By Gabriel Taison Campanholo and Luísa Fernandes Pereira
The Brazilian import environment has historically been characterized by complexity, high costs, bureaucratic hurdles, and low predictability—factors that directly affect national competitiveness. This scenario, however, is undergoing a significant transformation due to the New Import Process (NIP), a government-led modernization initiative that is now converging with the upcoming changes arising from the Tax Reform.
Accordingly, this article explores how the NIP is being implemented and why aligning its main instrument—the Single Import Declaration (DUIMP)—with the country’s new tax framework is essential to ensure greater predictability and legal certainty in the coming years.
1. New Import Process and the DUIMP: what it is and how it will work
The New Import Process (NIP) is a government program aimed at restructuring, simplifying, and reducing bureaucracy in Brazilian imports. It is centered on the Siscomex Single Portal, which replaced the former Siscomex system in force since 1993. The NIP was designed to address obstacles in the import flow, seeking to reduce bureaucracy, speed up procedures, improve efficiency, and create a centralized point of interaction between private operators (importers, freight forwarders, carriers) and various public authorities, such as the Brazilian Federal Revenue Service. More than a simple system upgrade, the program represents a modernization policy intended to align Brazil with the globalized economy.
In addition to operational changes to Brazilian imports, the NIP also introduces the Single Import Declaration (DUIMP). This declaration is the core element of the new process, consolidating in a single electronic document all customs, administrative, commercial, financial, tax, and logistics information. It replaces the former Import Declaration (DI) and Simplified Import Declaration (DSI) and integrates modules such as the Product Catalogue and the Attribute Registry.
Under the previous model—the DI—the process was complex and fragmented, as authorizations from consenting authorities (such as ANVISA, IBAMA, MAPA, among others) were obtained through parallel procedures, resulting in delays and bureaucracy. The DUIMP dramatically simplifies this scenario, as the Foreign Trade Single Portal will operate as a single window, integrating all relevant stakeholders and authorities. Based on the data provided in the DUIMP, the consenting authorities perform their validations separately, allowing for parallel processing and greater agility. It is even possible to declare the import before the goods arrive in Brazil, accelerating the process and standardizing customs clearance while the goods are in transit.
Another innovation of the new process is the creation of the Licenses, Permits, Certificates, and Other Documents (LPCO) module, which replaces the Import License (LI). Its main differentiating feature is that product information is provided only once for all consenting authorities. A representative characteristic is the possibility of using the same LPCO for multiple DUIMP operations. Accordingly, LPCO licenses operate under different security levels, depending on the risk associated with the imported item:
a. Level 1: Items exempt from licensing, monitored by authorities through the DUIMP and the Product Catalogue.
b. Level 2 (Flexible LPCO): Allows use across multiple import processes, generating cost savings and reducing bureaucracy. Balance control is managed by the document itself.
c. Level 3: Individual LPCO for each process, generally applicable to high-risk materials.
d. Level 4: Documentary or physical inspection, centralized in a single window.
In the new DUIMP, the risk parameterization channels will remain the same, with some improvements—particularly regarding information transparency. Once the customs broker accesses the DUIMP consultation screen in the Single Portal, they will be able to view the results of the import risk analysis more clearly. In this context, a new feature to be implemented is the Consolidated Channel, which will serve as the main parameterization channel. Its color will always reflect the combined result of the Brazilian Federal Revenue Service channels and the inspection channel, for which MAPA or ANVISA will be responsible.
In addition to the DUIMP and the LPCO, the Single Portal will also incorporate another innovation: the implementation of the Product Catalogue. This tool will allow importers to describe goods in a standardized manner, including correct tax classification and the completion of Attributes linked to each NCM code, enabling the reuse of this information in future imports. As a result, greater speed in the process and a reduction in data entry errors are expected.
The NIP pilot project, focused on the Single Import Declaration (DUIMP), began in October 2018 and has since shown steady progress toward full implementation. The definitive migration schedule to the DUIMP is being carried out in a phased and gradual manner; however, the expectation is that by 2026 all operations will be registered via DUIMP, and the Siscomex (LI/DI) system will be completely decommissioned.
2. The Tax Reform scenario for imports
The Consumption Tax Reform, established by Complementary Law No. 214 of 2025, introduces the Brazilian Dual VAT, which replaces several existing taxes. These include the Tax on Goods and Services (IBS), under state and municipal jurisdiction, which replaces ICMS and ISS and reduces the IPI rate to zero, except in the Manaus Free Trade Zone; and the Social Contribution on Goods and Services (CBS), under federal jurisdiction, which is intended to replace PIS and COFINS.
The legislation dedicates an entire chapter exclusively to IBS and CBS on imports, establishing taxation on the import of goods or services from abroad carried out by individuals, legal entities, or entities without legal personality, even if they are not registered or required to register under the regular IBS and CBS regime, regardless of the purpose of the import.
