Brazil RoHS Draft Regulation: What You Need to Know to Stay Compliant

Brazil’s electronics industry is on the brink of a regulatory shift — and if you're still assuming RoHS is just a European affair, think again.

The Brazilian National Council for the Environment (CONAMA) has released a draft resolution that mirrors the EU RoHS but with local twists. It’s called the Restriction of Hazardous Substances (RoHS) for Electrical and Electronic Equipment, and it sets out to limit 10 substances across a wide range of products.

Here’s the breakdown every manufacturer, importer, and compliance officer needs to understand — before enforcement becomes reality.

What Is Brazil RoHS?

Brazil RoHS is a draft technical regulation designed to control the use of hazardous substances in electrical and electronic equipment (EEE). It aligns with the EU RoHS Directive but includes region-specific timelines, obligations, and exemptions.

This draft is under final review — but its core structure is unlikely to change.

Regulated Substances Under Brazil RoHS

Brazil’s draft RoHS regulation restricts the following 10 hazardous substances, consistent with EU thresholds:

Brazil RoHS Compliance Timelines: What You Need to Prepare For

Brazil RoHS uses a phased implementation approach, allowing manufacturers time to adapt:

• Mercury: Already restricted since 2020 under national lighting legislation
• PBB, PBDE: Immediate effect upon final publication
• All other substances: Subject to a 4 to 7-year grace period depending on the product category

Expect targeted implementation per product type, announced in future annexes or resolutions.

Brazil RoHS Labeling & Documentation Requirements

Companies will need to:

• Affix proper hazardous substance labeling on packaging and products

• Issue a Declaration of Conformity (DoC) per Article 12

• Maintain a technical file with:

  • Product descriptions
  • Bill of materials (BoM)
  • Test reports or supplier declarations
  • Conformity statements

• Keep documentation for 5 years after market placement

Brazil RoHS Market Surveillance and Enforcement

Brazil’s version of RoHS isn’t just symbolic — enforcement is real:

• Environmental agencies will inspect products and documentation

• Penalties for non-compliance may include:

  • Fines
  • Sales bans
  • Product recalls
  • Criminal liability under national environmental law

Don’t wait for the first enforcement blitz to get your house in order.

Brazil RoHS Key Takeaways for Manufacturers & Importers

• Don’t underestimate Brazil RoHS just because it’s in draft form — it will become enforceable.
• Align your substance controls with EU RoHS best practices today.
• Start compiling a centralized technical documentation library for your affected SKUs.
• Automate compliance tracking across suppliers to reduce risk.

Get Ahead with Acquis RoHS Compliance Automation

Acquis helps manufacturers and importers eliminate compliance uncertainty.

Automated supplier outreach & data collection Real-time tracking of hazardous substance levels Brazil-ready declaration & documentation workflows AI-powered alerts for updates & deadlines

Book a demo today and see how Acquis keeps you audit-ready across every market — Brazil included.

Disclaimer: Final legislative publication is pending and may alter compliance deadlines.