for identification and traceability.

🤖 The first exemption list and technical documentation guidance are expected in January 2027, making early BOM-level material mapping essential.

Executive Regulatory Overview

CONAMA Resolution No. 516/2026 introduces substance restrictions modeled on the global RoHS approach, applied for the first time at a national level in Brazil. The resolution was published in the Diário Oficial da União and entered into force on 10 July 2026. On that date, restrictions on Polybrominated Biphenyls (PBB) and Polybrominated Diphenyl Ethers (PBDE) became immediately effective.

The remaining substances phase in across 2027, 2029, and 2030. This staged approach gives manufacturers a window to reformulate, re-source, and re-document, but the window closes on a fixed schedule. Companies that treat Brazil as an extension of an existing EU RoHS program will find the substance list familiar and the compliance mechanics unfamiliar.

For a broader view of how RoHS frameworks operate, see Certivo's RoHS framework overview.

What Is Brazil RoHS (CONAMA Resolution 516/2026)?

Brazil RoHS is a national regulation that restricts specified hazardous substances in electrical and electronic equipment placed on the Brazilian market. It establishes maximum concentration limits, a phased compliance calendar, mandatory product registration, and Portuguese-language labeling.

The regulation reflects a wider global pattern. Restriction of hazardous substances is no longer confined to the EU. China operates its own RoHS regime, and manufacturers now navigate multiple overlapping national frameworks. Managing that fragmentation is precisely where a centralized compliance data backbone becomes valuable, because the same product data must satisfy several jurisdictions at once.

Why Brazil RoHS Matters Now

For years, exporters could often demonstrate EU RoHS conformity and treat Brazil as covered by extension. CONAMA Resolution No. 516/2026 ends that shortcut. Brazil now requires jurisdiction-specific evidence, registration, and labeling. Manufacturers selling into Brazil must confirm scope, verify substance content, and maintain documentation that stands up to Brazilian requirements, not just EU ones.

Framework Scope and Affected Products

The regulation applies to electrical and electronic equipment, wires, cables, and spare parts. Batteries are excluded from the scope.

Scope determination is the first and most consequential step. A product that appears out of scope may contain in-scope spare parts or cabling. Manufacturers with complex, configurable products should map every component against the scope definition rather than making a product-level judgment. This is where BOM-level compliance intelligence prevents costly misclassification.

Restricted Substances and Thresholds

CONAMA Resolution No. 516/2026 restricts ten substances across three chemical categories. Thresholds follow the established RoHS convention, with Cadmium held to a tighter limit than the others.

Note: Hexavalent Chromium is regulated as a substance group rather than a single CAS number.

The threshold structure will look familiar to any team running RoHS programs elsewhere. The operational difficulty is not the number itself. It is proving, at the homogeneous material level, that every component in a multi-tier supply chain sits below the limit. That requires Full Material Declarations, not high-level supplier assurances. Managing thresholds against a live bill of materials is a core function of BOM substance and threshold management.

Brazil RoHS restricted substances and thresholds for electronic equipment compliance

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The Phase-In Timeline

The regulation restricts substances across four dates. Each date is fixed, and each carries distinct reformulation and documentation implications.

The January 2027 milestone is the one to watch most closely. Beyond the Mercury restriction, it is when the first exemption list and technical documentation guidance are expected. Until those exemptions are published, manufacturers cannot fully finalize design-for-compliance decisions for the 2029 and 2030 substances, because it remains unclear which applications may be exempt.

Certivo's approach to regulatory intelligence and horizon scanning is built for exactly this kind of staged, evolving rollout, where obligations arrive on a calendar and guidance follows later.

Brazil RoHS phase-in timeline showing substance restriction deadlines through 2030

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Affected Industries

The regulation reaches any organization that manufactures, imports, or distributes in-scope EEE in Brazil.

• Electrical and electronic equipment manufacturing — the primary target of the regulation

• Consumer electronics — high volume, high SKU count, frequent design changes

• Household appliances — long product lifecycles complicate substance tracking

• Wire and cable manufacturing — explicitly named in scope

• IT and telecommunications equipment — complex multi-tier supply chains

• Lighting equipment — historically sensitive to Mercury restrictions

• Industrial equipment and automation — configurable products with many variants

• Automotive electronics — electronic sub-assemblies within larger systems

• Aerospace electronics — specialized components with limited substitution options

• Electronic components and spare parts — spare parts are explicitly in scope

• Importers and distributors — carry registration and documentation obligations

Manufacturers in electronics and semiconductor and high-tech sectors face the broadest exposure, given the density of restricted substances in circuit-level components.

Registration, Labeling, and Documentation Requirements

Beyond substance limits, CONAMA Resolution No. 516/2026 introduces obligations that go further than substance content alone.

National Registry

The regulation establishes a National Registry. Manufacturers and importers will be required to register individual product models and submit self-declarations of conformity once the registry becomes operational. Based on currently available regulatory guidance, the registry mechanism is not yet live, which means the obligation exists but the submission channel is pending. Manufacturers should prepare model-level data now so they are ready when registration opens.

Portuguese-Language Labeling

Products must carry Portuguese-language labeling to support product identification and traceability. This is a jurisdiction-specific requirement that EU RoHS conformity does not satisfy. Labeling and identification tie directly into broader digital passport and traceability expectations that are spreading across markets.

