Brazil - Approves Draft RoHS Resolution

Further to Alphabet Newsletter on 8th August 2025, the National Environmental Council (CONAMA) approved a draft resolution on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (EEE) Manufactured, Imported, Distributed, and Marketed in Brazil.

The draft proposes concentration limits for ten hazardous substances, with a phased implementation schedule depending on the substances concerned, and establishes an exemption mechanism. The overall framework is generally aligned with the EU RoHS Directive.

The draft also proposes the establishment of a National Register for EEE Subject to Hazardous Substance Restrictions.Manufacturers or importers would be required to register their products before they enter Brazilian territory and generate a Declaration of Conformity (DoC) for each EEE, product model, or product family. The DoC must be linked to the registration information, and manufacturers or importers are responsible for the accuracy of the declaration and the product’s compliance.

In addition, manufacturers or importers would berequired to maintain technical documentation in Portuguese and ensure product traceability by providing information such as the product model, serial number, and manufacturer or importer details.

The draft resolution is proposed to enter intoforce on the date of its publication in Brazil’s Official Gazette. Alphabet Team will closely monitor further developments and provide updates accordingly.