Waste tires and Ibama: who is responsible after importing new tires?

Checked: 2 November 2026. This article supports transaction planning and does not guarantee approval. Check the current treatment by NCM classification, attributes, purpose and customs regime before contracting or shipping; consolidated administrative texts do not replace the official gazette, DOU.

Environmental responsibility starts during planning

Importing new tires can create obligations concerning waste tires generated in Brazil. The framework is Conama Resolution 416/2009, with procedures under Ibama Normative Instruction 9/2021. That instruction covers manufacturers and importers of new tires in NCM heading 4011 with a unit weight greater than 2 kg. Identify the product, weight and activity before estimating reverse-logistics costs.

This framework does not authorize importing waste and then arranging its destination. Ibama’s official guidance states that imports of used tires are prohibited under Conama Resolution 452/2012. Buying new tires for the Brazilian market and importing used tires are different legal questions. Nor does an Inmetro certificate eliminate environmental responsibility: product conformity and environmentally adequate destination address different issues and require separate evidence.

Identify the entity actually responsible

The listed CTF/APP activity for an importer is 21-45; for a manufacturer, 9-6; and for a waste-tire destination operator, 17-63. These codes are not interchangeable. Map each participant’s function and review all activities actually performed instead of selecting whichever description seems most convenient.

For imports conducted “por conta e ordem” or “por encomenda,” Ibama guidance assigns compliance to the purchaser or predetermined ordering party and requests the prior contract. The entity appearing as customs importer therefore does not alone settle environmental responsibility. Before shipment, align the contract, registration and access to operational data. A commercial agreement can organize performance between the parties, but it should not be used to erase the regulatory allocation identified by the authority.

The tire report is not another name for RAPP

The verified instrument is the “Relatório de Pneumáticos: Resolução Conama 416/2009.” It includes manufacturer/importer and collection-point forms, as well as the destination-operator form where appropriate. Information is consolidated quarterly and declared by 31 March of the following year. Organize reconciliation throughout the year; an annual submission deadline does not remove the need for consistent quarterly data.

CTF/APP, RAPP and the specific tire report are different instruments. Registration under activity 21-45 alone does not establish that every importer must file RAPP, and it does not establish a universal exemption either. Assess RAPP and TCFA separately against all actual activities and current rules. This research verifies the specific tire obligation within its scope, not every company’s overall RAPP or TCFA position.

Calculation and destination evidence

Resolution 416/2009 governs the destination calculation in relation to tires placed on the replacement market. Do not replace that calculation with the informal rule “one imported tonne means one tonne of waste,” which strips out the framework’s parameters and adjustments. Apply the regulatory calculation to actual data and retain the working papers, without inventing commercial offsets.

Maintain a trail connecting quantities, weights, incoming goods, market placement and evidence of collection and environmentally adequate destination. If unit counts and mass disagree, investigate the product records before changing the report. Hiring a service provider does not automatically turn every receipt into sufficient evidence. Selection should consider the destination operator’s function and documentation supporting the applicable procedure. Preserve the connection between documents and the reporting periods they support.

Defined dispensations and import control

Ibama lists temporary admission, drawback, returned goods, reimportation, bonded warehousing, Recof Automotivo and return from temporary export. It also includes natural persons importing no more than four new tires per year, each weighing no more than 40 kg. Do not expand that list by analogy to every small purchase or every transaction by a legal entity.

These are dispensations from collection, destination and the other procedures under IN 9/2021, without a specific Ibama manifestation. They do not automatically remove customs or Inmetro requirements. The agency also states that it no longer approves tire import licenses in Siscomex. That does not extinguish subsequent environmental obligations or establish that the product has no other administrative treatment at the border.

FAQ: mistakes that change the budget

Can I import used tires to meet the target? No. Collecting waste tires in Brazil does not create permission to import used tires.

Are four tires imported by a company exempt? The verified provision concerns a natural person within annual and weight limits; do not extend it automatically.

Without Ibama import consent, can I ignore reporting? No. Import consent and the specific environmental obligation are separate matters.

Does CTF registration always mean filing RAPP? That conclusion is not supported by this research. Check actual activities and applicable rules, keeping the specific tire-report assessment independent.

Closing the records with clear ownership

As a management practice, maintain a folder for each period containing incoming data, weights, calculation papers and destination evidence. Name the person receiving trading-company files, the person checking product records and the reviewer of the specific declaration. These operational assignments do not change the environmental responsibility already described for each import arrangement.

When a weight or quantity correction arrives, do not silently replace the previous spreadsheet. Record its source, reason, affected periods and the person who validated the change. Preserve the connection between the corrected entry and supporting evidence, identifying any consequences for calculation papers and data prepared for declaration.

Agree on a missing-document workflow too: the provider supplies evidence, the internal owner checks its relationship to the period, and the reviewer records the outstanding issue or its resolution. If information has already been declared, refer the case for assessment of the applicable procedure rather than assuming that editing an internal spreadsheet corrects the submission. This is recommended organization, not an additional deadline or form.

Official sources and next steps

• Instrução Normativa Ibama 9/2021
• Ibama: pneumáticos inservíveis
• Siscomex: Comunicado Importação 012/2026

Return to the origin page, explore tire certification, import licensing and LPCO, or contact our team to organize a document review. Advice cannot replace the competent authority’s decision.