Exporting to Brazil: How DUIMP, the Product Catalog and OEA Are Changing Brazilian Customs

In January 2024, this blog published Exporting to Brazil: What You Need to Know, a practical guide to the Brazilian market for U.S. exporters. That article covered the scale of the opportunity, the challenge of the Custo Brasil, and the U.S.-side export compliance steps companies must complete before goods ever leave the United States, including export classification, export licensing and restricted party screening. That foundation hasn't moved, and it remains the right first read for any company sizing up Brazil.

What has moved, substantially, is everything that happens after the goods arrive. Since that article was published, Brazil has been in the middle of replacing its entire import-declaration architecture—and the pace of that transition has accelerated sharply over the past year, to the point that it now deserves its own dedicated look. This is that follow-up: an inside view of how Brazilian customs actually processes a shipment once it lands, and how fundamentally the rules of that process have changed.

The replacement is not simply a faster or more digital version of the old system—it is a structurally different one. Brazil's customs authority, the Receita Federal do Brasil (RFB), is in the process of replacing a single, uniform inspection regime with two distinct tracks: a default track that is more data-intensive and more automated in its scrutiny than anything Brazilian importers have dealt with before, and a parallel, expanding fast lane reserved for operators who have earned the government's trust. Where a shipment lands between those two tracks now depends less on what happens at the moment of arrival and more on decisions made—and data submitted—weeks before the vessel ever leaves a U.S. port.

For exporters, freight forwarders, and compliance teams whose Brazilian counterparts are navigating this transition, there are four pieces of Brazil’s import modernization that exporters should understand:

• Declaração Única de Importação (DUIMP)
• Catálogo de Produtos (Product Catalog)
• LPCO (Licenças, Permissões, Certificados e Outros documentos).
• Programa Brasileiro de Operador Econômico Autorizado (OEA), Brazil's trusted-trader program, which determines which of the two tracks an importer actually experiences.

Understanding all four, and how they now interlock, is no longer a specialist concern. It is becoming a precondition for predictable trade with Brazil.

How DUIMP Is Replacing Brazil’s Legacy Import Declaration

Brazil is not moving every import shipment to DUIMP on a single date. Instead, the country is phasing out its legacy Declaração de Importação (DI) process operation by operation.

DUIMP is part of Brazil’s Novo Processo de Importação (NPI), or New Import Process, which is being implemented through the Portal Único de Comércio Exterior, Brazil’s single-window platform for foreign trade. The goal is to replace a document-heavy import declaration process with a more structured, data-driven system.

The legal foundation for the change comes from Brazil’s long-standing customs dispatch rules, including Normative Instruction SRF No. 680/2006, which governs import customs clearance, and Normative Instruction RFB No. 1,833/2018, which amended those rules to formally introduce DUIMP.

In practice, the transition is happening gradually. Brazil’s official DI phaseout schedule expands the mandatory use of DUIMP and, when applicable, LPCO—the licensing, permits, certificates and other documents module—based on the type of import operation. Factors can include the mode of transportation, customs regime, government agencies involved and other shipment-specific details.

That means there is no single “DUIMP day” for exporters to remember. Whether a shipment must be processed through DUIMP or can still use the legacy DI system depends on the current implementation schedule for that specific transaction.

For U.S. exporters, the takeaway is practical: Do not assume your Brazilian customer can clear today’s shipment the same way they cleared a similar shipment last year. Before goods move, confirm with the Brazilian importer or customs broker whether DUIMP, LPCO or Product Catalog requirements apply.

The Product Catalog: Compliance Moves from the Dock to the Desk

The most consequential change for exporters is not the import declaration itself. It is what happens before the declaration is filed. Under Brazil’s legacy import process, a product's tariff classification and technical description were largely settled at the moment a broker filed the DI, alongside the shipment's commercial documents. Errors surfaced, if at all, during document review or physical inspection, after the cargo had already arrived in Brazil.

The Catálogo de Produtos, or Product Catalog, moves that work upstream.