With respect to the importation of tangible goods, operations will be subject to IBS and CBS when the taxable event is the entry of goods of foreign origin into Brazilian territory. The tax assessment moment may occur upon the release of goods for consumption clearance, upon the release of goods subject to the special customs regime of temporary admission for economic use, or upon the assessment of the corresponding tax credit.
For taxation purposes, the place of import corresponds to the place where the goods are delivered to the final recipient, the principal domicile of the purchaser of bonded goods, or the place where loss or misplacement is identified.
The tax base will be the customs value plus: (a) Import Tax (II); (b) Selective Tax (IS); (c) Siscomex usage fee; (d) AFRMM—Additional Freight Charge for the Renewal of the Merchant Marine; (e) Contribution for Intervention in the Economic Domain levied on imports and CIDE-Fuels; (f) anti-dumping duties; (g) countervailing duties; (h) safeguard measures; and (i) any other taxes, fees, contributions, or duties levied on imported goods up to their release. The Complementary Law also clarifies that IPI, ICMS, and ISS are not included in the IBS and CBS tax base.
Furthermore, there is no indication of a special import regime. Therefore, the applicable rates are the same as those levied on the domestic acquisition of the respective goods, subject to specific provisions regarding rate setting for imports of goods subject to special taxation regimes.
The transition to this new system will be gradual, starting in 2026 with test rates and reaching full effectiveness in 2033.
3. The importance of alignment with the Tax Reform
The NIP, through the Single Import Declaration and Centralized Payment, serves as a powerful technological foundation for tax management, making it an essential precursor to the Tax Reform.
I. Data Centralization and Risk Management
By consolidating all customs, tax, and fiscal information in the DUIMP, the NIP provides high-quality data. As the Tax Reform introduces two broad-based taxes (IBS and CBS) that unify or simplify taxes such as ICMS, IPI, PIS, and COFINS, the DUIMP and the Product Catalogue will ensure standardized and transparent tax bases and tax incidence for audit purposes.
II. Unified Payment Platform
The Centralized Foreign Trade Payment Platform (PCCE) already enables the management of federal tax payments via automatic bank debit and state taxes through declaration/request via the State Treasury Departments (SEFAZ) within the same platform. This integration capability is crucial, as the reform introduces two new taxes with divided jurisdiction. The PCCE is already technologically prepared to function as a “single counter” for tax collection, simplifying compliance for importers by eliminating the need for multiple systems.
III. Tax Benefits and Cash Flow
In addition, proposals under discussion rely on the new process, such as allowing certified Authorized Economic Operator (AEO) companies to collect federal taxes by the 20th day of the month following the declaration registration. This change, supported by confidence in the NIP and DUIMP systems, represents a significant cash flow benefit for importers.
This prior effort toward tax integration becomes crucial in light of the Consumption Tax Reform. In summary, the modernization of government systems such as the DUIMP and the PCCE is not merely a procedural change; it represents the adaptation of Brazil’s digital infrastructure to support a more efficient business environment and, in the future, to more smoothly absorb legal and tax changes aimed at simplifying the country’s complex tax landscape. The NIP is paving the digital highway on which the reformed tax system will travel.
4. Validation by public and private stakeholders and collaborative governance
The effective implementation of the NIP will depend on validation and alignment between the public and private sectors, ensuring predictability and security in customs operations, as clarified in a Brazilian Federal Revenue Service live session. Accordingly, the monitoring of the migration of import operations to the NIP will be conducted jointly by the Secretariat of Foreign Trade (SECEX), the Federal Revenue Service, consenting authorities, and private sector representatives within the CONFAC Cooperation Subcommittee.
This collaborative process will involve periodic meetings of the Cooperation Subcommittee, whose main objective is to identify and address issues related to the migration of imports. In this regard, the private sector is responsible for submitting detailed reports of issues that hinder migration to the Single Portal to the CONFAC Executive Secretariat. Such communication must take place during the Cooperation Subcommittee meetings, which are scheduled through March 2026, in accordance with the LI/DI Decommissioning Schedule.
This governance model ensures that system implementation occurs with validation from both sectors, adjusting procedures, resolving system-blocking errors, and ensuring greater transparency of the new system.
5. Anticipating scenarios
The transition to the New Import Process, with mandatory use of the DUIMP and prior completion of the Product Catalogue, requires importers to adapt their internal processes, invest in staff training, and ensure technological integration of their systems with the Single Portal. Companies that anticipate these adaptations are more likely to reduce risks, costs, and lead times, thereby gaining competitiveness.
The tax practice of Marins Bertoldi Advogados continuously monitors the stages of NIP implementation and the regulations arising from the Tax Reform and is fully available to assist companies in analyzing impacts, adapting processes, and handling all demands related to the new import environment.
