DUIMP and the New Import Process: preparing your migration

The Right Question Is Which Operation Can Migrate

DUIMP is an integral part of the New Import Process, but its adoption should not be treated as a single, one-off form replacement for all companies. Corporate planning must assess the specific operation and the conditions published in the official rollout schedule. An option available for a particular flow does not confirm availability for all others.

Many executives begin internal discussions by asking when the company will be required to transition. This reactive stance often leads to two opposing mistakes: a disorderly rush to register incompatible shipments, or complete inertia while waiting for an across-the-board switch. The correct approach is to analyze operations case by case, separating shipments that already have regulatory and systemic support from those that still require the traditional framework.

As of the editorial benchmark of October 31, 2026, this article does not state mandatory compliance or decommissioning dates. The schedule is dynamic: check the current version during planning and again before registering the operation. Record the date of the inquiry and the parameters used during verification, creating an auditable track record of decisions made by your foreign trade management.

The transition to the New Import Process transforms the logic of customs control. Instead of submitting repetitive information with every clearance, importers begin structuring permanent master data within the Single Portal (Portal Único). To navigate this change safely, it is valuable to rely on prepared technical partners, such as customs brokerage partners with more than 25 years of practical experience, accustomed to interpreting the nuances of normative instructions and customs tax parameterizations.

Conduct a Diagnostic of Your Actual Flows

List the company's recurring flows by transport mode, merchandise, customs regime, consenting government agency, and other relevant conditions specified in the schedule. Do not rely solely on the NCM code as a summary of the entire operation. The combination of these elements can be decisive in evaluating the viable path within the regulatory environment.

An effective diagnostic requires dividing the import portfolio according to objective decision criteria:

• Mode of transport used (ocean, air, or road) and point of entry into the national territory.
• Tax classification of the operation, distinguishing direct consumption, resale, or special customs regimes.
• Involvement of consenting government agencies and the requirement for licenses, permits, or technical certifications before or after shipment.
• Packaging type—bulk or containerized cargo—observing berthing and storage rules.

For each flow, identify who verifies eligibility and who authorizes the operational procedure. If there is any doubt, clarify it before shipment. A commercial response such as “our software already handles DUIMP” does not prove that a specific import is covered by current conditions. Systems may be technically integrated with government interfaces even if the intended customs route is not yet authorized for DUIMP filing.

Avoid common mistakes during this initial phase:

• Assuming that clearance for an exempt product automatically authorizes the migration of similar items subject to physical inspection.
• Overlooking the destination bonded facility, as not all terminals operate with the same integration flows simultaneously.
• Leaving the feasibility analysis for when the cargo is already in international transit.

Select a representative pilot with stable data and an available team. Avoid simultaneously introducing an unfamiliar supplier, a complex product, and an untested integration. This ensures any issues are easier to isolate and resolve without disrupting supply flows to the manufacturing plant or distribution network.

Project governance gains strength when backed by an integrated logistics structure. Relying on more than 10 partner trading companies, partner warehousing facilities in the Santos region, and multimodal distribution solutions operated by qualified partners ensures physical predictability for cargo while internal teams validate the new digital steps of the import process.

Treat Data as Part of the Project

The product catalog and required attributes demand consistent technical information. Procurement, engineering, or quality assurance must participate; it is unreasonable to expect customs brokers to infer materials, applications, and specifications from a generic invoice description.

Under the previous model, open-ended commercial descriptions were frequently tolerated on the commercial invoice and manually adapted in the import declaration. In the New Import Process, the Product Catalog serves as a centralized data repository maintained by the importer. Incomplete, inaccurate, or divergent information that fails to reflect the physical reality of the material will halt documentary progress even before the vessel or aircraft arrives.

To organize data without rework, adopt an internal data-cleansing roadmap:

• Identify the exact composition, active ingredient, or mechanical properties of each active SKU in the company.
• Link each item to its respective foreign manufacturer, ensuring that changes in manufacturing plants are reflected in the system.
• Complete the specific attributes required for tariff classification, eliminating generic text or informal commercial descriptions.
• Standardize statistical measurement units in accordance with official Brazilian foreign trade tables.

Designate an owner for each item record, maintain version control, and establish when a product update requires review. Also verify the details of the operators involved. The information must match the merchandise actually purchased, rather than a similar record used in a previous shipment.

If system integration is involved, test the handoff points between your ERP, service providers, and the Single Portal according to available capabilities. Document failures, permissions, acceptance criteria, and support protocols. Automation without governance merely repeats errors faster, whereas well-defined manual controls help detect discrepancies during the pilot.

Communication between departments must be continuous. Procurement teams must alert foreign trade personnel whenever there is a change in supplier, technical drawings, or raw materials. Without this alignment, the product catalog quickly becomes obsolete, generating registration discrepancies that delay customs inspection and trigger additional port storage costs.

FAQ: Migration Without Shortcuts

Does DUIMP eliminate import licenses? You should not assume this. Applicable administrative controls remain in place according to the requirements of the respective consenting agencies. What changes is the control mechanism, which is now handled through specific modules of the Single Portal, such as LPCO (Licenses, Permits, Certificates, and Other Documents), requiring prior verification for each type of merchandise.

Can I freely choose between DI and DUIMP? Availability depends on the official conditions of the operation, not merely the company's preference. Each flow must be fully supported by the clearance stages established by customs authorities. As long as a given type of operation is not supported within the DUIMP environment, the importer must continue using the traditional declaration (DI).

Does a single published date apply to everything? No. The implementation process takes place gradually and is segmented by transport modes, administrative treatments, and operational characteristics. Check the scope, conditions, and schedule updates before making the filing decision for any import batch.

Does the Product Catalog need to contain all company items prior to migration? It is not necessary to clean up the entire historical database all at once. The company can prioritize registering items involved in the pilot operation and gradually expand to high-frequency or high-value items, provided that no item is shipped under the new framework without a properly structured record.

Official sources:

• Cronograma oficial de ligamento DUIMP