Brazil Energy Efficiency Label Requirements

If you plan to sell charging products to Brazil, or buy chargers and power adapters locally in Brazil, you will most likely encounter an energy efficiency label with a colored rating bar. Many people have a vague understanding of it: Is this label mandatory? What is its relationship with safety certification and fast charging? How to verify its authenticity? Today we will thoroughly explain the relevant rules of Brazil’s energy efficiency label, from basic knowledge to practical judgment, so that even beginners who have just come into contact with it can understand.

Basic Knowledge of ENCE

The official name of this label is **National Energy Efficiency Label**, with the Portuguese abbreviation ENCE. It is an official power-saving rating label launched by the Brazilian Energy Efficiency Program (abbreviated as PBE) for regulated products. Simply put, its core function is to tell consumers “whether this product consumes a lot of electricity”, making it easier for people to compare and choose among similar products, while encouraging manufacturers to produce more energy-efficient products.

Here we first draw a core boundary to avoid confusion later: ENCE only manages “energy consumption level”, which is completely separate from whether the product is safe, how fast it charges, or whether it supports wireless connection.

All requirements of ENCE are not set arbitrarily. Its regulatory system consists of three parts: the top level is Brazilian federal decrees, the middle level is normative instructions issued by the National Institute of Metrology, Quality and Technology of Brazil (INMETRO, a federal agency responsible for relevant metrology, conformity assessment and market supervision), and the bottom level is the rule documents for each specific energy efficiency project (called Portaria in Portuguese). That is to say, the energy efficiency requirements for different product categories may be completely different. The specific requirements shall be subject to the Portaria of the corresponding project, and there is no set of universal rules. Specific registration, conformity assessment and labeling obligations shall also be subject to the corresponding PBE project documents.

There is another easily confused label called Procel. Many people think it is Brazil’s official energy efficiency label, but in fact it is a **high energy efficiency honor label**, equivalent to an “Energy Conservation Excellence Award”, which can only be applied for by products with a very high energy efficiency level. However, it cannot replace the mandatory ENCE label at all — even if a product has obtained Procel certification, as long as it is within the mandatory scope, it must still be affixed with ENCE.

Many people ask about the order of ENCE and other compliance requirements. In fact, there is no fixed prerequisite relationship: INMETRO electrical safety certification belongs to the safety dimension. Whether to do safety first and then energy efficiency depends on the provisions of the specific PBE project; EMC (Electromagnetic Compatibility) and Anatel radio compliance belong to different regulatory dimensions, and are usually not equivalent to ENCE requirements. Whether they apply, and how they connect with safety and energy efficiency compliance, still need to be verified separately according to product functions and corresponding regulations. Fast charging protocols such as PD and QC only determine charging speed and compatibility, and have no direct relationship with energy efficiency.

If a product is within the mandatory control scope but is not compliant, it may face penalties such as cargo detention, fines, and removal from shelves once found. The specific circumstances shall be subject to regulations and actual law enforcement. Some platforms or specific regulated categories may require INMETRO registration, conformity assessment or label materials, which shall be subject to platform rules and applicable PBE documents for the product.

Scope of Application Judgment

After figuring out what ENCE is, the question everyone is most concerned about must be: Does my product need to be affixed with this label? Don’t guess. Use the official 4-step verification method to judge in order, and you will basically not make a mistake:

Step 1: First clarify the basic product information: What type of product is it? Is the input alternating current or direct current? Does it have a power conversion function? Is it for consumer use or industrial/medical special use? If the definition is not clear, you will definitely make mistakes when checking the rules later.

Step 2: Go to the PBE column on the official INMETRO website, check the corresponding product list and the Portaria document of this category, and confirm whether the product is in the control list.

Step 3: Even if it is in the list, you must check whether there are exemption clauses, transition period arrangements, or exception rules for special purposes. You cannot directly apply the rules just because you see similar products.

Step 4: After confirming that it is within the mandatory scope, clarify the specific compliance obligations: Is it enough to just affix the label, or do you need to complete testing, registration or conformity assessment first? Are there special requirements for sales pages and packaging?

For your quick reference, we have sorted out the verification priority of common charging products:

Product TypeWhether ENCE Verification is PrioritizedCore Notes
Wall-plug USB chargers, laptop power adapters (AC input consumer type)YesThey are in the high-probability mandatory scope, and need to be compared with the rules of the external power supply PBE project
Car chargers, wireless charging bases, power banks, industrial/medical special chargersNeed separate verificationThe rules for AC wall chargers cannot be directly applied. It is necessary to confirm whether there is a corresponding PBE project
Pure passive charging cables/data cables, adapters/female sockets without conversion chipsUsually no, but still need to be verified according to product definitionPure passive cables are usually not subject to PBE energy efficiency labels; if adapters, female sockets or cables contain active electronic circuits, they shall be re-verified according to the actual product definition and INMETRO list

People who are new to this are prone to several misunderstandings in scope judgment. Here we clarify them in advance:

First, not all products with power conversion must be affixed with ENCE. Only products included in the PBE mandatory project need it. Some power supplies for special purposes, even with conversion functions, do not need to be affixed if they are not in the list.

