RoHS in 2026: Essential Updates From the EU, Uzbekistan, Vietnam, and Brazil
This blog was originally posted on 19th March, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.
AUTHORED BY JOYCE COSTELLO, SENIOR REGULATORY COMPLIANCE SPECIALIST, COMPLIANCE & RISKS
Key Insight
Global RoHS regulations are undergoing significant change, with the EU transferring exemption and restriction procedures to ECHA, proposing digitalisation of compliance documentation, and revising its harmonised standard. Simultaneously, new or emerging RoHS frameworks in Uzbekistan, Vietnam, and Brazil are advancing, each with distinct local requirements but broadly aligned with EU substance restrictions. Compliance teams should act now to understand how these developments affect their documentation, exemption strategies, and market access obligations.
Introduction
Since we last wrote about regulatory developments in the RoHS area, with a focus on China RoHS specifically, there have been some critical changes in the EU and beyond, a synopsis of which is the aim of this update.
Looking for a high-level snapshot of RoHS rules impacting EEE today? Download our Global RoHS Comparison Table.
EU RoHS
Simplified Procedures Under Directive (EU) 2025/2456
On 1 January 2026, Directive (EU) 2025/2456 entered into force, allocating existing scientific and technical tasks normally performed by the EU Commission to the European Chemical Agency (ECHA; ‘the Agency’), with effect from 13 August 2027.
Directive 2011/65/EU contains two procedures relating to the assessment of chemicals: the evaluation of economic operators’ applications for granting, renewing or revoking an exemption from the substance restrictions and the review of substances to be added to the list of restricted substances. Directive (EU) 2025/2456 transfers both procedures to the remit of ECHA.
Economic operators managing RoHS compliance have been left frustrated with a protracted and inefficient exemption procedure for the most part of RoHS 2’s existence, and the EU Commission has responded by acknowledging its lack of chemicals-related expertise which has led to the administrative delays.
Changes to Exemption Applications from 13 August 2027
For parties who rely on exemptions to comply with EU RoHS, or who intend on making an exemption application, such application will need to be made to ECHA, instead of the EU Commission. ECHA will handle the administrative steps, including acknowledging receipt, verifying completeness, notifying the Commission, and inviting public comments.
Once ECHA considers the application to be complete, it must request the opinion of the Committee for Socio-economic Analysis, in addition to the opinion of the Committee for Risk Assessment.
The time limit for making an application for renewal of an exemption remains unchanged: it must be made no later than 18 months before the exemption expires.
The Commission is required to adopt a decision on the application within 9 months of receipt of the opinions from the Agency Committees. As is currently the case, the existing exemption will remain valid until a decision on the application for renewal is adopted by the Commission.
ECHA, in agreement with the Commission, will establish a harmonised format and comprehensive guidelines for exemption applications, to be published in either 2026 or 2027.
Changes to Substance Restrictions
ECHA is now formally assigned a role in the restriction process, making it consistent with the restriction process under EU REACH.
The list of restricted substances in Annex II will be reviewed by the Commission periodically and at least every 4 years.
Restriction dossiers, which propose new restrictions, can be prepared by a Member State or by ECHA at the request of the Commission.
Omnibus IV: Proposed Digitalisation and Common Specifications
The European Commission is taking steps to modernize EU product legislation by proposing significant changes to how product documentation is handled. As part of the Omnibus IV Simplification Package, the Commission has released two proposals aimed at removing outdated requirements for paper-based documentation, with the goal of reducing administrative burdens for businesses.
While the EU Commission now advocates for the ‘digital by default’ principle, current EU product legislation still often requires essential documentation to be provided in paper format. Even though the New Legislative Framework (NLF) does not mandate a specific format for instructions for use, market surveillance authorities commonly expect them to be in paper form.
Proposed Changes: Digitalisation
The proposals would amend several harmonised product laws under the NLF, including EU RoHS, as follows:
- Require the EU declaration of conformity to be drawn up in electronic form and made accessible via a web address or machine-readable code.
- Mandate that manufacturers include a ‘digital contact’ on products to improve communication with economic operators and national authorities.
- Allow instructions for products to be provided in electronic form, with the exception of safety information, which would continue to be demanded on paper or marked on the product for consumers.
- Change reporting obligations to national authorities to ‘electronic form’ only, moving away from the option of ‘paper or electronic format’.
- Introduce a requirement for electronic exchanges between economic operators and competent authorities.
- Stipulate that information from the EU declaration of conformity and instructions must be included in the digital product passport, when relevant legislation requires it.
