Brazil RoHS is no longer a future possibility. CONAMA Resolution No. 516/2026 was published on July 10, 2026, entered into force on the publication date, and created Brazil’s national framework for restricting hazardous substances in electrical and electronic equipment, or EEE. For manufacturers and importers already selling in the European Union, the encouraging news is that the Brazilian substance list and concentration limits closely match EU RoHS.
Your existing EU RoHS work can therefore provide a strong starting point, but it is not a ready-made Brazilian compliance package. Brazil adds local registration, self-declaration, Portuguese-language documentation, traceability, product information, and specific record-retention obligations. The best strategy is to preserve the evidence already built for Europe, then perform a structured jurisdictional gap assessment rather than rebuilding everything from zero. This article explains where the two regimes align, where they diverge, and how you can turn one mature technical file into a practical global RoHS system.
CONAMA Resolution No. 516/2026 applies broadly to EEE commercialized in Brazil, including wires, cables, and spare parts used for repair, reuse, functional upgrades, or capacity improvements. It restricts ten substances at the homogeneous-material level: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP. The limits are 0.1% by weight for each restricted substance except cadmium, which is limited to 0.01%. Those are the same ten substances and general maximum concentration values used by EU RoHS.
The Brazilian phase-in schedule is not uniform. PBB and PBDE became subject to the limits when the Resolution entered into force; mercury receives 180 days; cadmium, hexavalent chromium, and lead receive three years from publication; and the four phthalates receive four years. This staged approach creates a moving compliance baseline that must be controlled by substance and date. Products governed by stricter Brazilian rules for a particular substance must follow the more restrictive requirement.
Substance group | Brazil RoHS compliance timing | EU RoHS status in 2026 |
|---|---|---|
PBB and PBDE | From July 10, 2026 | Already restricted |
Mercury | 180 days after entry into force | Already restricted |
Cadmium, hexavalent chromium, and lead | Three years after publication | Already restricted |
DEHP, BBP, DBP, and DIBP | Four years after publication | Already restricted |
Timelines and substance limits are based on Brazil RoHS CONAMA Resolution No. 516/2026 and EU RoHS Annex II.
The Resolution includes exclusions that will look familiar to EU compliance teams, including certain defense equipment, space equipment, large-scale industrial equipment or installations, specific transport and professional non-road machinery, active implantable medical devices, photovoltaic modules for permanent energy-generation systems, and R&D equipment supplied only in a business-to-business context. Brazil also expressly excludes cells and batteries from this Resolution. Scope must still be assessed against each product’s intended function, configuration, and route to market.
EU RoHS operates through Directive 2011/65/EU and its amendments. Manufacturers must prepare technical documentation, conduct the applicable internal production-control procedure, issue an EU Declaration of Conformity, affix the CE marking, and maintain procedures so series production remains compliant when designs, components, or standards change. Technical documentation and the EU Declaration of Conformity are generally retained for ten years after the EEE is placed on the market.
Brazil takes a different administrative route. The Resolution creates a National Registry of EEE Subject to Hazardous Substance Restrictions, requires individualized registration for each equipment, model, or product family, and generates a linked self-declaration of conformity. The registry system must still be implemented and regulated by Brazil’s Ministry of the Environment and Climate Change, and companies will have one year from the system’s availability to enter information and issue the self-declaration. Manufacturers and importers remain legally responsible for the truthfulness of submitted information.
Compliance element | European Union | Brazil |
|---|---|---|
Core substance limits | Ten substances at homogeneous-material level | Same ten substances and general limits |
Main declaration | EU Declaration of Conformity | Brazilian self-declaration generated through the registry |
Product marking | CE marking under RoHS and other applicable EU legislation | Identification and traceability information in Portuguese; selective-disposal symbol where applicable |
Technical documentation | Manufacturer-controlled technical file | Minimum technical documentation in Portuguese, with details to be defined by the Ministry |
Retention period | Generally 10 years after placing EEE on the market | Five years after product discontinuation for the declaration and technical documentation |
Registration | No centralized RoHS product registry | Mandatory national product, model, or family registry |
Enforcement structure | Member State market-surveillance authorities | Federal environmental authority, with sampling and testing powers |
The comparison reflects the EU RoHS manufacturer obligations and Chapters III through VI of Brazil RoHS.
These differences explain why an EU-compliant product should not automatically be described as “Brazil RoHS compliant.” The EU file may demonstrate the chemistry, supplier controls, and risk assessment, but the Brazilian importer may still need local registration, a Portuguese evidence package, a Brazilian self-declaration, Brazilian identification details, and local traceability records. Cross-referencing the files is usually more efficient than duplicating every record.
A mature EU technical file normally contains the most difficult evidence to collect: the bill of materials, supplier declarations, material declarations, test reports, exemption references, component risk rankings, and records showing how changes are managed. EN IEC 63000:2018 is the harmonized European standard for RoHS technical documentation, while IEC 63000 defines the documentation a manufacturer compiles to declare compliance with applicable substance restrictions. This risk-based structure is reusable because Brazil also expects supporting technical evidence and permits documentation review or testing.
