On August 8, 2025, Brazil’s National Environment Council (CONAMA) opened a public consultation on a draft regulation similar to the EU RoHS, proposing restrictions on 10 hazardous substances in electrical and electronic equipment sold in Brazil. The restricted substances include lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and four phthalates (DEHP, BBP, DBP, DIBP). Maximum concentration limits are 0.1% for most substances and 0.01% for cadmium, aimed at reducing environmental and health risks from electronic waste.

Key Points

1. Scope of Application Applies to all electrical and electronic equipment sold in Brazil, including household appliances, IT equipment, lighting, and medical devices. Exemptions cover national defense, aerospace, large-scale industrial equipment, vehicles, photovoltaic modules, and R&D equipment.

2. Restricted Substances and Limits

· Lead, mercury, hexavalent chromium, PBB, PBDE, four phthalates: 0.1%

· Cadmium: 0.01% Limits are measured by homogeneous material.

3. Compliance Deadlines

· Brominated flame retardants: Immediate upon enactment

· Mercury: 180 days

· Lead, cadmium, hexavalent chromium: 3 years

· Four phthalates: 4 years

4. Exemptions Temporary exemptions may be granted where substitution is technically infeasible or alternatives are unreliable, subject to Ministry approval.

5. Registration and Self-Declaration A national registration system will require manufacturers and importers to register products and submit self-declarations certifying compliance, including product identification and manufacturer details.

6. Responsibilities and Obligations Manufacturers, importers, distributors, and retailers must ensure compliance, maintain records

for 5 years, and report non-compliance immediately. Measures may include sales suspension or product recalls.

7. Labeling and Information Products must include model numbers, manufacturer details, and eco-recycling symbols to support proper disposal.

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