Second, not all products with safety certification must undergo energy efficiency assessment. Safety and energy efficiency are two completely independent systems. Whether to do energy efficiency assessment only depends on the PBE list, and there is no direct correspondence with whether there is safety certification.

Third, compliance is not required just because the power reaches a certain value. Scope determination is multi-dimensional. Product type, purpose, and input type must all be considered, not just power.

Fourth, not all USB-C fast chargers are definitely within the control scope. It still needs to be judged according to the product definition and PBE list, not just based on the interface type and fast charging function.

Official Verification Method for PBE Energy Efficiency Regulations

Some people may ask, where is it reliable to check the rules? It should be emphasized here that only the content published in the PBE column on the official INMETRO website and the Official Gazette of Brazil (DOU) is the authoritative basis. Various third-party interpretations and guides on the Internet can only be used as clues to find rules, and cannot be directly used as compliance standards.

When checking the rules, focus on verifying three types of information:

First is basic information: the full name of the energy efficiency project, the corresponding Portaria number, the release and effective dates, and whether there is a transition period.

Then is the scope of application: the clear definition of the product, requirements for input and output, power range, and whether there are usage restrictions — for example, for the same type of charger, consumer and industrial ones may not be in the same project.

Finally, compliance requirements: what test standards to use, whether there is a fixed label template, what the registration or conformity assessment process is, and how to maintain relevant documents.

All documents must be kept properly during the compliance process, including applicable regulatory texts, laboratory test reports that meet project requirements, registration or conformity assessment documents, official label templates, and technical files of Brazilian importers. It is best to mark the date of regulation retrieval, and regularly review through official channels to avoid being unaware of regulation updates.

Interpretation of ENCE Label Information

After getting an ENCE label, you cannot judge whether it is compliant only by its appearance. The layout, fields and display position of the label must be subject to the official template of the corresponding PBE project. Some projects use colored energy efficiency rating scales, while some projects may mainly mark specific energy consumption data; not all projects have the same rating bars or fields.

Specific projects such as external power supplies may list average efficiency, no-load power consumption, output information, etc., and may also include brand, model, manufacturer or importer information, as well as official marks or registration information specified by the project. However, it cannot be presumed that all ENCE labels must simultaneously include rated output, no-load power consumption, conversion efficiency, manufacturer/importer information and the so-called “INMETRO filing number”. The specific fields and label carriers shall be compared with the official template, Portaria and technical requirements of the corresponding PBE project.

Many people misunderstand the judgment logic of energy efficiency grades when looking at labels. Here is a unified explanation: for specific projects such as external power supplies, common indicators include average effective efficiency and no-load power consumption, that is, how much input electric energy is effectively transmitted when the product is working, and how much electricity it consumes itself when no device is connected. The indicators used by other PBE categories may be different, and the indicators of external power supplies cannot be directly applied to all products.

Energy efficiency grading usually sets thresholds according to product categories and power segments. Products with different powers cannot be directly compared — for example, a 10W Class A charger and a 65W Class A charger have their energy efficiency levels evaluated for their respective power segments, and it cannot be said that the 10W one is more energy-efficient. The test voltage, frequency, load point and calculation method must be subject to the Portaria and technical specifications of the corresponding project, and different projects may adopt different test conditions.

There are four common misunderstandings about labels that you must avoid:

1. **High energy efficiency = fast charging?** No. The energy efficiency grade cannot directly represent the charging speed; the charging speed mainly depends on the output power, device and protocol compatibility, while efficiency mainly reflects energy loss. The two cannot replace each other. However, efficiency will also affect heat generation, input power and the continuous output capability of some products.

2. **Are all energy efficiency grades from A to G?** No. The grading rules of different PBE projects are different. Some projects may only have 3 grades, or even only mark energy consumption data without grading.

3. **Is the value marked on the label the actual charging power?** No. That is the rated maximum output. The actual achievable power depends on whether your device supports the corresponding power and protocol.

4. **Are energy efficiency parameters safety parameters?** No. Energy efficiency mainly assesses energy consumption performance, which is not equivalent to judging safety issues such as electric leakage and overheating. Safety issues depend on the corresponding safety certification or conformity assessment requirements.

