CONAMA publishes regulations on hazardous substances in electronics

In summary

Already established on the international stage through the RoHS (Restriction of Hazardous Substances) Directive, the restriction on the use of certain hazardous substances in electrical and electronic equipment is now expressly incorporated into Brazilian law with the publication of CONAMA Resolution No. 516/2026. In addition to establishing limits on the use of these substances in products sold in Brazil, the regulation creates new obligations related to product registration, self-declaration of conformity, traceability, and enforcement, with significant implications for manufacturers, importers, distributors, and retailers.

In more detail

On July 10, 2026, CONAMA Resolution No. 516/2026 (“Resolution”) was published, establishing restrictions on the use of certain hazardous substances in electrical and electronic equipment sold within Brazil.

Applicable to manufacturers, importers, distributors, and retailers, the Resolution sets maximum concentration limits, by mass of homogeneous material, for substances such as polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), mercury, cadmium, hexavalent chromium, lead, bis(2-ethylhexyl) phthalate (DEHP), benzyl butyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP). The list of covered substances may be expanded or revised over time, and the Ministry of the Environment and Climate Change (“MMA”) is responsible for assessing the need to update the regulations at least every 5 years.

The regulation provides for a phased compliance schedule. The limits applicable to PBB and PBDE took effect immediately upon publication of the Resolution, while the restrictions on mercury must be complied with starting in January 2027. For the other substances, the compliance deadlines range from three to four years.

Temporary exemptions from the implementation deadlines are also provided for when the substitution of the substances in question is technically unfeasible, no reliable alternatives are available, or substitution would result in environmental, health, or safety impacts that outweigh the expected benefits.

Another key point is the creation of the National Registry of Electrical and Electronic Equipment Subject to Restrictions on Hazardous Substances, through which manufacturers, importers, and distributors must register the equipment covered by the regulation, provide technical information, and issue self-declarations of compliance. These declarations entail administrative, civil, and criminal liability and must certify compliance with the requirements of the Resolution or, where applicable, the existence of a grace period or temporary exemption.

The Resolution also establishes additional obligations for actors in the supply chain and strengthens enforcement mechanisms. Competent authorities may request technical documentation and supplementary information, as well as collect samples of electronic equipment to verify compliance with the established requirements. The regulation took effect on the date of its publication.