Global Market Access: Nemko Group AS Testing Services

Brazil introduces RoHS-style restrictions

Written by Nemko | August 31, 2026

                                                                                                                                                                              

Brazil, officially the Federative Republic of Brazil, is the largest country in South America and borders every country on that continent except Chile and Ecuador. It is also the world's 5th largest country by area and the 7th largest by population, having over 220 million people with Portuguese as the official language. The most populous city is São Paulo, followed by Rio de Janeiro and the capital city Brasília. 

About 60% of Brazil's total land area is occupied by the Amazon rainforest which plays a crucial role in the global climate and for understanding the effects of climate change.

Climate and environmental matters are high on the national agenda, including the prevention of toxic substances released into the environment and human health.

Brazil's National Council for the Environment (CONAMA) has therefore now adopted Resolution No. 516/2026, with restrictions on the use of certain hazardous substances in electrical and electronic equipment sold in the country. The regulation introduces a national framework commonly described as a Brazilian RoHS regime and, like the European RoHS Directive, establishes maximum concentration limits for ten hazardous substances contained in electrical and electronic equipment, including cables, wires, and certain spare parts. The regulation does, however, include some Brazil-specific compliance obligations of administrative nature (as mentioned further below).

The measure restricts the use of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs), polybrominated diphenyl ethers (PBDEs), and four phthalates commonly regulated under international RoHS programs. Manufacturers and importers are required to assess product compliance against specified concentration limits applicable to homogeneous materials.

The regulation introduces phased implementation periods depending on the substance concerned. Requirements for PBBs and PBDEs became applicable immediately upon entry into force. Mercury restrictions become applicable following a 180-day transition period, while compliance deadlines for lead, cadmium, hexavalent chromium, and the specified phthalates extend over multiple years.

The resolution also establishes the National Registry of Electrical and Electronic Equipment Subject to Restrictions on Hazardous Substances, through which manufacturers, importers, and distributors must register covered products and provide associated compliance information. The framework further includes self-declaration obligations and compliance documentation requirements intended to support traceability and regulatory enforcement activities.

All parties involved with supplying electrical and electronic products to Brazil should evaluate product material composition, supply-chain compliance information, technical documentation, and future registration obligations to determine the impact of the new requirements.

Further information may be seen e.g. here.

 

For other information and/or assistance with product compliance and market access in South American countries, please contact Michelle.Furrow@nemko.com. Concerning RoHS, please contact Kenny.Ho@nemko.com

 

 

 

(This article is based on information provided by Geremy Bradshaw; edited by T.Sollie)