Exporter of Record in Brazil
Brazil exports iron ore, soybeans, crude oil, beef, aircraft, and automotive vehicles to China, the United States, Argentina, and the European Union. Outbound cargo moves through the Port of Santos and Port of Paranaguá for sea freight and through Guarulhos International Airport (GRU) for air cargo. To act as a legal Exporter of Record in Brazil, an entity must hold a CNPJ (Cadastro Nacional da Pessoa Jurídica), active RADAR habilitação from Receita Federal do Brasil (RFB), and a valid e-CNPJ digital certificate for Portal Único Siscomex filing. A foreign company without these credentials cannot file a DU-E (Declaração Única de Exportação) and cannot sign as the legal exporter. Exports are exempt from ICMS under Lei Complementar 87/1996 (Lei Kandir) and exempt from IPI and PIS/COFINS. Brazil applies Imposto de Exportação (IE) to specific commodities under Decreto-lei 1.578/1977, including soybeans, raw hides, and firearms.
Carra Globe acts as your Exporter of Record in Brazil, holding active CNPJ, RADAR habilitação, and e-CNPJ for Portal Único Siscomex filing. Carra Globe manages the DU-E, DECEX export licence applications, ICMS and IPI exemption documentation, Mercosur certificates of origin, IBAMA CITES permits, and end-user certificates for EAR-controlled goods. For cargo movement, Carra Globe integrates freight forwarding into every third-party EOR Brazil solution by sea and air.
What is an Exporter of Record in Brazil
An Exporter of Record in Brazil is the CNPJ-registered entity named on the DU-E (Declaração Única de Exportação), Brazil’s official export customs declaration filed through the Portal Único Siscomex under Instrução Normativa RFB n° 1.702/2017. The Receita Federal do Brasil (RFB) and the Secretaria de Comércio Exterior (SECEX) under the Ministério do Desenvolvimento, Indústria, Comércio e Serviços (MDIC) govern all outbound customs and export trade policy. The EOR is legally responsible for export classification, export licence compliance, ICMS exemption documentation, Mercosur origin certification, and restricted party screening. A foreign company without CNPJ and RADAR habilitação cannot access Portal Único Siscomex to file the DU-E. Read our guide on what is an Exporter of Record before shipping goods from Brazilian territory.
Why Foreign Companies Cannot Export from Brazil Without an EOR
Portal Único Siscomex requires a valid CNPJ, active RADAR habilitação, and an e-CNPJ digital certificate before any user can file a DU-E. A foreign company without Brazilian incorporation holds none of these and cannot initiate export customs clearance at any Brazilian port or airport. The NF-e (Nota Fiscal Eletrônica) must be issued by a CNPJ-registered entity before the DU-E can be registered, meaning cargo cannot legally move from a Brazilian warehouse to the port without a Brazilian EOR. Beyond the customs filing barrier, DECEX issues export licences for controlled and sensitive goods only to CNPJ-registered entities habilitados in Siscomex, meaning a foreign company cannot independently obtain clearance for goods on Brazil’s Lista de Bens Sujeitos a Controle na Exportação under Lei 9.112/1995.
What Carra Globe Manages as Your EOR in Brazil
- DU-E filing: Carra Globe registers and files the Declaração Única de Exportação through Portal Único Siscomex using active CNPJ, RADAR, and e-CNPJ before cargo departs
- NF-e issuance: Carra Globe issues the Nota Fiscal Eletrônica required before domestic movement of export cargo from warehouse to port
- DECEX export licence management: Carra Globe submits applications to SECEX/DECEX for sensitive goods, dual-use items, and goods on Brazil’s controlled export list under Lei 9.112/1995
- ICMS and IPI export exemption: Carra Globe applies Lei Kandir ICMS exemption and IPI zero-rating documentation on all export transactions
- Mercosur certificate of origin: Carra Globe issues certificates of origin for MERCOSUL-bound exports qualifying for preferential tariff treatment
- Restricted party screening: Carra Globe screens all consignees against the BIS Entity List, Denied Persons List, and OFAC sanctions lists
- IBAMA CITES permits: Carra Globe coordinates IBAMA wildlife export permits for CITES-listed species including timber, wild animals, and biological material
- Re-export controls: Carra Globe confirms EAR classification on US-origin components and obtains BIS or DDTC licences where required
Common Export Holds & Fines in Brazil: How Carra Globe Protects Your Cargo
The most frequent causes of export holds at Santos and Paranaguá follow a consistent pattern: RADAR habilitação lapsed or suspended, NF-e not issued before cargo moves to port, DU-E filed with incorrect NCM code, DECEX export licence absent for sensitive goods, Imposto de Exportação unpaid on controlled commodities, Mercosur certificate of origin unsigned or in wrong format, IBAMA CITES permit missing, EAR-controlled US-origin components not screened. Every one results in cargo held at bonded warehouse with compounding daily demurrage costs.
Carra Globe prevents these by verifying compliance before cargo departs: confirming active RADAR status, issuing the NF-e before warehouse release, validating the NCM code against DECEX controlled lists, confirming IE liability by commodity, and completing restricted party screening before the DU-E is registered.
