As a manufacturer deeply involved in the lithium battery industry for 16 years, we have seen too many Brazilian importers unable to clear customs and collect their goods due to certification issues—resulting in their goods being held by customs, paying exorbitant fines, and even being blacklisted.
This article provides a systematic compliance framework for importers based on an in-depth interpretation of Brazil’s Electronic Equipment Safety Law No. 5,648/2023 and INMETRO Technical Instruction No. 207/2024, helping to build a trade chain with controllable risks.
Core analysis of the Brazilian lithium battery regulatory system
1. Mandatory certification system (Conformidade Obrigatória)
According to the latest regulations of the Brazilian National Institute of Industrial Quality, Standardization and Metrology (INMETRO), all imported lithium batteries must meet the following certification requirements:
- INMETRO certification: applicable to industrial and energy storage lithium batteries with an energy density ≥ 100Wh (exemption: consumer electronic accessory batteries must comply with ABNT NBR 16359)
- ANATEL certification: Lithium batteries with wireless communication modules (such as LoRa and NB-IoT) must pass the electromagnetic compatibility assessment of the Brazilian National Telecommunications Agency
- IBAMA environmental compliance: According to the National Hazardous Waste Management Law (PNRS No. 12.305/2010), importers must complete the record of material composition and pay the ecological compensation tax
2. Manufacturer’s extended responsibility (EPR) mechanism
Since January 2024, Brazil has implemented the Circular Economy Act, which requires lithium battery manufacturers/importers to:
- Reverse logistics system construction: a recycling network covering 27 states nationwide (requires access to the Sistema Nacional de Informações sobre Resíduos)
- Minimum recycling rate standards: lithium recycling rate ≥ 35%, cobalt recycling rate ≥ 45% in 2025 (refer to ISO 14021 verification standards)
Brazil is the world’s fourth-largest consumer of lithium batteries (the market size will exceed $800 million in 2023), but it is also Latin America’s most stringent certification market:
According to data from the Brazilian National Metrology Bureau (INMETRO) in 2023, 37% of imported lithium batteries were returned due to certification issues, with an average processing cost of up to $12,000/cabinet; the Rio de Janeiro Customs once destroyed lithium batteries worth $5 million.
Three rules for importing lithium batteries into Brazil
1. INMETRO certification
- Applicable products: All lithium batteries with a capacity ≥ 100Wh (except mobile phone and laptop batteries)
- Certification process (at least 8 weeks):
- Laboratory testing (designated institutions such as Cepel and Labene):
- Overcharge to 2 times the voltage (must trigger the protection circuit)
- Store at 55°C for 7 days (capacity attenuation ≤ 20%)
- Drop test from 1 meter (no damage to the housing)
- Prepare Portuguese technical documentation in advance (circuit diagram + description of the protection mechanism)
2. ANATEL certification
If your lithium battery contains a wireless communication module (such as Bluetooth or GPS positioning), it must pass ANATEL certification:
- Test focus:
- Electromagnetic radiation intensity (in accordance with NR-10 standards)
- Signal interference test (2.4GHz band requires special attention)
- Marking requirements: The ANATEL number (in the format “12345-AA”) must be marked in a prominent position on the product
3. Environmental compliance: IBAMA registration + dangerous goods transport documents
- IBAMA registration:
- Submit an “Analysis Report on the Composition of Lithium Batteries” (focusing on testing the lead, mercury and cadmium content)
- Pay an environmental compensation fee (about $0.3/kg)
- Transport documents:
- UN 38.3 test report (required for air transport)
- For shipping, you need an IMO dangerous goods certificate (Class 9 dangerous goods label size ≥ 10 × 10 cm)
Small details on lithium battery labels
1. Details on Portuguese labels
- Capacity indication: must use “Wh” instead of “mAh” (e.g. 3.7V/2000mAh to be converted to 7.4Wh)
- Warning words:
- “Não desmonte ou incinere” (Do not disassemble or incinerate)
- “Mantenha fora do alcance de crianças” (Keep away from children)
- Symbol specifications:
- Trash can with a cross (≥15mm)
- Fire prevention symbol (use ISO 7010 W002 pattern)
2. 3 common mistakes
- Carton coding: must print the Brazilian tax number (CNPJ) and importer’s address
- Anti-static packaging: inland transportation requires the use of pink anti-static bags (in accordance with ABNT NBR 15703)
- Lot traceability: The production date format must be “DD/MM/AAAA” and laser-engraved (stickers are not accepted).
Guide to the most common problems for importers
- Misuse of Chinese standards: Brazil requires a cycle life test of 500 times (China’s national standard is 300 times), which needs to be confirmed with the supplier in advance
- Certification documents expired: The INMETRO certificate is only valid for 1 year! Set up an automatic reminder 3 months before expiration
- Incomplete customs clearance documents: mandatory Certificado de Livre Venda, Laudo Técnico, and Nota Fiscal Eletrônica
- Ignoring local regulations: the state of São Paulo requires additional labeling of “Reciclagem obrigatória,” and the state of Amazonas prohibits the use of polyvinyl chloride (PVC) packaging
Conclusion
In the field of lithium battery imports in Brazil, compliance capabilities have surpassed simple product quality to become a core indicator of supply chain resilience. Choosing a manufacturer partner with a forward-looking compliance layout will help you achieve sustainable value growth in the Brazilian market.