Proposed Changes: Common Specifications
EU RoHS does not currently offer any uniform alternative to traditional harmonised standards for demonstrating conformity. Omnibus IV seeks to change this, by adding a provision for the use of ‘common specifications’ as an alternative to harmonised standards.
Common specifications will be a set of technical requirements, other than a standard, that provide a means of complying with the essential requirements applicable to a product. Products that comply with these common specifications benefit from a presumption of conformity, identical to the benefit provided by harmonised standards.
Under the Omnibus IV proposal, the European Commission can adopt these specifications via implementing acts in “exceptional” circumstances:
- Absence of harmonised standards
- Insufficient harmonised standards
- Urgent need to address non-compliant products or materials.
Unlike harmonised standards, common specifications will be freely available to the public.
Revision of EN IEC 63000
The European Commission has initiated the revision process for RoHS harmonised standard EN IEC 63000:2018 by issuing an implementing decision to CENELEC on 18 December 2025.
The request reflects the EU’s expectation of more structured “internal production control”, with clear and auditable documentation.
The Commission wants CENELEC to explain when analytical test results are required. Where there is any indication of a risk to RoHS objectives, then analytical test results must form part of the technical documentation.
CENELEC is therefore being asked to develop clear, verifiable criteria for determining when there is a “risk” that a component may contain restricted substances.
A risk would be assumed, for example, when an Annex III/IV exemption is (or was) used and it is unclear whether the exemption threshold is exceeded, or where the exemption has no threshold. The risk assessment would also consider the trustworthiness of suppliers and other criteria; if a past non‑conformity was found, a risk is assumed.
If a RoHS exemption is used, this would need to be explicitly indicated in the technical documentation.
The decision explicitly links the future version of EN IEC 63000 to digital product passport needs. For example, the standard must make it possible for relevant data to be moved simply and securely from the technical documentation into a future digital product passport for use by third parties.
CENELEC is required to have completed and formally adopted the revised standard by 19 August 2028.
Uzbekistan RoHS
Uzbekistan is for the first time addressing concerns over toxic chemicals in electronics, through Resolution No. 517 approving technical regulations on restricting the use of hazardous substances in electrical and electronic products.
The list of restricted substances and thresholds, aligned with EU RoHS, apply to most electronics, from household appliances to IT products, toys, lighting and cables, with medical devices and large industrial equipment currently excluded from scope.
Before products hit the Uzbek market manufacturers must confirm compliance through a declaration or official certification at the applicant’s discretion, in accordance with the established schemes.
Although Uzbekistan maintains a list of exemptions, it has not mapped EU RoHS exemptions to their RoHS regulation, so it is unsafe to assume that where an exemption is currently valid in the EU, it also applies in Uzbekistan.
In response to widespread concern within industry about the feasibility of meeting the tight deadline originally established – 16 February 2026 – the Cabinet of Ministers has postponed the commencement of obligations to 16 February 2027. This 12-month “breathing room” is a significant win for manufacturers, allowing more time to ensure all technical documentation and substance restrictions are fully aligned with the new standards.
The supplementary time is also appropriate considering Uzbekistan’s ongoing reform of its technical regulation system, aimed at improving market oversight and aligning standards with international practices.
Under the revised system a national conformity mark, Conformity Uzbekistan (CUz), will be applied to products subject to technical regulations, including Uzbekistan RoHS, from 1 January 2027. A draft resolution detailing the precise rules and conditions for the use of the conformity mark is currently being considered.
Proposed Vietnam RoHS
The draft mandatory Vietnam RoHS technical regulation (QCVN) circulated in 2022 has not to date been approved, and remains unfinalised / pending, despite an intended 2026 start date.
However, in January this year, the Ministry of Trade issued 5 measures to implement the newly-commenced Chemicals Law No. 69/2025/QH15. Among these was Circular No. 01/2026/TT-BCT which introduces through Annex XIX a list of hazardous chemicals in products requiring information disclosure.
The following substances which are typically regulated under RoHS rules require disclosure, when used in the products specified:
- Lead: in batteries and electronic products
- Cadmium: in electronic products
- Mercury: in light bulbs
- Hexavalent chromium: in anti-rust paint, chrome-plated steel, batteries and electronic products.
Although not defined in the Circular, ‘electronic products’ should be given its ordinary meaning unless or until future MOIT guidance clarifies it.
Disclosure is performed in accordance with Article 29 of implementing Decree No. 26/2026/ND-CP. In summary, it entails declaring the concentration of these substances in the National Chemical Database before the products are sold, in addition to publicly disclosing this information on the product label or on a website.
