Introduction

The highly anticipated Brazilian version of the Restriction of Hazardous Substances in Electrical and Electronic Equipment (Brazil RoHS) is entering the final stretch of the legislative process. Recently, a technical committee under the National Environment Council (CONAMA) voted to approve the revised version following the 2025 public consultation. The draft has now been formally submitted to the Technical Committee on Legal Affairs for final review; if approved, it will be presented to the CONAMA plenary session for a final vote.

For companies already compliant with EU RoHS standards, while the design of the product may already meet requirements, the real challenge lies in Brazil’s unique local compliance procedures - specifically mandatory product registration and self-declarations of conformity.

This guide outlines the key requirements of the proposed Brazil RoHS regulation and highlights the practical compliance steps companies should prepare for.

Key Requirements of the Proposed Brazil RoHS Regulation

Substance Restrictions: Highly Aligned with the EU

The Brazil RoHS draft almost entirely mirrors the EU RoHS standards regarding restricted substances and their maximum concentration limits:

The Real Challenge: Local Market Access Obligations

Compared to the EU model, the Brazilian government has layered additional market access requirements, which are the primary source of compliance pressure for companies:

• Mandatory National Database Registration: All regulated products must be registered in an upcoming established Brazilian national registry system.

• Exclusive Declaration of Conformity (DoC): Companies cannot enter the market solely based on an EU DoC; they must issue a self-declaration that meets specific Brazilian requirements.

• Traceability and Labeling: Product bodies, packaging, or accompanying documents must include specific symbols and identification information.

What Companies Must Prepare for Under Brazil RoHS

Even if a product is fully compliant with EU RoHS, companies must still prepare for the following under the new Brazilian regulations:

• Mandatory Pre-market Registration: Registration in the system must be completed before the product can be sold in the Brazilian market.

• Compliance Localization: There must be a legal entity or individual located within Brazil responsible for product registration and legal liaison. Technical documentation and declarations of conformity must be prepared in Portuguese.

• Sampling and Testing Readiness: Brazilian federal regulatory agencies have the right to sample batches on the market and may even require testing in accredited laboratories to verify substance content.

Latest Legislative Developments

The Technical Committee on Environmental Quality (CTQA) discussed the revised draft in early 2026. According to the latest feedback, the draft removed the requirement to provide product photos in the declaration of conformity to protect trade secrets. However, it strengthened the obligation to publicize corrective measures via mass media for non-compliant products.

The upcoming implementation of Brazil RoHS marks a significant rise in "green barriers" within the South American market. Companies should realize that the focus of compliance is no longer just "material substitution" at the engineering level, but rather the establishment of a local compliance framework.

Compliance Recommendations from REACH24H

REACH24H recommends that relevant enterprises begin auditing their supply chain responsibilities within Brazil as soon as possible and start preparing localized technical documentation. We will continue to monitor further developments regarding Brazil RoHS.