Brazil Export Compliance Framework (2026)
Export Declaration System and Customs Authority
Receita Federal do Brasil (RFB) and SECEX/MDIC govern all outbound customs processing in Brazil. Every DU-E is filed through the Portal Único Siscomex using the exporter’s e-CNPJ digital certificate, under IN RFB n° 1.702/2017. RFB assigns each DU-E a selectivity channel: green (Canal Verde) for immediate release, yellow (Canal Amarelo) for documentary review, or red (Canal Vermelho) for physical inspection. The official Siscomex portal is gov.br/siscomex.
Export Licences and Controlled Goods
SECEX, through its DECEX (Departamento de Operações de Comércio Exterior), administers export licences under Lei 9.112/1995 (Lei de Exportação de Bens Sensíveis e Serviços Diretamente Vinculados), which controls the export of sensitive goods, dual-use technology, and items with military applications. The CAMEX (Câmara de Comércio Exterior) issues resolutions on export quotas, suspensions, and controlled commodity lists. Exporters submit licence applications through the Portal Único Siscomex at gov.br/mdic, with processing taking 10 to 30 business days depending on the sensitivity classification and agency routing.
ICMS, IPI, and Export Tax Treatment
Lei Complementar 87/1996 (Lei Kandir) exempts all goods exports from ICMS, eliminating the cascading state tax that applies to domestic transactions. IPI carries a zero rate on exports and PIS/COFINS do not apply to export transactions. These exemptions must be correctly documented on the NF-e and DU-E to be recognised by RFB.
Brazil applies Imposto de Exportação (IE) to a narrow list of commodities under Decreto-lei 1.578/1977 and CAMEX resolutions. Current rates include:
- Soybeans: 6.5%
- Raw hides and leather: 9%
- Firearms and ammunition: 150%
CAMEX can impose temporary IE on additional commodities by resolution. Exporters must confirm the current IE position for their specific NCM code before shipment.
Re-Export Controls on Foreign-Origin Goods
Any goods manufactured in Brazil incorporating US-origin components with an Export Control Classification Number (ECCN) remain subject to the Export Administration Regulations (EAR), administered by the Bureau of Industry and Security (BIS). Goods carrying a non-EAR99 ECCN may require a BIS licence before re-export to specific destinations. ITAR-controlled items on the US Munitions List require DDTC authorisation regardless of US content percentage. Carra Globe screens all goods for EAR and ITAR jurisdiction before the DU-E is filed.
Certificate of Origin and Mercosur Trade Agreements
Brazil is a founding member of MERCOSUL (Mercado Comum do Sul), and exports to Argentina, Paraguay, Uruguay, and Bolivia qualify for preferential tariff treatment under the Tratado de Assunção (1991) using a Mercosur Certificate of Origin. The Mercosul-EU Acordo Provisório de Comércio, provisionally implemented from 1 May 2026 (verify current implementation status before publishing), creates preferential access for qualifying Brazilian goods entering the European Union.
Export Documents Required in Brazil
- DU-E (Declaração Única de Exportação): filed through Portal Único Siscomex using exporter CNPJ, RADAR, and e-CNPJ digital certificate
- NF-e (Nota Fiscal Eletrônica): mandatory before domestic movement of export cargo; NF-e data integrates automatically into the DU-E via SPED
- Commercial invoice (fatura comercial): full goods description, NCM code, declared export value, Incoterms, country of origin
- Packing list (romaneio de embalagem): gross and net weights, dimensions, contents per package
- Bill of Lading (Conhecimento de Embarque) or Airway Bill (Conhecimento Aéreo): must match the DU-E in all material particulars
- Mercosur Certificate of Origin: preferential tariff claims for exports to Argentina, Paraguay, Uruguay, and Bolivia
- DECEX export licence: sensitive goods, dual-use technology, and controlled commodities under Lei 9.112/1995
- IBAMA CITES permit: goods derived from CITES Appendix I, II, or III species
- MAPA phytosanitary or animal health certificate: agricultural exports, live animals, and plant-based products (mention only for export context — for Brazil import compliance under MAPA, see our Importer of Record in Brazil page)
- End-user certificate (EUC): EAR-controlled US-origin components requiring BIS authorisation
EOR vs Shipper of Record in Brazil: Key Differences
These are two distinct legal roles under Brazilian customs law, and confusing them results in compliance failures at the port of export.
- Exporter of Record: the CNPJ-registered entity legally named on the DU-E, carrying full liability for export compliance, DECEX licence accuracy, ICMS exemption documentation, and NF-e issuance under IN RFB n° 1.702/2017
- Shipper of Record: the party identified on the Conhecimento de Embarque or Conhecimento Aéreo as the physical sender of cargo
- Who RFB holds accountable: the EOR, not the Shipper of Record, on every outbound shipment
- Practical application: a foreign company can appear as Shipper of Record while Carra Globe acts as EOR, maintaining full legal compliance without requiring Brazilian entity registration
For companies importing goods into Brazil, see our Importer of Record in Brazil page.
