Manufacturers targeting Brazil cannot avoid ANATEL – the National Telecommunications Agency. Products with wireless transmission/reception capability that need to connect to Brazil's public network require ANATEL authorisation – without it, customs blocks shipments and e‑commerce platforms refuse listings.
The process is straightforward: a Brazilian OCD (Designated Certification Body) reviews test reports and issues an assessment opinion, which is submitted to ANATEL for final approval. Upon approval, an authorisation number is issued – the industry habitually calls it "CoH," though that term has long been deprecated officially. The product must bear the ANATEL mark plus the authorisation number in the format "ANATEL 12345-25-67890" – the middle two digits are the authorisation year. Minimum character height is generally 5mm; for very small devices, check with the OCD first.
2026 brings significant ANATEL changes: customs system integration, lithium‑battery mandatory listing, tighter module‑acceptance rules, and renewal requirements. One by one.
ANATEL divides telecom equipment into three types – but validity is not strictly tied to Type I/II/III; it depends on the specific technical Act (Ato) for each product category.
Type I: Terminal equipment connecting to the public switched telephone network – phones, satellite phones, VoIP handsets, modems. Type I certificates have no fixed expiry date – provided the product undergoes no major hardware or RF changes and continues to meet current technical standards. If standards are updated, ANATEL can require supplementary testing – failure leads to authorisation cancellation.
No expiry date does not mean permanent peace of mind. Market‑surveillance failures or standard updates can lead ANATEL to cancel directly. Annual compliance maintenance is still required.
Type II: Radio equipment not covered by Type I – Wi‑Fi routers, Bluetooth speakers, wireless adapters, LoRa modules, RF transmitters. Type II certificates typically have a 5‑year validity. The "2‑year" figure circulating is outdated.
Type III: Other ANATEL‑regulated equipment – fibre‑optic patch cords, communication cables, connectors, mobile signal amplifiers. Most Type III certificates also have 5‑year validity.
2. Module Certificate Acceptance – How to Save on Whole‑Product Testing
"The Wi‑Fi module I'm using already has ANATEL – does the whole product still need testing?" Almost every manufacturer asks this.
Yes, you can reference it – but there are conditions. ANATEL's Official Letter No. 218/2022 does not say "any module can be referenced."
Three hardware conditions:
·The module must have an independent ANATEL authorisation.
·The whole product must not modify the module's RF circuitry, antenna, or power supply.
·The whole product must not introduce additional radiation or alter RF performance.
If all three are met and the product's primary function is not RF communication – you can reference the module authorisation. Whether the module is soldered to the board or on a socket is not the deciding factor.
Critical: if the product's core function is wireless communication – 4G routers, CPEs, wireless gateways – even if all three conditions are met, most OCDs will not accept module referencing and still require whole‑product certification. The referencing path only works for products where RF is an ancillary feature – e.g., an air conditioner with Wi‑Fi. Confirm the classification with your OCD before starting – don't discover halfway through that the path is blocked.
There are many cases where soldered‑down modules still qualify for referencing. Conversely, if a removable module connects to a different antenna type, or the whole product adds an external RF PA, the hardware conditions are not met – full whole‑product certification is required.
One often‑overlooked prerequisite: the module manufacturer must be willing to grant you referencing rights. Some do not; others require a separate commercial agreement. At that point, the whole‑product manufacturer must decide – pay the licence fee or pay for full retesting.
3. Two Major 2026 New Rules
3.1 Customs System Integration (Ato nº 18,086/2025) – effective 25 May 2025. ANATEL's certification system is now linked with Brazil's Siscomex customs database. Before goods arrive, the system automatically verifies whether the importer's CNPJ, certification number, model, and NCM customs code match.
If they don't match, the system flags a red light – goods are detained, returned, or in severe cases, destroyed. Penalties depend on shipment value and violation history – mismatched documentation is a hard stop, no negotiation. SISAM provides early warnings, but customs officers retain manual review discretion – it's not a fully automated AI system.
3.2 Fixed lithium batteries added to mandatory list (Ato nº 5314/2026) – issued 14 April, mandatory from 12 October 2026. Covers fixed lithium‑ion secondary batteries used in telecom scenarios – base‑station energy storage, communication backup power – mainly 24V and 48V fixed lithium battery systems; other voltage levels must be checked against the Act boundaries. Float charge life must be at least 10 years. Consumer UPS and residential energy storage are not covered.
Test standards:
·ABNT NBR 16975 – electrical performance.
·NBR 16976 – safety requirements.
·IEC 61000‑4 series – EMC immunity.
BMS must include status monitoring and alarm upload capabilities – communication protocol is not brand‑ or model‑specific.
Certificate maintenance requires periodic re‑verification. Most OCDs require supplementary retesting at year 3 and year 6, with a full retest at year 9. Different OCDs may have slightly different schedules – confirm at project kick‑off. Environmental compliance is also required – manufacturers must submit a waste battery recycling and disposal plan.
4. Renewal – Grace Periods Are Not Standardised
A few practical points on ANATEL certificate renewal:
·Renewal window: 3–4 months before expiry. Delay is risky – OCD review queues and lab schedules will not accommodate your timeline.
·Grace periods after expiry are not standardised – they vary by product category; some categories have no grace period at all. Don't believe anyone who says "180 days across the board."
During renewal, OCDs typically require a declaration of no major changes, plus recent market‑surveillance records. If you modified the RF solution, transmit power, or frequency bands during the certificate's validity – that's not a renewal – it's a change assessment requiring retesting.
Firmware updates are also a trap. ANATEL regulations do not clearly distinguish between application‑layer and RF‑layer firmware. Never assume "this is just an upper‑layer change – no need to report." For any firmware iteration, consult your OCD first to assess whether supplementary testing is required.
5. Common Pitfalls – Lessons from Chinese Manufacturers
5.1 Certificate holder must be a Brazilian company: ANATEL does not accept overseas factories as direct certificate holders. Mainland manufacturers must use a Brazilian importer or distributor with a CNPJ as the certificate holder. If the certificate holder and the customs importer don't match, customs will not release the goods. The certificate itself does not grant exclusive import rights – exclusivity depends on your commercial agreement with the Brazilian certificate holder.
5.2 Portuguese is unavoidable: User manuals, installation guides, warning labels, and product nameplates must be in Portuguese. Circuit diagrams, BOMs, and test reports can be in English – but missing Portuguese on manuals and labels leads to rejection. Some manufacturers submit only English manuals – the review is returned, adding two weeks of back‑and‑forth.
5.3 Testing is mostly done in Brazil: Theoretically, ANATEL accepts reports from accredited overseas labs. In practice, most Brazilian OCDs only accept formal reports from local labs. Domestic labs can be used for pre‑testing and troubleshooting – but confirm with your OCD whether they will accept your chosen lab's formal report before starting. Don't test in China and then find out the report is not accepted – forcing you to send samples to Brazil for retesting.
5.4 Lithium‑battery countdown: For those exporting communication‑storage lithium batteries, there are only about two months left until the 12 October mandate. Products must pass NBR 16975 and NBR 16976, BMS must be in place, the Brazilian certificate holder must be locked in, and Portuguese documentation must be ready – all in parallel. It's tight. After the deadline, no certificate = no customs clearance – no negotiation.
ANATEL certification is not technically difficult – but getting the timing right is everything. For expert guidance, contact BlueAsia at 13534225140 (King) or email king.guo@cblueasia.com.
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