Compliance Process and Basic Requirements

If your product is indeed within the mandatory scope, the core compliance requirements can be divided into several parts:

First is pre-verification. Note that there is no unified fixed order, and it shall be in accordance with the requirements of specific projects: First, confirm whether ENCE compliance for this category requires the completion of INMETRO safety certification first, and what the connection requirements between the two are; second, laboratories with the specified accreditation scope shall be used, or other test methods allowed by the project shall be adopted in accordance with the requirements of the corresponding PBE project; third, registration, conformity assessment or label authorization shall be handled by the responsible subject specified by the project as required. Whether foreign laboratory reports are acceptable must also be checked against the project’s accreditation, mutual recognition and report requirements, and it cannot be generally asserted that all are not recognized.

Then are label and display requirements: Whether ENCE labels must be used on the product body, packaging and sales display, as well as the label position, size and durability requirements, shall be subject to the label template and Portaria of the corresponding PBE project. It cannot be uniformly presumed that all products must have the label affixed to a conspicuous and wear-resistant position on the product body. If regulations require relevant information to be displayed online, it shall also be provided in accordance with the requirements. The most important thing is the principle of consistency: the information on the label shall be consistent with the test report, registration or conformity assessment documents, product nameplate and sales materials, and shall not be modified at will.

Regarding registration and changes: The validity period, maintenance and update methods of registration, conformity assessment documents or label authorization shall be specified by the corresponding PBE project. Different projects do not necessarily have a unified fixed term. When there are changes in product model, key parameters, internal solutions or design, it shall be evaluated according to project requirements whether changes, re-testing or re-registration are needed, and the product cannot be sold directly after self-modification. If the official updates the regulations, the adjustment shall also be completed within the specified transition period.

INMETRO conducts random spot checks on products within the mandatory scope. Common violations include forging ENCE labels, product parameters not matching registration or conformity assessment information, failing to affix labels or go through relevant procedures as required. Once found, they may face penalties such as removal from shelves, confiscation and fines.

Common Pitfalls to Avoid and Quick Judgment

After finishing the rules, let’s talk about the most common pitfalls in actual operation, and how to quickly judge whether a product’s ENCE label is compliant.

Common pitfalls can be divided into two categories:

One category is product selection pitfalls: When selecting products, many people either only judge the energy efficiency grade by power, or think that high energy efficiency means good overall quality — in fact, energy efficiency is only an indicator of the dimension of power saving, and cannot be directly equated with safety, durability and charging speed. Do not take energy efficiency as the only selection criterion.

The other category is compliance pitfalls: First, using energy efficiency labels from other countries (such as US Energy Star, EU energy efficiency label) to replace ENCE. In Brazil, labels from other countries cannot replace applicable ENCE requirements; second, printing labels by yourself that have not been confirmed through the project required procedures, which may constitute forgery or improper use of official labels, and is a serious violation; third, applying consumer energy efficiency rules to industrial and medical special chargers. The control requirements of the two may be different and cannot be confused.

If you just want to quickly check for obvious non-compliance without checking the database, you can first do a 3-step visual inspection:

Step 1: Check whether the label text, fields, size and layout are consistent with the Portuguese official template of the corresponding PBE project. If the language or layout does not conform to the template, further verification shall be carried out, but the final judgment cannot be made only based on whether it is in English.

Step 2: Check the information: Are the brand and model on the label consistent with the nameplate on the product body? Are the parameters reasonable? For example, if a charger marked 65W has obviously mismatched rated output parameters, you should be vigilant.

Step 3: Check the condition: Is the label placed in the position required by regulations? Is it wear-resistant and free of alteration traces? If it is affixed to a position that does not meet the project requirements, comes off as soon as it is scraped, or has traces of character modification, you should be vigilant.

For further authenticity verification, you can check the product information through the official INMETRO PBE product or label query channel, and at the same time save the applicable Portaria, registration or conformity assessment documents and official label template. You can enter the product registration information, or use fields such as brand and model to check whether the information in the database is consistent with that on the label. The official database is an important verification channel, but the database page cannot of course replace regulations, registration documents, conformity assessment certificates or project requirements; if the information has not been synchronized, the search fields are different, etc., the judgment shall be made in combination with the project documents. Third-party query tools can only be used as auxiliary clues and cannot be used as the sole basis for compliance.

Finally, let’s talk about the procurement decision logic. Compliance must be put first:

Step 1: First confirm that the product indeed belongs to the corresponding PBE project, has completed the registration or conformity assessment required by the project, and the label usage method is true and effective — no matter how cheap non-compliant products are, do not touch them, otherwise the loss will be greater if they are inspected during sales.

Step 2: Choose according to the usage scenario: If it is for high-frequency long-term use, such as chargers that are plugged in every day at home or in the office, choose high-energy-efficiency ones, which can save a lot of electricity bills in the long run; if it is for low-frequency short-term use, such as temporary backup chargers, it is enough to meet the minimum energy efficiency requirements, which can control costs.