Each Brazilian importer now maintains a persistent, structured registry of every product it imports, independent of any individual shipment. Every item carries an NCM (Brazil's tariff classification code) and a defined set of attributes—structured data fields specific to that classification, covering composition, technical specification, and intended use, built jointly by government and industry through a mapping exercise that has so far defined close to 30,000 such attributes across 43 economic sectors. By the time a DUIMP is filed, the product should already be validated in the Catalog; the declaration largely references a record that already exists rather than describing the goods from scratch.

This has two important consequences for exporters.

First, classification and product-description errors can affect more than one shipment. If an importer builds an incomplete or inaccurate Catalog record for a product, that problem can follow future imports of the same item.

Second, the RFB has been actively pruning the data burden on its own initiative: in late 2025 it eliminated more than 1,600 optional attributes that existed solely for the tax authority's own use, narrowing the Catalog to the fields that genuinely drive classification and risk analysis. That pruning is a useful signal in itself—it suggests a regulator trying to make the new system survivable for ordinary filers, not just theoretically complete.

For a U.S. exporter, the practical implication is that commercial invoices and technical specification sheets are no longer just shipment paperwork—they are the raw material from which a Brazilian importer's permanent product master file gets built, and that file now drives risk scoring on every transaction going forward, not only the one it accompanies.

LPCO: Bringing Brazil’s Import Licensing Into One Module

Before the NPI, import licensing in Brazil meant routing a shipment through whichever subset of separate agency systems applied to the product—Anvisa for health-regulated goods, MAPA for agricultural products, Ibama for environmental controls, Inmetro for conformity assessment, the Army’s Directorate for controlled items, among others—each with its own process, document standard and timeline layered on top of the core customs declaration.

LPCO (Licenças, Permissões, Certificados e Outros documentos) brings these licensing, permitting, certificate and other document requirements into a single module inside the Portal Único. A license can be reused across multiple import operations instead of being requested anew each time, fees and requests can be handled through the single window, and the architecture is designed to support more coordinated review among agencies rather than a purely sequential, siloed process. Where licensing applies, LPCO can also connect to the Catalog: the system may identify, from a product’s registered attributes, whether it falls under a given agency’s control and trigger the licensing request from within the Catalog rather than as a separate downstream step.

The implication mirrors the Catalog’s: a product’s regulatory status in Brazil is now increasingly determined by how precisely it is described upstream, which makes attribute-level data quality a precondition for licensing speed, not merely for customs clearance.

The Risk Engine: A Single, Unforgiving Channel Result

Brazil’s customs risk model still resolves to the familiar four channels: green (automatic release), yellow (document review), red (physical inspection) and gray (review plus valuation scrutiny). What has changed is how the channel gets decided, and when.

Under the DI, each agency with jurisdiction over a shipment ran its own risk analysis with a degree of independence. Under the DUIMP, the RFB and relevant licensing agencies feed into a single, consolidated risk result, governed by the most restrictive outcome among them: if MAPA’s analysis flags a shipment red while the RFB’s own model would have cleared it green, the declaration is routed red. The importer sees one outcome, not a set of agency-by-agency results to reconcile.

That consolidation is paired with a second shift: because product attributes, licensing status, and import history now live in the Catalog and LPCO ahead of filing, the RFB's risk engine has structured data to work with far earlier than it did under the DI — and it is reportedly using it more aggressively. Practitioners describe an automated cross-referencing capability that catches discrepancies between the Catalog record and the shipment's actual commercial invoice—a different declared composition, a missing mandatory attribute, drift from a product's own filing history—and treats those discrepancies as an immediate trigger toward the stricter channels. The net effect is a system that used to catch errors reactively, after arrival, increasingly built to flag them proactively, based on data quality established before departure.

The Other Track: How OEA Can Turn Trust Into a Green-Channel Default

That stricter default is only half the picture, and it is the half most coverage of the DUIMP transition leaves out. Running in parallel—and now explicitly converging with DUIMP and Brazil's broader fiscal modernization—is the Programa Brasileiro de Operador Econômico Autorizado (OEA), Brazil's version of the trusted-trader frameworks that have become standard internationally since the World Customs Organization's SAFE Framework.