Crucially, this disclosure obligation applies to the extent that no technical regulation exists. In other words, it fills the RoHS regulation lacuna and, should the RoHS QCVN be adopted, it would likely override this or reduce reliance on the disclosure rule.
For a deep dive into Vietnam’s New Chemicals Framework, check out our blog.
Proposed Brazil RoHS
Brazil’s proposed RoHS Resolution has finished progressing through the CONAMA committees and now proceeds to the final decision phase within CONAMA’s internal process, Plenária do CONAMA Plenary (full council).
The proposed Resolution would introduce EU‑aligned substance restrictions and a mandatory national registration and self‑declaration system.
The proposal applies to most electrical and electronic equipment (EEE) up to 1000 V AC/1500 V DC, including cables and spare parts, with a list of typical EEE categories (IT/telecom, lighting, consumer, tools, toys, medical, monitoring, etc.), with batteries and accumulators explicitly excluded.
Phased transition periods are established by substance group: immediate application for PBB/PBDE, 180 days for mercury, 3 years for cadmium, hexavalent chromium and lead, and 4 years for the four phthalates DEHP, BBP, DBP and DIBP.
Mandatory Registration
Manufacturers or importers will be required to register each equipment, model or product family in the National Register of Electrical and Electronic Equipment with Restrictions of Hazardous Substances, prior to manufacturing for or importing into the national market.
Declaration of Conformity Procedure
The proposal builds a Brazil‑specific self‑declaration regime, without the need for third‑party certification. For each equipment/model/family, the declaration must include at least:
- Identification data of the foreign manufacturer and the importer (for imported EEE).
- Identification of the person responsible for the registration.
- Statement of compliance with substance restrictions for relevant parts, or identification of applicable exemptions.
- A responsibility statement for the truthfulness of the information.
The declaration will need to accompany the product, either physically or via digital access means, and be available online.
A one‑year transition period will run from the date of the system’s availability for inclusion of information and issuance of self‑declarations for existing products.
Exemptions
An exemption mechanism is provided for specific applications. The Ministry of the Environment and Climate Change will decide on the inclusion, modification, renewal and revocation of exempted materials/components for EEE. Similarly to EU RoHS, requests for renewal must be filed up to 18 months before the exemption’s expiry date and while a renewal request is under review, the existing exemption remains valid. Within 180 days of the Resolution’s gazetting, the Ministry of Environment and Climate Change must publish a list of exempted EEE and their validity periods, as well as guidelines and criteria for applying for, renewing, or revoking exemptions.
Conclusion
Global RoHS frameworks are continuing to mature. The shift toward digitalised documentation and centralised chemical oversight – particularly within the EU – will in the coming years mark a significant transition for the EEE industry. While new regulations in Uzbekistan, Vietnam, and soon in Brazil do introduce specific local nuances, the overarching trend is increased transparency and a growing alignment with international standards.
Frequently Asked Questions
- From what date do EU RoHS exemption applications need to be submitted to ECHA instead of the EU Commission? From 13 August 2027, exemption applications must be submitted to ECHA rather than the EU Commission. ECHA will handle administrative steps including acknowledging receipt, verifying completeness, notifying the Commission, and inviting public comments.
- Has the deadline for Uzbekistan RoHS compliance changed, and when does it now apply? Yes. The original deadline of 16 February 2026 was postponed by the Cabinet of Ministers by 12 months. Obligations now commence on 16 February 2027.
- Can manufacturers assume that an EU RoHS exemption is also valid under Uzbekistan RoHS? No. Although Uzbekistan maintains a list of exemptions, it has not mapped EU RoHS exemptions to its own regulation, so it is unsafe to assume that an exemption valid in the EU also applies in Uzbekistan.
- What is the current status of Vietnam RoHS, and what disclosure obligations exist in the meantime? The draft mandatory Vietnam RoHS technical regulation remains unfinalized and pending despite an intended 2026 start date. In the interim, Circular No. 01/2026/TT-BCT requires disclosure of certain hazardous substances – including lead, cadmium, mercury, and hexavalent chromium – in specified products via the National Chemical Database and on product labels or a website. This disclosure obligation applies to the extent that no technical regulation exists.
- Does Brazil’s proposed RoHS Resolution require third-party certification? No. The proposal builds a Brazil‑specific self‑declaration regime, without the need for third‑party certification. Manufacturers or importers must register each equipment, model or product family in the national register and issue a self‑declaration of conformity prior to manufacturing for or importing into the national market.
Stay Ahead Of Regulatory Changes in RoHS in 2026
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