Preserve the original EU evidence rather than translating every supplier document indiscriminately. Build a Brazilian summary layer in Portuguese that identifies the product, maps each high-risk homogeneous material to its evidence, lists applicable exemptions, and explains why the evidence is sufficient. Brazil RoHS requires minimum technical documentation in Portuguese, but the Ministry still has to define its exact content. Your file architecture should therefore remain adaptable when the implementing act is published.
A practical reuse process looks like this:
Our RoHS technical file guide and EU RoHS compliance guide can help you structure the source evidence before building the Brazilian layer. For a broader view of jurisdictional differences, review our overview of RoHS regulations worldwide.
IEC 63000 supports a risk-based technical file built from supplier information, contractual controls, declarations, material data, and analytical evidence. Testing every component without first understanding the bill of materials can be costly and still leave gaps. A documented risk assessment helps direct laboratory work toward the materials most likely to contain restricted substances.
The IEC 62321 series provides standardized methods for determining restricted substances in electrotechnical products. X-ray fluorescence can screen selected elements, while other parts of the series address sample preparation and confirmatory analysis. IEC 62321-12, for example, covers simultaneous determination of PBB, PBDE, and the four RoHS phthalates in polymers by GC-MS. Brazil’s authority may requisition samples or require testing in accredited laboratories when documentation indicates possible irregularity.
The strongest strategy combines documentary review and selective testing. Use supplier evidence where it is specific, current, traceable, and technically credible; use screening when material risk is uncertain; and use confirmatory methods when screening cannot distinguish the regulated substance or when a result is near the limit. You can learn more about our RoHS testing approach, chemical testing services, and practical RoHS standards.
Both regimes allow time-limited exemptions when substitution is technically or scientifically impracticable, when substitute reliability is not ensured, or when substitution would create greater environmental, health, or safety impacts. EU exemptions are maintained in Annexes III and IV and are reassessed through a formal process. Renewal applications are generally due at least 18 months before expiry, and an exemption under timely review remains valid until the Commission decides.
Brazil RoHS uses similar decision criteria and also sets an 18-month renewal deadline. The Brazilian Ministry may consider foreign exemptions and seek harmonized expiry dates for supply-chain predictability. However, the Resolution requires the Ministry to publish an initial Brazilian exemption list within 180 days of publication, so an EU exemption should be treated as supporting evidence—not automatic legal authorization—until the Brazilian list and procedures are available.
Create an exemption register with the product family, part number, homogeneous material, substance, technical application, EU exemption number, Brazilian status, evidence owner, expiry date, renewal status, and redesign plan. Review it whenever an exemption, supplier, design, or Brazilian implementing measure changes. Our updated EU RoHS exemptions list provides a useful reference point for the European side of that register.
Brazil’s Resolution demonstrates how RoHS-style rules can preserve the EU’s core substance architecture while adding local market-access mechanisms. The substance list, homogeneous-material concept, thresholds, exclusion logic, and exemption criteria are closely aligned, but the Brazilian registry, self-declaration, Portuguese documentation, traceability, and communication requirements reflect a distinct national enforcement model. For global manufacturers, this is a strong argument for maintaining one controlled product-compliance data set with jurisdiction-specific outputs.
It is reasonable to expect suppliers serving several Latin American markets to receive more requests for full material declarations, current RoHS statements, and laboratory evidence after Brazil’s adoption. This is an operational inference, not a confirmed regional legislative trend. Companies that standardize data collection now will nevertheless be better positioned to respond if other jurisdictions adopt similar rules. Our online RoHS training can help engineering, sourcing, quality, and regulatory teams use the same compliance language.
First, classify every product family sold or planned for sale in Brazil. Confirm scope, exclusions, responsible importer, transition dates, and any components that may depend on an exemption. Products containing PBB or PBDE deserve immediate attention because their restrictions applied from the Resolution’s entry into force. Mercury-containing applications should also be prioritized because their transition period is only 180 days.
Second, audit your EU technical files for evidence quality rather than document quantity. Look for outdated supplier declarations, declarations that cover only the original six substances, reports that cannot be tied to a specific part or material, unverified exemption claims, and product-family groupings that are too broad for the Brazilian registry. Rank missing evidence by material and supplier risk, then test only where documentation cannot close the gap.
Third, prepare the local operating system before the Brazilian registry goes live. Assign an accountable owner, define Portuguese documentation workflows, plan how the self-declaration will accompany the product or packaging, and capture the markings and traceability data required on the product. The Resolution also requires the declaration to be available online and allows a maximum of five business days to provide it on request when it cannot appear on the packaging.
Brazil RoHS does not make your EU RoHS technical file obsolete; it makes that file more valuable. The same substance evidence, supplier controls, IEC 63000 structure, IEC 62321 test data, exemption analysis, and change-management records can support both markets. The successful approach is to separate the common technical core from the Brazilian legal layer, then keep both synchronized as products and regulations evolve.
At Enviropass, we help you audit supply-chain evidence, assess products, review exemptions, design testing plans, and build technical files that remain usable across jurisdictions. Our combination of documentary review and analytical testing lets us identify both paperwork gaps and actual material risks. Whether you need a focused Brazil gap assessment or a complete global RoHS program, we can turn fragmented supplier data into a defensible compliance strategy.
Close the Brazil RoHS gaps before they become market-access problems.
We will review your EU RoHS evidence, map the Brazilian requirements, identify missing documentation or tests, and give you a practical corrective-action plan.