Restricted Substances and Implementation Schedule

Restricted Substance	Maximum Concentration	Compliance Deadline
Polybrominated Biphenyls (PBB)	0.1%	July 10, 2026
Polybrominated Diphenyl Ethers (PBDE)	0.1%	July 10, 2026
Mercury (Hg)	0.1%	January 6, 2027
Cadmium (Cd)	0.01%	July 10, 2029
Hexavalent Chromium (Cr-VI)	0.1%	July 10, 2029
Lead (Pb)	0.1%	July 10, 2029
Bis(2-ethylhexyl) phthalate (DEHP)	0.1%	July 10, 2030
Benzyl butyl phthalate (BBP)	0.1%	July 10, 2030
Dibutyl phthalate (DBP)	0.1%	July 10, 2030
Diisobutyl phthalate (DIBP)	0.1%	July 10, 2030

Which Products Are Affected?

The Resolution has a broad scope and applies to electrical and electronic equipment with rated voltage not exceeding 1,000 V AC or 1,500 V DC, including parts and components.

Examples of products covered by the Resolution include:

• Telecommunication equipment, such as smartphones, routers, access points, modems, gateways, IoT devices and other products commonly subject to ANATEL approval;
• IT equipment, such as computers, notebooks, monitors, servers and related equipment;
• Household appliances and other electrical appliances;
• Electrical and electronic medical devices and in-vitro diagnostic equipment;
• Lighting equipment;
• Electrical and electronic tools;
• Monitoring and control instruments;
• Consumer electronics;
• Toys and electronic sports/leisure equipment;
• Photovoltaic modules, subject to the exclusions established by the Resolution; and
• Wires, cables, parts and replacement components.

Which Products Are Excluded?

CONAMA Resolution No. 516/2026 also establishes specific exclusions. Some examples are:

• Equipment specifically intended for defense and national security;
• Equipment designed to be sent into space, as well as ground equipment necessary for the operation of satellites and space systems;
• Large-scale fixed industrial equipment and installations;
• Certain means of transportation;
• Professional non-road mobile machinery;
• Implantable electronic medical devices;
• Batteries and cells when considered as products themselves;
• Certain photovoltaic modules installed as part of permanent solar systems; and
• Equipment specifically designed for Research & Development (R&D) and made available exclusively on a B2B or institutional basis.

Does This Change ANATEL or INMETRO Certification?

At this stage, CONAMA Resolution No. 516/2026 does not directly change the existing ANATEL or INMETRO certification procedures.

ANATEL/INMETRO certification and CONAMA hazardous-substance compliance should therefore be considered separate regulatory requirements.

However, many products subject to ANATEL or INMETRO requirements, including telecommunication equipment, IT equipment, household appliances and electrical/electronic medical devices, are also within the scope of CONAMA Resolution No. 516/2026.

A product may therefore need to comply with both the applicable ANATEL/INMETRO requirements and the new CONAMA environmental requirements before being placed on the Brazilian market.

What will Manufacturers and Importers Need to Do?

The Resolution creates the National Registry of Electrical and Electronic Equipment with Hazardous Substance Restrictions, which will be implemented and regulated by the Brazilian Ministry of Environment and Climate Change (MMA).

Each applicable equipment, model or product family will need to be registered, and the responsible Brazilian manufacturer or importer will be required to issue a Self-Declaration of Conformity.

The MMA registration will include information such as:

• Manufacturer and Brazilian importer identification;
• Product, model or product family identification and traceability information;
• Declaration of compliance with the applicable substance restrictions;
• Applicable exemptions, when relevant; and
• A statement of responsibility for the information provided.

The MMA registration system is not yet available, and the Resolution does not establish a specific deadline for the system to become operational. Once the system is made available, manufacturers and importers will have a one-year transition period to include the required information in the Registry and issue the Self-Declaration of Conformity.

Technical Documentation and EU RoHS

Manufacturers and importers will be required to maintain technical documentation supporting the Self-Declaration of Conformity.

For products already compliant with EU RoHS, we expect the technical impact to be significantly reduced because the Brazilian Resolution adopts the same ten main restricted substances and equivalent maximum concentration limits.

Existing EU RoHS documentation, Declarations of Conformity, technical files and test reports may therefore be useful as the technical basis for Brazilian compliance. However, the exact documentation that will be accepted in Brazil will depend on the supplementary regulation to be issued by the MMA.

Product Marking and Consumer Information

The Resolution also introduces identification, traceability and environmental information requirements.

Applicable equipment must provide information allowing its identification and traceability, including:

• Product model, serial number, lot number or other identification;
• Registered trade name or trademark and a contact address in Brazil; and
• Identification of the Brazilian manufacturer or, for imported products, the Brazilian importer.

For equipment subject to reverse logistics requirements, a crossed-out waste container symbol indicating selective disposal will also be required. The Resolution allows some of this information to be provided through a redirection tool and, where direct marking is technically impossible or impractical, through the packaging, accompanying documentation or other permitted means.

These marking requirements are subject to specific transition periods linked to the issuance of the Brazilian Self-Declaration of Conformity.

What Should Manufacturers Do Now?

Manufacturers planning to commercialize electrical or electronic products in Brazil should start reviewing their existing RoHS compliance documentation to confirm whether their products already meet the Brazilian RoHS limits, particularly for PBB and PBDE, whose restrictions are already in force, and mercury, whose restriction will take effect in January 2027. For products already compliant with EU RoHS, we recommend keeping the applicable Declaration of Conformity, technical documentation and available test reports ready for evaluation once the MMA publishes the supplementary requirements.

At this stage, no change to current ANATEL or INMETRO certification projects is required solely as a result of this Resolution.

E3Tech is closely monitoring the implementation of CONAMA Resolution No. 516/2026, including:

• MMA supplementary regulations;
• Technical documentation requirements;
• Exemption lists;
• Availability of the new registration system; and
• Further implementation guidance.

We will provide further updates as soon as these requirements are officially published.

For the complete regulatory text and further details, please refer to the official CONAMA publication:

Official CONAMA Resolution No. 516/2026:
https://conama.mma.gov.br/?option=com_sisconama&task=arquivo.download&id=861

Please feel free to contact E3Tech if you have any questions regarding the applicability of CONAMA Resolution No. 516/2026 to your products.