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Article Highlights:
- On the surface, Brazil RoHS looks like a carbon copy of the EU's regulation. It restricts the same ten substances at the homogeneous-material level, and the concentration limits match the EU, too.
- But Brazil RoHS differs from EU RoHS in several crucial ways, including in its reporting obligations. The Brazilian resolution creates a National Registry of EEE Subject to Hazardous Substance Restrictions, and every covered product, model, or product family has to be individually registered in this system.
- The good news is that companies with mature EU RoHS technical files aren't starting from square one. The substance evidence required by EU RoHS maps cleanly onto Brazil RoHS. What doesn't transfer automatically, however, is anything specific to market access.
Most compliance teams tracking global RoHS programs have their eyes on an established set of countries and regions: the EU, China, maybe Vietnam's new chemical compliance framework. Substance restrictions in Brazil, however, tend to slip past people. That's partially because it worked its way through government committees for years before anything actually happened.
It moved past all that bureaucratic red tape on July 10, 2026, though, and Brazil's National Environmental Council (CONAMA) published Resolution No. 516/2026 in the Federal Official Gazette. The new chemical regulation took effect the same day. Now, if your products touch the Brazilian market, you need to familiarize yourself with this new regulation. And the obligations go beyond just a typical substance ban.
What Brazil RoHS Actually Restricts
On the surface, Brazil RoHS looks like a carbon copy of the EU's regulation. It restricts the same ten substances at the homogeneous-material level:
- Lead
- Mercury
- Cadmium
- Hexavalent chromium
- PBB
- PBDE
- The four phthalates (DEHP, BBP, DBP, and DIBP)
The concentration limits match the EU, too: 0.1% by weight for most substances, and 0.01% for cadmium. If your engineering team already builds to EU RoHS limits, the chemistry restrictions themselves are not the challenge.
The harder part is understanding the phase-in schedule, which is staggered by substance, rather than applying uniformly on day one. PBB and PBDE, for example, were restricted the moment the resolution took effect. Mercury gets a 180-day grace period. Cadmium, hexavalent chromium, and lead have three years from the publication date of Resolution No. 516/2026. The restrictions on the four phthalates, meanwhile, don't go into effect for another four years.
All this regulatory staggering means that a single product can simultaneously face concentration thresholds for some substances and still be inside a grace period for others. It's all relatively complex, and it can be easy to lose track of where your products stand and when they need to start limiting the inclusion of specific substances.
The Reporting Obligations Nobody's Talking About
In addition to the staggered chemical restrictions, Brazil RoHS also diverges from its EU counterpart in terms of reporting obligations. In fact, it's in these requirements where most claims of "we're already RoHS compliant" fall apart.
The Brazilian resolution creates a National Registry of EEE Subject to Hazardous Substance Restrictions. Every covered product, model, or product family has to be individually registered in this system. That registry then generates a linked self-declaration of conformity—not a document you draft and file away, but something tied directly to a government database. Manufacturers and importers are legally on the hook for the accuracy of the information and documentation they submit.
The EU's Restriction of Hazardous Substances, on the other hand, has no centralized RoHS product registry at all. A manufacturer prepares its own technical file, issues its own Declaration of Conformity, and affixes the CE mark. In contrast, the Brazilian government takes ownership of the documentation itself. While the nation's Ministry of the Environment and Climate Change still has to implement the registry system, once it goes live, companies have one year to enter their EEE information and issue the self-declaration.
There's also a language requirement that's likely to trip up a lot of multinational suppliers: Everything has to be in Portuguese. Product identification, traceability information, batch and serial numbers, and the manufacturer or importer's contact address in Brazil must be submitted in the country's primary language.
The record obligations for Brazil's RoHS are also starkly different from what companies are accustomed to in the EU. EU RoHS documentation generally has to be kept for ten years after a product goes on the market. In contrast, Brazil RoHS requires documentation to be maintained for five years after the product is discontinued. Suffice it to say, this is a different clock, tied to a different event. This ultimately means that businesses either need to start holding on to RoHS documentation for significantly longer than in the past, or they need to establish their own Brazil-specific document repository guidelines.
Distributors and Retailers Aren't Off the Hook
Another obligation that seems likely to catch organizations off guard is that Brazil RoHS explicitly pulls distributors and retailers—rather than just manufacturers and importers—into the compliance scope. Under the new regulation, these stakeholders are required to confirm that a self-declaration exists before they can distribute or sell a covered product. And if a distributor or retailer markets goods under its own brand, alters a product in a way that could affect compliance, or fails to obtain that self-declaration, it can be treated as the equivalent of a manufacturer, with all the legal consequences that entails.
Where an Existing EU RoHS File Does and Doesn't Help
The good news is that companies with mature EU RoHS technical files aren't starting from square one. The substance evidence required by EU RoHS—including supplier declarations, full material declarations (FMDs), test reports, and bill of materials data—maps cleanly onto Brazil RoHS, because the underlying chemistry is nearly identical. The IEC 63000 documentation structure and IEC 62321 testing methods that support your EU file are the same ones Brazilian authorities look for when they request evidence.
What doesn't transfer automatically, however, is anything related to market access. This includes the Brazilian registry entry, the Portuguese-language self-declaration, local exemption statuses, and the traceability markings required on the product itself. Brazil RoHS is expected to publish its own initial exemption list within 180 days of the resolution's publication, and while the Ministry of the Environment and Climate Change may look to harmonized EU exemptions for guidance, an EU exemption number isn't automatic legal cover in Brazil. Renewal requests reportedly follow an 18-month lead time similar to the EU process, so exemption tracking needs its own line item in your compliance calendar.
Practically, this means reusing the hard-won EU evidence as your foundation, then building additional compliance steps specific to Brazil's regulation on top of it.
Building a Brazil RoHS Compliance Plan
A few things are worth completing before the registry system goes live and the compliance clock really starts ticking.
- Companies operating in Brazil should inventory every product family sold or planned for sale in the country. In addition, they might want to flag which ones contain PBB, PBDE, or mercury—the substances with the shortest runway before restrictions enter into force.
- Organizations should examine existing EU technical files for gaps. These could include declarations that only cover the original six RoHS substances, undocumented exemptions, or product groupings too broad for individual Brazilian registration.
- Finally, in-scope businesses may want to assign clear ownership for the Portuguese documentation workflow and the eventual registry entry, rather than assume their existing compliance team will absorb it by default.
Brazil RoHS reporting obligations are more demanding from an administrative perspective than the substance restrictions themselves suggest at first glance. Companies that wait for full enforcement clarity before acting are likely to be scrambling once the registry deadline arrives.
How Compliance Tools Can Help You Stay Ahead of Brazil RoHS
Tracking substance restrictions and reporting deadlines across a global supply chain—especially when a new regime like Brazil RoHS layers additional obligations on top of existing chemical restrictions—is exactly the kind of work that can become overwhelming for small internal compliance teams.
Compliance software Z2 can assist those professionals, helping companies monitor component-level substance data against multiple regulations simultaneously. With Z2, companies don't have to worry about starting their compliance process from scratch every time a new country adopts its own version of RoHS. And when paired with Z2's industry-leading electronic component search engine, teams gain visibility into which parts, suppliers, and product families need attention before an impending regulatory deadline.
To see how Z2 can help your team get ahead of Brazil RoHS and other emerging compliance regimes, schedule a free trial with one of our product experts.