Get in Touch
Carra Globe EOR Services in Brazil
Carra Globe’s Brazil EOR service covers the full export compliance chain from origin to border: Exporter of Record, Importer of Record, Delivered Duty Paid, freight forwarding by sea from Santos, Paranaguá, and Itajaí and by air from GRU and Viracopos, white glove delivery for high-value cargo including aircraft components and medical equipment, warehouse logistics at bonded facilities near Santos and Guarulhos, and global trade compliance covering restricted party screening and export classification across 175+ countries.
Carra Globe’s EOR network extends across key export markets: Philippines, Colombia, USA, UK, Taiwan, China, Germany, Mexico UAE. For Brazil import compliance, see our Importer of Record in Brazil page.
Frequently Asked Questions: Exporting from Brazil
What is the difference between an Exporter of Record and a despachante aduaneiro in Brazil?
A despachante aduaneiro (licensed customs broker) files the DU-E on behalf of the EOR through Portal Único Siscomex but carries no legal liability for export compliance under IN RFB n° 1.702/2017. The EOR is the CNPJ-registered entity that carries full legal and fiscal accountability, and Carra Globe acts as the EOR while coordinating the licensed despachante aduaneiro under one accountable structure.
Can a foreign company export from Brazil without registering locally?
A foreign company cannot export from Brazil without CNPJ, RADAR habilitação, and e-CNPJ digital certificate, as Portal Único Siscomex rejects any DU-E filed without these credentials. Carra Globe holds all three registrations and acts as the legal EOR on every shipment, enabling export from Brazil without incorporating a local entity.
How do ICMS and IPI exemptions work on exports from Brazil?
Lei Complementar 87/1996 (Lei Kandir) exempts all goods exports from ICMS, and IPI carries a zero rate on export transactions, eliminating the two largest Brazilian taxes from the export price. These exemptions must be correctly applied on the NF-e and DU-E, and Carra Globe manages the full exemption documentation as part of the EOR Brazil service.
Do US EAR or ITAR controls apply to goods exported from Brazil?
EAR applies to goods manufactured in Brazil containing US-origin components with an ECCN above the 25% de minimis threshold for most destinations. ITAR applies to US Munitions List items regardless of US content percentage and requires DDTC authorisation for any transfer. Carra Globe screens every Brazil EOR shipment for EAR and ITAR jurisdiction before the DU-E is filed.
How long does export customs clearance take in Brazil?
Canal Verde clears the DU-E within 1 to 3 business days of Portal Único submission. Canal Amarelo documentary review takes 3 to 7 business days. Canal Vermelho physical inspection takes 7 to 15 business days at Santos and Paranaguá. DECEX export licences for sensitive goods add 10 to 30 business days before the DU-E can be filed.
Does Brazil's RADAR habilitação system affect how quickly Carra Globe can activate EOR coverage?
Carra Globe holds permanent active RADAR habilitação with Receita Federal do Brasil, meaning no activation delay applies to new clients. A company attempting to register its own Brazilian entity would face 60 to 120 days to obtain CNPJ, RADAR, and e-CNPJ before filing a single DU-E. Carra Globe eliminates this entirely and activates EOR coverage within 3 to 5 business days for standard commercial goods.
What is the NCM code and why does it matter for Brazil exports?
The NCM (Nomenclatura Comum do Mercosul) is Brazil’s eight-digit tariff classification system, aligned with the Harmonized System but with four additional digits specific to MERCOSUL. The NCM code on the DU-E determines ICMS exemption eligibility, Imposto de Exportação liability, DECEX licence requirements, and Mercosur certificate of origin qualification. An incorrect NCM triggers Canal Vermelho inspection, potential RFB fine, and export hold. Carra Globe classifies every shipment against the current Tabela NCM before the DU-E is filed.
Can Carra Globe handle both the NF-e and the DU-E for Brazil exports?
Carra Globe issues the Nota Fiscal Eletrônica as the CNPJ-registered exporter before cargo moves from warehouse to port, then registers the DU-E through Portal Único Siscomex with the NF-e data integrated via SPED. Foreign companies attempting to manage these two documents through separate Brazilian service providers regularly face filing sequence errors that result in cargo blocked at the port gate. Carra Globe manages both under one accountable structure.
How does Brazil's Drawback regime affect the Exporter of Record?
Drawback is Brazil’s export incentive regime under Portaria SECEX n° 23/2011, allowing importers to suspend or eliminate import duties on inputs used in manufacturing goods for export. The Drawback holder must appear as the EOR on the corresponding DU-E to close the Drawback commitment with SECEX. A foreign company without CNPJ and RADAR cannot hold Drawback registration, making a Brazilian-registered EOR essential for companies operating Drawback-financed export production in Brazil.
What penalties does RFB impose for export declaration errors in Brazil?
RFB imposes fines under Decreto-lei 1.455/1976 and the Regulamento Aduaneiro (Decreto 6.759/2009) for DU-E errors including incorrect declared value, wrong NCM code, and undeclared Imposto de Exportação liability. Fines range from 1% to 100% of the commercial value of the goods depending on the severity of the violation, with wilful undervaluation treated as a customs fraud offence. Carra Globe’s pre-departure compliance verification eliminates the primary causes of RFB fine exposure before the DU-E is registered.
