Nota Técnica nº 24/2026/DSPRAD-SEDIGI/SEDIGI/MJ: Manifestação técnica e análise da conformidade jurídica de Smart Toys (brinquedos/dispositivos com inteligência artificial) disponíveis no mercado brasileiro (Technical Note 24/2026 on the legal compliance of AI smart toys sold in Brazil)

Key Findings

• — Six products examined: Loona, EMO, Miko 3, Aibi, Amazon Fire HD Kids Pro and Vector, available via Amazon, Mercado Livre, Shopee, AliExpress, Magazine Luiza, eBay and Casas Bahia
• — The note finds that design simulating sentience or affection (Loona described by its manufacturer as reproducing pet-like displays of affection) can encourage intense emotional bonds and calls for the technological nature to be explained clearly to children
• — For Vector, marketed with a 'living personality', the note flags the risk that a psychological-dependency bond is abruptly broken if the server infrastructure is switched off, with potential harm to emotional development
• — The analysis is described as preliminary mapping based on public information and the consultancy's diagnosis; it does not decide the merits
• — Recommendations: Senacon to investigate supplier identification, legal representation (art. 40 ECA Digital), protection mechanisms (art. 11 Decree 12.880/2026) and prominent risk information (art. 50); ANPD to examine children's data processing, profiling and behavioural advertising

Methodology Notes

Documentary and legal analysis of six products using manufacturer materials, public information and a commissioned technical diagnosis (Prof. George Augusto Valença Santos with UFRPE researchers), produced within a project to draft a Guide on AI in Childhood. No laboratory or conversational testing is reported in the passages read. Electronically signed 1 July 2026 (PDF created 2 July); the ministry news release was reported by Olhar Digital on 7 July 2026. The gov.br news page and PDF path now return 404; the PDF was read via the Wayback capture of 2026-08-09 (25 pages), which is used as the primary link.

Sources