Step 3: If it is a special category such as multi-port charger or wireless charger, compare them according to their corresponding category energy efficiency indicators, and cannot directly compare the energy efficiency grade with single-port AC wall chargers.

Practical Operation of Typical Product Cases

After talking about so many rules, let’s take three of the most common charging products as examples, and you will understand how to apply them in practice at a glance:

65W USB-C Wall-plug Charger (AC Input Consumer Type)

This is a type of product like the commonly used GaN fast charger. First look at the product definition: AC 100-240V input, USB-C PD output, belonging to consumer external power supplies, which is a typical AC input consumer charger.

When querying regulations, you need to check the Portaria corresponding to the external power supply project under PBE to confirm whether it is within the mandatory control scope. You cannot directly conclude that it must be labeled just because it is 65W, USB-C or AC input.

First confirm whether this model is included in the mandatory scope according to the current PBE list and the Portaria of the external power supply project; if included, complete testing, registration or conformity assessment and label use in accordance with the provisions of the project. The specific laboratory, responsible subject and label carrier shall be subject to the project documents.

For other compliance, it is necessary to separately verify whether INMETRO safety certification and EMC certification are required. These are different requirements from energy efficiency, but the same product may be applicable to both, which shall be confirmed separately.

When selling, note that all information on the product label, outer packaging and online sales page must be consistent with the project documents and registration or conformity assessment content, and cannot be modified at will.

Pure USB-C Data Cable (Passive Accessory)

Ordinary passive transmission cables have no power conversion function themselves, and only transmit electricity and data.

Pure passive USB-C cables that do not contain active electronic circuits and only undertake connection functions are usually not subject to PBE energy efficiency labels. Cables and adapter products with active chips, signal conversion, power management or other electronic functions shall be verified according to the actual product definition and current PBE list, and conclusions cannot be drawn only based on the product name or interface name.

If it is confirmed that the product is a pure passive cable, it usually does not need to be affixed with an ENCE label, nor does it have corresponding energy efficiency registration requirements. However, it may still need to meet other requirements such as interface compatibility and material safety, for example, it cannot be easily broken or overheated.

When selling, you cannot promote content such as “energy efficiency grade A”, because pure passive cables are usually not within the scope of energy efficiency control, and such promotion will mislead consumers.

12V Car USB Charger (DC Input Type)

It is a car charger plugged into the car cigarette lighter. The product definition is a consumer car charging product with 12V DC input and USB output. The input is DC, which is different from the AC input of wall chargers.

When querying regulations, you must specifically check whether there is a PBE project for DC input car charging products. You must never directly apply the energy efficiency rules of AC wall chargers.

If there is no corresponding PBE project, no labeling is required; if there is, it shall be implemented in accordance with the rules of the corresponding project. Whether testing, registration or use of specific labels is required shall also be subject to the current documents of the project.

For other compliance, it is also necessary to verify whether vehicle-related safety certification is required, which is also different from the safety requirements of consumer wall chargers.

When selling, you cannot mark it with the energy efficiency grade of AC wall chargers, otherwise it may be misleading publicity, because the test conditions and grading rules of the two may be different.

Core Summary and Competence Self-check

Let’s go through the core knowledge points again for your memory:

First, ENCE is the official label of Brazil’s PBE energy efficiency program. Only products included in mandatory projects need to be used in accordance with project requirements, not all products with power supplies.

Second, the scope of application shall be judged in four steps: first clarify the product definition → then check the PBE product list → verify exemptions and transition periods → finally determine specific compliance obligations. Do not guess based on feeling.

Third, energy efficiency grades are divided according to product categories, power segments or other conditions specified by the project. Common reference indicators for external power supplies include efficiency and no-load power consumption, but the indicators, test conditions and calculation methods of different projects may be different. Energy efficiency cannot directly represent charging speed, nor can it replace the judgment of product safety.

Fourth, all specific compliance requirements shall be subject to the Portaria documents, technical requirements and official label templates of the corresponding PBE project, and there is no universal process applicable to all products.

Fifth, Procel is a high energy efficiency honor label and cannot replace the mandatory ENCE label.

After learning these contents, you should be able to independently complete the following things:

Use the 4-step method to judge whether common charging products need ENCE requirement verification; understand the core information on the ENCE label and avoid common misinterpretations; verify the compliance and authenticity of the label by combining visual inspection, official PBE query channels and project documents; select appropriate charging products according to the logic of compliance priority combined with usage scenarios; clearly distinguish the different functions of ENCE energy efficiency labels, safety certification, EMC, Anatel radio compliance and fast charging protocols, and will no longer confuse them.

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