OEA certification recognizes importers, exporters and other trade operators that demonstrate strong supply-chain security, customs compliance and a clean operating history. In exchange, certified operators may receive tangible operational benefits, including a lower inspection rate, priority processing, a dedicated RFB point of contact and access to mutual recognition arrangements with customs authorities abroad.

In April 2026, the RFB went further. Normative Instruction RFB No. 2,318/2026 restructured the compliance arm of the program—OEA-Conformidade—into three explicit tiers: OEA-C Essencial, a simplified entry tier built specifically for export trading companies; OEA-C Qualificado; and OEA-C Referência, the top tier. The benefits scale sharply with tier. Referência-certified importers can defer payment of taxes owed on an import operation until the 20th day of the month following the operation, and—critically, given everything described above—their import and export declarations are routed to the green channel by default, exempted from the consolidated worst-case risk logic that now governs everyone else, except in cases involving intelligence alerts, national security concerns, judicial decisions, or controls reserved to other agencies. The reform also reaches into Brazil's ongoing consumption-tax overhaul: under Complementary Law 214/2025, export trading companies certified at the Essencial tier gain suspension of the new IBS and CBS levies on qualifying operations—a direct link between customs trust status and the country's biggest tax reform in a generation.

Read together with the DUIMP and Catalog changes, the strategic shape of Brazil's reform becomes clear. The RFB is not making customs uniformly easier or uniformly harder. It is widening the gap between two populations of importers: a default population subject to a stricter, automated, cross-referenced risk model with less room for the document-level improvisation the old system tolerated, and a certified population that has effectively opted out of that model in exchange for a demonstrated compliance history. Brazil is, in effect, importing the global trusted-trader logic into a system that historically treated every shipment as equally suspect.

What This Means for Customs Brokers

For Brazil's despachantes aduaneiros, or customs brokers, this is a genuine redefinition of the job, not a software update. The Portal Único's intervener registry allows an importer to formally designate a broker as the Gestor do Catálogo de Produtos—the party responsible for creating, updating, and maintaining that importer's product records.

That is a different discipline than filing a declaration per shipment. It requires sustained technical familiarity with the goods themselves, deliberate data governance, and continuous tracking of attribute and licensing rules the RFB has been revising on a near-monthly cadence. It also makes the broker a direct actor in whether a client can credibly pursue OEA certification at all, since a clean Catalog and a stable compliance history are now part of the same evidentiary record.

Brokers who treat the Catalog as a one-time setup task rather than a maintained asset are the ones whose clients will find themselves disproportionately routed into the system's stricter half.

What This Means for U.S. Exporters

Three adjustments follow directly:

• Product documentation now functions as classification data, not just shipment paperwork. Generic invoice descriptions that may have been adequate under the DI model are increasingly likely to create attribute gaps in a Catalog record that persists across future shipments of that item.
• Timing has shifted left. Because classification and licensing now happen earlier in the process, resolving a classification ambiguity after the goods are already in transit is a structurally worse position than it used to be. There is materially less slack in the new system for fixing problems at the border.
• Your Brazilian counterparty's certification status is now a relevant commercial fact, not a back-office detail. Whether the importer on the other end of the transaction is pursuing or holds OEA certification — and whether their broker is actively maintaining a disciplined Catalog—increasingly determines whether a shipment experiences Brazil's stricter default track or its expanding fast lane.

Where This Is Headed

Brazil’s government continues to target broad implementation of the NPI across states, transport modes and customs regimes, but the timeline has already moved more than once and may continue to shift as the rollout reaches more complex operations. What is unlikely to reverse is the underlying logic: a system that increasingly treats trust as something to be earned and verified with data, rather than assumed and checked at the border.

Put side by side with our original guide to the Brazilian market, the picture is now reasonably complete. U.S. exporters need to get U.S.-side export compliance right, and they also need to support the Brazil-side data and trust posture that now shape import clearance. The operating question for 2026 is no longer simply, “What documents does this shipment need?” It is also, “Does our data—and our counterparty’s compliance standing—put us on the track that gets faster, or the one that just got stricter?”

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