How to structure an import: logistics, taxes, and integrated controls
Learn how to structure your import operation in Brazil, integrating the new IBS/CBS flows effective in 2026, Siscomex Radar limits, and logistics cost management.
To structure an import operation in Brazil sustainably, a company must integrate customs authorization, rigorous tax classification, and financial planning to support the tax burden at clearance. In 2026, the coexistence of tax regimes during the reform transition period requires specific controls over the IBS (Imposto sobre Bens e Serviços - Tax on Goods and Services) and the CBS (Contribuição sobre Bens e Serviços - Contribution on Goods and Services). This article provides general and informative guidance and does not constitute individualized legal or tax advice.
Scope and Validity of Rules in 2026
This roadmap reflects the regulations in force and the tax transition scenario observed in November 2026. Structuring an import requires compliance with the Radar authorization sub-modalities and adherence to the schedule for replacing PIS/Cofins and ICMS with CBS and IBS, respectively. Correct application depends on the nature of the operation and the company's registration status with the Special Secretariat of the Federal Revenue of Brazil (RFB - Secretaria da Receita Federal do Brasil).
Authorization in Radar Siscomex: Capacity Criteria
The first approval gate for foreign trade is the Registration and Tracking Environment for Customs Intermediaries (Radar - Ambiente de Registro e Rastreamento de Atuação dos Intervenientes Aduaneiros). According to RFB Normative Instruction No. 1984/2020 and subsequent updates, authorization is segmented according to the legal entity's financial capacity. The 'Limited' modality allows operations up to USD 50,000 or USD 150,000 every six months, based on the history of federal tax and social security contributions.
For operations requiring higher volumes, the 'Unlimited' sub-modality requires proof of financial capacity compatible with the intended import volume. It is essential that the company performs a review of the capacity estimate when the estimation and operation planning justify the request, observing official monitoring and review procedures. It is important to note that using a trading company does not remove the need for the acquiring or ordering company to have its own Radar authorization, maintaining joint liability according to the chosen modality.
Tax Classification and Tax Matrix in 2026
The Mercosul Common Nomenclature (NCM - Nomenclatura Comum do Mercosul) determines the applicable rates and administrative requirements. In 2026, the import cost calculation must integrate the Import Tax (II - Imposto de Importação) and the Tax on Industrialized Products (IPI - Imposto sobre Produtos Industrializados) — where applicable — with the new consumption matrix. CBS and IBS are levied at the time of customs clearance. The calculation base and the possibility of credit depend on the company's tax regime, with Real Profit for importers (Lucro Real) allowing for credit compensation differently from simplified regimes.
Errors in NCM classification or in the description of goods can lead to the application of customs infraction fines and significant delays in cargo release. Complementary Law 214 (Lei Complementar 214) establishes guidelines for the management of these taxes, and the application of state or federal tax benefits must be validated according to the legislation in force on the date of registration of the Import Declaration (DI - Declaração de Importação) or the Single Import Declaration (Duimp - Declaração Única de Importação).
Logistics Planning and Choice of Incoterms
International logistics should be treated as an integral part of tax governance. The definition of the Incoterm (International Commercial Terms) establishes the division of costs and risks between buyer and seller. Terms such as FOB (Free on Board) and FCA (Free Carrier) allow the Brazilian importer to select the freight forwarder and insurance, offering greater control over the costs that will compose the Customs Value — the calculation base for most taxes.
Document management, including the Commercial Invoice, Packing List, and Bill of Lading, must be precise. The absence of original documents or errors in their issuance can generate demurrage costs (container detention fees), which are not recoverable via tax credit and directly impact the operation's profitability.
Import Modalities and Contractual Structure
There are crucial legal distinctions between modes of operation. The importer can opt for direct import or import via third parties. The choice between import on behalf of and by order or by order (importação por conta e ordem ou encomenda) impacts financial flow and ownership of goods. In import 'on account and order', the importer is a service provider promoting clearance for a third party (acquirer), while in import 'by order', the importer acquires the goods with its own resources for later resale to the predetermined orderer.
Each modality requires prior registration of the link between the companies in Siscomex. Lack of compliance in these contracts and respective exchange payments can mischaracterize the operation, resulting in severe tax penalties for concealing the actual acquirer.
Governance and Prior Licensing
Before shipping, verify the administrative treatment of the goods and the operation, including LI (Import License) or LPCO (Licenses, Permissions, Certificates, and Other Documents) in the corresponding flow. Consenting bodies, such as ANVISA, MAPA, or INMETRO, have specific deadlines for analysis. Integrated control must predict whether licensing is required prior to shipment or can be carried out after arrival. The Duimp registration aims to centralize these interactions, but internal governance must ensure licenses are active to avoid cargo detention in primary zones, which would generate excess storage costs.
Cash Flow Management and Total Cost
A common error in structuring is neglecting the amount necessary for clearance. The budget must consider the taxes effectively due, their payment events, and clearance costs. In 2026, the CBS/IBS testing phase has conditions for exemption from collection and does not mean full universal disbursement of these taxes. It is recommended to build a total import cost spreadsheet that includes port fees, handling fees (capatazia), customs broker expenses, in addition to the nominal tax burden, to ensure the viability of nationalization.
Checklist
FAQ
How do CBS and IBS impact import costs in 2026?
Imports are within the scope of IBS/CBS according to their legal bases and conditions. In 2026, there is a testing phase; PIS/Cofins are replaced by CBS in 2027, while the transition from ICMS/ISS to IBS is gradual. Do not apply a generic base or rate without identifying the product, operation, and year.
Is the Radar limit fixed?
No. The limit for the 'Limited' modality is reviewed by the Federal Revenue every six months based on the taxes paid by the company. If the company makes a capital contribution or increases its economic activity, it can request a review of the estimate to migrate to the 'Unlimited' modality.
What is detention in the customs inspection channel?
Upon registering the declaration, the cargo may be directed to the green (automatic release), yellow (documentary check), red (documentary and physical check), or gray (special procedure to investigate signs of fraud or valuation) channels. Detention requires the presentation of proof of the transaction and can extend the nationalization period.
Next Steps
Structuring an import requires constant monitoring of customs and tax legislation. After consolidating the basic flow, the company should seek logistics optimization and maintain the compliance of product registrations. For support in implementing integrated controls and feasibility analysis, please contact us.
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