Duimp and the consumption tax reform: who picks the legal basis before charging begins

Duimp and tax reform: the system now sets each item's tax code from the legal basis chosen. CBS/IBS charging starts in 2027.

Siscomex, Brazil's foreign trade portal, scheduled for 27 September 2026 the changes to the Duimp, the Single Import Declaration, for the consumption tax reform. Siscomex Import Communiqué No. 100/2026, signed by offices of the Receita Federal (Brazil's federal revenue service) and the Foreign Trade Secretariat (Secex), states that there will be no charging or payment of CBS and IBS, the new consumption taxes, before 1 January 2027. Until then, the change lies in how the declaration is filled in: the system sets each item's tax code from the legal basis selected.

Before the change, the system went down. Siscomex Systems Notice No. 016/2026 announced a scheduled outage of 19 systems, including the Duimp and the DU-E (the single export declaration), on Saturday, 26 September 2026, from 14:00 to 18:00 Brasília time. Communiqué No. 100/2026 kept Duimp registration blocked until 23:59 that day, because of a temporary outage of the banking network, and reopened it at 00:00 on 27 September.

Siscomex Import Notice No. 089/2026, of 19 August 2026, lists four changes to the Duimp. The Place of Consumption Operation (state and municipality) becomes mandatory. The field "other taxes/duties" is mandatory until release. The cClassTrib field ends its validity, and legal bases (FL, from the Portuguese fundamento legal) for CBS and IBS are optional. We read the list of changes, not the detail of each one.

Importers. The importer is the party that files the Duimp. Under Communiqué No. 100/2026, it will no longer be necessary to fill in cClassTrib for the items, and the CST and cClassTrib codes of each item will be set by the system based on the legal bases selected. The text warns that some optional CBS and IBS legal bases "will not be available" and will be implemented "during the following week". A Duimp filed with an inappropriate CBS or IBS legal basis because the correct option is missing "will not be grounds for penalties".

Freight forwarders and NVOCCs. The texts we read do not mention freight forwarders or NVOCCs.

Exporters. The only reference to exports in the texts we read is the scheduled outage of 26 September, which included the DU-E. The changes described concern the Duimp.

Our take

the question that cannot wait until 2027 is who, in your company and in your chain, picks the legal basis for each item, since the system now derives the tax code from it. The tolerance is transitional: some legal-basis options are still missing, a filing with an inappropriate basis because the correct option is missing draws no penalty, and charging begins on 1 January 2027. In our reading, the data filed now is the record your company will carry when charging arrives. For importers, that means deciding who chooses and who checks the basis for each item, a choice that calls for a technical reading of the product and the operation. For freight forwarders and NVOCCs, the cargo data that feeds the client's declaration is likely to weigh more: it is worth knowing whether what you pass on reaches the Duimp without discrepancy.

Questions for your company

Importer: Who in your company chooses the legal basis for each Duimp item, and on what grounds, given that the system now sets the tax code from it?
Importer: If a Duimp was filed with an inappropriate legal basis because the correct option was missing, is it flagged for review once the option is available?
Importer: Who maintains the state and municipality of the Place of Consumption Operation, now mandatory, and where does that data come from?
Freight forwarder and NVOCC: What cargo data do you pass to the importing client, and does it reach their Duimp without rework or discrepancy?
Everyone: Who in your company follows Siscomex notices on the tax reform, and how quickly do they reach whoever files the operation?

In numbers

US$ 7.74 bn: trade surplus in September, up 146.4% from September 2025 (US$ 3.14 bn)
US$ 34.42 bn: exports in September, up 12.9%; imports totalled US$ 26.68 bn, down 2.4%
US$ 61.09 bn: total trade flow in September, up 8%
US$ 8.3 bn: exports to Europe in September, up 51.9%
+31.9%: exports to the US in September; year to date, down 6.5%
US$ 84.4 bn: projected 2026 surplus, below the previous projection (US$ 90 bn)

The September trade surplus was US$ 7.74 billion, up 146.4% from September 2025. Exports rose 12.9% and imports fell 2.4%. The projection for the 2026 surplus was cut from US$ 90 billion to US$ 84.4 billion.