Technical Documentation

Manufacturers must maintain technical documentation supporting compliance. Based on currently available regulatory guidance, the detailed format is expected alongside the January 2027 technical guidance. In practice, this means Full Material Declarations, supplier self-declarations, and test evidence organized so they can be produced on request. Maintaining that evidence in an audit-ready state, rather than reconstructing it reactively, is the difference between a smooth inspection and a scramble. Certivo supports continuous audit-ready documentation so evidence is retrievable at the point in time it is needed.

To understand where your current documentation stands, you can request a compliance review with a Certivo specialist.

Compliance Risks and Enforcement Outlook

Based on currently available regulatory guidance, the resolution does not, in the source material available, specify a detailed penalty schedule. The practical risks are nonetheless significant.

• ⚠ Market access risk — products that cannot demonstrate conformity or complete registration may face barriers to sale in Brazil

• ⚠ Customer disqualification — OEM customers increasingly require jurisdiction-specific declarations and may deprioritize suppliers who cannot provide them

• ⚠ Documentation gaps — inability to produce Full Material Declarations or technical files on request creates exposure during inspection

• ⚠ Labeling non-conformity — missing Portuguese-language labeling is a visible, easily identified deficiency

The safest posture is to treat the 2026 restrictions as fully enforceable now and prepare systematically for the 2027, 2029, and 2030 milestones rather than waiting for enforcement clarity.

Supply Chain and Operational Impact

The heaviest operational load falls on supplier data collection. Proving that ten substances sit below threshold across a multi-tier supply chain requires structured declarations from every relevant supplier, not blanket statements.

Key challenges include:

1. Obtaining Full Material Declarations — many sub-tier suppliers report at the component level, not the homogeneous-material level the thresholds require

2. Version control — supplier data ages, and a declaration valid in 2026 may not reflect a 2029 formulation change

3. Multi-tier visibility — restricted substances often enter through Tier 2 or Tier 3 suppliers with limited compliance capacity

4. Data harmonization — declarations arrive in inconsistent formats and must be normalized

Manual collection through spreadsheets and email does not scale to ten substances across thousands of parts and hundreds of suppliers. Automated supplier data collection and portals reduce the manual burden and improve data quality at intake. For electronics supply chains specifically, Certivo has written on automating multi-tier compliance across global suppliers.

Brazil RoHS supplier data collection workflow for material declaration compliance

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Brazil RoHS vs. EU RoHS: What Is Different

For teams already running EU RoHS programs, the value is in the delta. The substance list and thresholds are broadly familiar. The mechanics are not.

The takeaway for a compliance engineer: do not assume EU RoHS conformity transfers automatically. The substance data may carry over, but registration, labeling, and the phase-in calendar require separate Brazil-specific handling. Managing both regimes from one dataset is the argument for a single source of truth for product compliance.

Compliance Preparation Checklist

✅ Determine scope — identify which products, spare parts, wires, and cables fall within Brazil RoHS

✅ Verify current restrictions — confirm PBB and PBDE compliance, which are in force now

✅ Prepare for January 2027 — plan for the Mercury restriction and monitor the expected exemption list and technical guidance

✅ Review 2029 and 2030 substances — assess product material composition for the heavy metals and phthalates restricted later

✅ Collect supplier declarations — obtain updated supplier self-declarations and Full Material Declarations at homogeneous-material resolution

✅ Build technical documentation — assemble the evidence needed to support conformity

✅ Plan for registration — prepare model-level data for the National Registry and self-declarations of conformity

✅ Address labeling — implement Portuguese-language labeling for products sold in Brazil

✅ Monitor guidance — track publication of exemption lists and technical guidance expected January 2027

✅ Align with EU RoHS — reuse existing substance data where applicable, while handling Brazil-specific registration and labeling separately

Manufacturers who want a structured way to measure documentation readiness across RoHS, REACH, PFAS, and related frameworks can use a Customer Audit Readiness Scorecard as part of a broader compliance risk assessment.

How AI and Automation Support Brazil RoHS Compliance

Brazil RoHS adds another jurisdiction to an already crowded compliance map. Managing it manually means duplicating effort across regimes. AI-native compliance automation addresses the structural challenges directly.

Automated Supplier Data Collection

Certivo's supplier portals let suppliers submit declarations directly, with validation at intake. This reduces the manual chase for missing data and improves the quality of Full Material Declarations across the supply base.

AI Document Parsing and Certificate Validation

CORA-powered regulatory intelligence extracts and validates data from supplier declarations, test reports, and material disclosures. CORA flags incomplete fields and checks reported values against the applicable thresholds, reducing the manual review that ten substances across thousands of parts would otherwise require. Certivo has detailed this approach in its work on AI-powered mill test report analysis.

BOM-Level Material Mapping

Linking substance data to a live bill of materials lets compliance teams answer, at the product level, whether a given model is Brazil RoHS conformant. This is essential for model-level registration and for responding to customer audits. It is a core capability described in Certivo's product compliance management guide.

Regulatory Change Management

CORA regulatory insights monitor developments such as the expected January 2027 exemption list, so compliance teams learn of changes as they are published rather than discovering them during an audit. This shifts the organization from reactive compliance toward continuous readiness.

A Conversion-Focused Note

Traditional compliance approaches rely on spreadsheets, email, and manual cross-referencing that do not scale as jurisdictions multiply. Certivo serves as the system of record for product compliance, combining automated supplier data collection, BOM-level substance mapping, and CORA regulatory intelligence in one platform. The result is fewer surprises during audits, faster response times, and the ability to absorb new frameworks like Brazil RoHS without a proportional increase in headcount.

To see how this applies to your product portfolio and supply chain, speak with a compliance specialist.