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New RoHS regulations in Brazil are about to be introduced: 10 categories of hazardous substances restrictions and corporate compliance guidelines
Time：
2025-09-23
Brazil has released a draft resolution on the Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS), aimed at restricting the use of 10 hazardous substances in electrical and electronic equipment. Relevant enterprises should immediately begin collecting supply chain information, require suppliers to provide complete material declarations, and conduct targeted testing on products if necessary to ensure compliance with limit requirements.
On August 27, 2025, the Brazilian Ministry of Environment and Climate Change (MMA) issued the G/TBT/N/BRA/1603 notification through the WTO, announcing the draft resolution on the Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS) in Brazil. The public consultation period will continue until September 24, 2025, and it is expected that the final regulation will be approved and come into effect after the consultation period ends.
Main content
01. Control product scope
The scope of controlled products includes electrical and electronic equipment and their components, cables, and spare parts with rated voltages not exceeding 1000V AC and 1500V DC, including household appliances, computers and communication equipment, lighting equipment, consumer equipment, photovoltaic modules, electrical and electronic tools, toys and sports equipment, electronic medical equipment, electronic equipment for in vitro diagnostics, veterinary equipment, monitoring and control instruments, and automatic distributors.
The exempted product categories include: defense and security equipment; Space equipment; Large fixed industrial equipment; Large fixed installation; Transportation vehicles (excluding self-propelled personal mobile devices); Non road mobile machinery; Implantable electronic medical devices; Professional photovoltaic modules; Batteries and rechargeable batteries (themselves); Equipment specifically designed for inter enterprise research and development.
02. Hazardous substances under control
The Brazilian RoHS draft refers to the EU RoHS regulations and aims to restrict the use of 10 hazardous substances in electrical and electronic equipment. They are lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers, and four phthalates (DEHP, BBP, DBP, DIBP), with limit requirements consistent with the EU RoHS 2.0 directive. Except for cadmium with a weight percentage of ≤ 0.01%, the limit for other restricted substances is ≤ 0.1% by weight.
The draft sets different compliance transition periods for different hazardous substances:
Polybrominated biphenyls and polybrominated diphenyl ethers shall be implemented from the effective date;
The mercury limit requirement has a 180 day transition period;
The limit requirements for cadmium, hexavalent chromium, and lead have a transition period of 3 years;
The limit requirements for four types of phthalates require a transition period of 4 years.
03. Core compliance requirements
Manufacturers and importers must register their products with the National Electrical and Electronic Equipment Hazardous Substance Restriction Registry and submit a self declaration of conformity. These statements must include manufacturer/importer information, product identification, statements of compliance with restriction requirements, and any exemptions from use.
Technical documents must be saved in Portuguese, proving the authenticity of the conformity statement, and kept for at least five years after the product is discontinued.
The product must have clear and durable markings, including model, manufacturer/importer name, and other information to ensure traceability. Products subject to reverse logistics constraints must be labeled with designated disposal symbols on their body.
For certain specific applications, if they cannot be replaced temporarily, temporary exemptions can be applied for. The Ministry of Environment and Climate Change will announce the exemption application process and preliminary exemption list within 180 days after the resolution is issued.
2、 Compliance recommendations
The introduction of the Brazilian RoHS resolution draft is not accidental. As early as the end of 2017, the Brazilian government announced plans to develop regulations similar to the EU RoHS directive. Once the Brazilian RoHS resolution draft is passed, export companies will have a transition period ranging from 180 days to 4 years to adapt to the restrictions of different substances. Relevant companies should immediately begin collecting supply chain information, require suppliers to provide complete material declarations, conduct targeted testing on products if necessary to ensure compliance with limit requirements, and establish compliance technical documents and product labeling. It is recommended that companies closely monitor the subsequent release of exemption lists and registration procedure guidelines, submit exemption or registration applications in a timely manner, and ensure the continued compliance of exported electrical and electronic products.
As a professional third-party testing and certification service organization, Jiayu Testing has qualifications such as CMA, CNAS, CPSC, and has obtained laboratory accreditation from multiple authoritative certification agencies at home and abroad. Jiayu Testing has rich project experience in the field of RoHS hazardous substance control, relying on advanced instruments and equipment and a professional laboratory technology team to provide customers with customized raw material and whole machine restricted substance testing solutions, assisting enterprises in actively responding to regulatory requirements, helping them achieve hazardous substance risk control, and effectively improving product compliance. Welcome to contact us at 400-9269-886!
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