Brazil INMETRO Ordinance 231/2026 Takes Effect! Mandatory Certification for LED Lamps Greatly Expanded
The Brazilian National Institute of Metrology, Quality and Technology (INMETRO) has officially issued Portaria nº 231/2026. The ordinance approves the Unified Technical Quality Specifications, Conformity Assessment Requirements and National Energy Conservation Label (ENCE) Rules for LED luminaires and lighting equipment, formally repealing the four-year-old Portaria nº 69/2022. It substantially expands the scope of products subject to mandatory certification for LED lamps and tightens access requirements covering optics, electrical safety and market surveillance. As Latin America’s largest destination for China’s exported lighting products, the comprehensive overhaul of Brazil’s certification rules will directly shape foreign trade layouts of lighting industrial clusters in South China, including the Pearl River Delta, Zhongshan and Foshan.
I. Significantly Expanded Regulatory Scope: Major Luminaire Categories Included in Mandatory Certification
Compared with the previous regulation, the landmark change under the new rule is that supervision is no longer limited to LED bulbs and light sources. All integrated LED luminaires for industrial, commercial and residential applications fall under INMETRO mandatory certification, covering mainstream commercial and residential lighting products such as indoor panel lights, recessed downlights, outdoor garden lights and all-in-one integrated LED luminaires.
Meanwhile, the regulation establishes a detailed list of exempt products, including but not limited to: ultraviolet lighting products, special lighting for medical, aviation, marine and automotive applications, OLED luminaires, professional stage lighting, municipal road LED luminaires fixed on street light poles, LED luminaires equipped with photovoltaic systems, extra-low voltage LED strips, Christmas decorative lighting and illuminated decorative figures, battery-powered portable LED luminaires, as well as empty lamp holders without integrated light sources that allow interchangeable bulbs.
From now on, the vast majority of domestically manufactured LED luminaires for residential fit-outs, commercial real estate and courtyard lighting must hold the new INMETRO mandatory certification certificate to clear customs and circulate in Brazil. This closes the grey channel previously exploited by some finished luminaires entering Brazil without certification under exemption clauses.
II. New Mandatory Test Items Introduced; Power Supply and Optical Design Require Rectification
To meet Brazil’s requirements for indoor eye safety and power grid energy efficiency, Ordinance 231/2026 adds multiple mandatory test items, which constitute core rectification priorities for Chinese lighting manufacturers:
Mandatory Flicker Modulation Depth Testing
All indoor luminaires shall undergo testing of the Pst flicker index (per IEC TR 61547-1:2020) and Stroboscopic Visibility Measure (SVM, per IEC TR 63158:2018), to mitigate risks posed by high-frequency flicker to human vision and nervous systems. Commercial panel lights for supermarkets and office buildings face stricter testing thresholds; low-quality luminaires with resistor-capacitor drivers will fail compliance tests directly.
Mandatory Power Factor (PF) Requirements by Power Tier
For the first time, the new rule imposes power factor requirements on low-wattage products. LED products rated between 2 W and 5 W must achieve a PF ≥ 0.40. The former regulation set no PF requirements for products below 5 W. Low-end luminaires relying on low-cost non-PFC drivers to capture Brazil’s market will face heightened compliance pressure. Specific limits and detailed requirements for higher power ranges shall follow the annexes of the official ordinance text.
Simultaneous Upgrade of EMC and Harmonic Standards
Brazil has updated electromagnetic compatibility standards to CISPR 15:2018, alongside revised harmonic current requirements aligned with IEC 61000‑3‑2:2018 (AMD2:2024). No uniform fixed percentage harmonic limits are specified; differentiated harmonic current limits apply to luminaires of different power ratings, with exact values referenced in official annex tables. Photometric testing shall adopt the LM-79 series standards, correlated colour temperature (CCT) evaluation follows the C78.377 series, and LED package test reports must comply with the LM-80 series standards.
III. Stricter Supervision: Triple Controls via Energy Label Traceability, Factory Annual Audits and Cross-border Sampling
The new regulation raises not only product testing benchmarks but also strengthens post-market surveillance and customs enforcement, sharply increasing costs for non-compliant exporters:
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Mandatory affixation of Portuguese ENCE energy labels embedded with traceable QR codes. The QR codes link directly to INMETRO’s official database for parameter verification. Certification bodies reserve the right to revoke enterprise certificates if luminous efficacy, power input, colour rendering index or other parameters are falsely labelled.
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Adoption of Certification Scheme 5. Factories holding valid certificates must undergo annual on-site audits by authorised OCP bodies to verify production line quality control and incoming component management. Certificates will be suspended if factories fail audits, eliminating the malpractice of using one certificate across multiple manufacturing sites. Enterprises with small-batch and multi-consignment export volumes may alternatively select Scheme 1b (batch testing with unlimited certificate validity) for greater flexibility.
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Reinforced random sampling for cross-border e-commerce and seaport shipments. Whether shipped as full sea containers or small parcels to Brazilian e-commerce platforms, luminaires found without valid certificates, holding expired certificates or inconsistent with certified samples will be detained, returned or confiscated. Sanctions are based on Brazil’s Law No. 9933/1999, with penalties scaled according to the severity of violations.
IV. Two-Phase Transition Period with Clear Timelines for Certificate Renewal
INMETRO introduces a phased transition framework to allow importers to deplete existing stock and manufacturers to complete product rectification, with clearly defined deadlines:
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Transition Period for Manufacturers & Exporters: Ends on 5 November 2027
During this period, luminaires certified under the old Portaria nº 69/2022 may continue production and customs clearance into Brazil. Starting 5 November 2027, Brazilian Customs will no longer accept old certificates for clearance; only products certified under the new standard will be permitted import. The strict compliance window for importers runs from 5 November 2027 to 5 May 2028, during which only luminaires with new certification are eligible for customs entry.
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Transition Period for Offline Distributors: Extended to 5 May 2030
Existing inventory already imported and placed on the Brazilian market under the previous regulation can be sold at retail until 5 May 2030. This arrangement prevents massive stock losses for importing distributors and cushions market disruption triggered by the new rule. The old regulation will be completely abolished once the transition expires.
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V. Far-Reaching Impacts: South China Lighting Industry Faces Compliance Upgrade Window
Brazil has long remained the largest Latin American export market for China’s lighting products. Numerous manufacturers in Zhongshan, Shenzhen, Foshan and other parts of South China supply panel lights, garden lights and other integrated luminaires to Brazil, capturing sizeable shares in the residential and commercial lighting import market by virtue of cost competitiveness. The expanded certification scope means South China’s lighting exporters need to carry out three key tasks: submit products for testing covering newly added flicker, PF and EMC items, obtain updated INMETRO certificates, and redesign Portuguese traceable energy labels.
In the short term, small and medium foreign trade manufacturers will incur extra testing and certification costs, while low-end luminaires equipped with non-PFC drivers will gradually exit the Brazilian market. In the long run, stringent access thresholds will phase out low-price, disorderly small-scale production capacity. Large-scale lighting enterprises with independent power supply R&D and optical design capabilities are better positioned to consolidate market share in Brazil.
In summary, demand across South America’s lighting market maintains steady growth, yet access regulations in regional countries keep tightening. Following Brazil’s upgrade of mandatory lighting certification, Argentina, Chile and other Latin American nations are also rolling out new luminaire energy efficiency rules. For lighting enterprises focusing on Latin America, this certification expansion brings compliance challenges, alongside a pivotal opportunity to phase out low-end competitors and secure premium commercial lighting distribution channels in Brazil.
