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CONAMA 516/2026 in Brazil includes mandatory control of brominated flame retardants
Author.
LCS
Source:
Post time:
2026-08-11
On July 8, 2026, the Brazilian National Council for the Environment (CONAMA) signed Resolution 516 (RESOLU ÇÃ O CONAMA N º 516), which came into effect immediately after its publication in the Federal Official Gazette (DOU) on July 10.
This is Brazil's first nationally unified regulation on the restriction of hazardous substances in electronic and electrical equipment (EEE), commonly known as "Brazilian RoHS" in the industry. The regulation benchmarks the EU RoHS framework, restricting 10 types of hazardous substances at the level of homogeneous materials and setting a phased compliance transition period for categories such as communication equipment.
Scope of Application
Control object: Electronic and electrical equipment with a rated voltage not exceeding 1000V AC/1500V DC, as well as its components, cables, and spare parts.
Clearly covering: computers and communication equipment, household appliances, lighting equipment, consumer devices, photovoltaic modules, electronic medical equipment, monitoring and control instruments, etc.
Main exemptions: Defense and security equipment, spacecraft and ground equipment, large fixed industrial installations, transportation vehicles (excluding self-propelled personal mobile devices), non road mobile machinery, implantable medical devices, batteries, pure research and development equipment, etc.
Limit values for 10 types of hazardous substances (homogeneous materials)
① Lead (Pb) → 0.1%
② Mercury (Hg) → 0.1% (must also meet the stricter requirements of Brazilian Law 9470/2018)
③ Cadmium (Cd) → 0.01% (stricter than other metals, prone to pitfalls)
④ Hexavalent chromium (Cr ⁶⁺) → 0.1%
⑤ Polybrominated biphenyls (PBB) → 0.1%
⑥ Polybrominated diphenyl ether (PBDE) → 0.1%
⑦ - ⑩ Four types of phthalates (DEHP/BBP/DBP/DIBP) → 0.1% each
Transition period in stages
This is the core rhythm of the entire regulation. Each node represents a batch of material transitioning from 'transition' to 'coercion'.
Today (July 10, 2026) - PBB and PBDE control measures come into effect
Bromine containing flame retardants are immediately restricted. All bromine containing flame-retardant components such as PCB boards, plastic casings, and cable insulation layers must be immediately inspected.
180 days later (around January 2027) - Mercury (Hg) control comes into effect
Lighting equipment and mercury containing components must undergo compliance verification.
Three years from now (July 10, 2029) - cadmium, hexavalent chromium, and lead pipe controls will take effect
Solder, alloys, and electroplating layers are fully included. This is the stage with the largest workload for compliance rectification, especially paying attention to the stricter limit of 0.01% cadmium.
4 years from now (2030/7/10) -4 types of phthalates will come into effect for control
Thoroughly inspect cables, soft rubber, and plastic parts.
Products and their maintenance spare parts produced before the transition period are not traceable.
compliance obligations
① Registration is completed through the National Hazardous Substance Restriction Registration System (by model or product series), and a Declaration of Conformity (DoC) is obtained. The registration system is still under construction, and enterprises must complete registration within one year after its launch.
② Portuguese durable label products must be accompanied by a Portuguese durable label, indicating the model/serial number, trademark, Brazilian contact address, manufacturer or importer information, and labeled as recyclable (with fork trash can).
③ Technical documents in Portuguese are compiled in Portuguese and retained for 5 years after the product is delisted.
④ Establish traceable records and retain them for 5 years.
⑤ The collaborative distribution/retail process of the supply chain requires requesting compliance statements from suppliers; Any non-compliance found must be immediately reported, discontinued, rectified, and recalled.
Key Tip:
The Brazilian RoHS and EU RoHS limit frameworks are consistent, but additional localization requirements such as national registration, Portuguese technical documents, product labeling, and traceability are added. Enterprises that have already met the EU RoHS requirements still need to go through the compliance process separately for the Brazilian market.
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