Sources

What changed

US: CBP adjusts COBRA customs fees for fiscal year 2027

United States

US Customs and Border Protection (CBP) adjusted the COBRA customs fees for inflation, by 38.322%, for fiscal year 2027, and they have been required since 1 October 2026. The merchandise processing fee (MPF) has a minimum of US$ 34.58 and a maximum of US$ 670.86, and the 0.3464% ad valorem rate is unchanged. Arrival of a commercial vessel is now US$ 604.47 and a broker permit US$ 190.88. The express consignment fee is US$ 1.38.

Gentil reading: If your company sells into the US on DDP terms and acts as importer of record, review the quotes for operations from 1 October 2026: the floor and the cap of the processing fee were adjusted, and the rate was not. For sales with the price already set, decide who absorbs the difference.

Source: Federal Register, 2026-15530 (31/07/2026), CBP, taxas aduaneiras COBRA

US: USITC opens five-year review of the anti-dumping orders on aluminum foil from Brazil

United States

The USITC, the US International Trade Commission, has begun the five-year review of the anti-dumping orders on aluminum foil from Armenia, Brazil, Oman, Russia and Turkey, and of the countervailing orders on Oman and Turkey. The original order dates from 12 November 2021. The review assesses whether revocation would lead to continuation or recurrence of material injury. The deadlines are in the agenda.

Gentil reading: If your company exports aluminum foil from Brazil to the US, decide now whether it will take part in the review and who answers the USITC questionnaire. The response and comment dates do not wait for the issue to be analysed.

Source: Federal Register, 2026-20139 (01/10/2026), USITC

Siscomex Remessa now rejects declarations with an incomplete NCM or a malformed cClassTrib

Siscomex

In Siscomex Remessa, the import declaration for consignments (DIR) requires an NCM (the Mercosur Common Nomenclature) with at least the first six digits of a valid code and a six-digit cClassTrib. A transmission outside that standard is rejected, and the DIR is not registered. The notice comes from Coana, the Receita Federal's customs administration office, is dated 28 September 2026 and treats the rule as effective from 1 October 2026.

Gentil reading: Anyone transmitting consignments needs to know who maintains the NCM and cClassTrib of each product: a record with an incomplete code now prevents the declaration from being registered. Note that this differs from the Duimp, where cClassTrib is no longer filled in.

Source: Siscomex, Comunicado Importação nº 101/2026 (28/09/2026)

Calendar

7 Oct: Estimated, unofficial date ("on or around") for the US Department of Commerce's final anti-dumping determination on dissolving pulp from Brazil; the preliminary margin was 7.20% for Bracell (19 May 2026)
8 Oct: ANTAQ webinar on the review of its container demurrage and detention rule, 15:00 Brasília time, YouTube
8-9 Oct: EU Trade Commissioner Maroš Šefčovič in Beijing for the EU-China Trade and Investment Council (according to AFP)
16 Oct: Deadline to give notice of intent to participate in the US review of the anti-dumping order on Brazilian aluminum foil, which decides whether the order stays (US Department of Commerce)
20 Oct: Deadline for comments to ANTAQ on container demurrage and detention, 23:59 Brasília time
22 Oct: Deadline to enter an appearance at the US International Trade Commission (USITC) to take part in the review on Brazilian aluminum foil (21 days after the 1 October publication)
29 Oct: Meeting of Gecex, the committee of Brazil's Foreign Trade Chamber (Camex) that sets import tariffs, 09:30 Brasília time
31 Oct: Last day to request administrative review of the US orders on Brazilian steel wire rod
2 Nov: Responses due at the US International Trade Commission (USITC) in the Brazilian aluminum foil review, by 5:15 p.m. Washington time
4 Nov: Comments due on the CBP notice on IEEPA tariff refunds
9 Nov: End of the suspension of US port fees on China-linked vessels, 11:59 p.m. New York time; no extension published as of 3 October
4 Dec: Comments due to the US Federal Maritime Commission (FMC) on its complaints and mediation portal
8 Dec: Comments on adequacy due at the USITC in the Brazilian aluminum foil review
1 Jan 2027: Start of CBS and IBS charging, according to Siscomex (Import Communiqué No. 100/2026)

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