Monthly Changes Digest
October 2025
LC 227 supplementary law draft published for tax reform transition rules. Chinese steel anti-dumping duties extended. DUIMP expands to plastics and rubber.
Tax reform
LC 227 draft — transition rules for CBS/IBS
The government published the draft of Lei Complementar 227, which establishes the detailed transition rules for CBS/IBS. Key provisions for importers: (1) CBS/IBS test rates of 0.9%/0.1% confirmed for 2026, (2) CBS full rate from 2027 replaces PIS/COFINS on imports at a single rate, (3) IBS gradual replacement of ICMS between 2029-2033 with specific phase-in percentages, (4) ICMS incentive programs grandfathered through the transition period but not beyond. Public comment period: 45 days.
Tariff changes
GECEX Resolution 610 — TEC adjustments
- 33 NCM codes adjusted — focus on agricultural inputs (3105 — fertilizers, 3808 — pesticides)
- Temporary reductions of 2-6pp on fertilizer intermediates
- Objective: support domestic agriculture competitiveness and food security
- Duration: 12 months, effective November 1
Ex-Tarifário — GECEX Resolution 612
- 94 new concessions
- Significant batch for logistics automation: conveyor systems (8428), packaging machinery (8422), warehouse robots (8479)
- 10 concessions for lithium battery manufacturing equipment (8479, 8514)
Trade defense
Chinese steel — anti-dumping duties extended
- SDIC extends anti-dumping duties on hot-rolled steel from China for additional 5 years
- Duties: 14.2%–25.8% ad valorem, depending on the Chinese producer
- NCM codes affected: 7208.10 through 7208.90
- Brazilian steel industry (Instituto Aço Brasil) successfully demonstrated continued dumping margins
Safeguard investigation — glass containers
- SDIC opens safeguard investigation on glass containers (7010) from all origins
- Triggered by surge in imports from Argentina, Mexico, and Colombia
- Provisional safeguard measures under consideration
Customs procedures
DUIMP — HS chapters 39-40 now mandatory
- DUIMP now required for plastics (chapter 39) and rubber (chapter 40)
- All major industrial import chapters now on DUIMP
- Remaining chapters (textiles, clothing, footwear) expected to migrate in Q1 2026
Regulatory changes
- ANVISA — RDC 760/2025 establishes new requirements for imported dietary supplements. INCI nomenclature alignment with Codex Alimentarius. Effective April 2026.
- IBAMA — new CTF requirements for importers of products containing PFAS chemicals. Environmental licensing now required for 15 additional NCM codes.
- INMETRO — publishes final rules for EV charger certification (Portaria 695). Mandatory for all imported Level 2+ chargers from July 2026.
ICMS changes
- São Paulo — publishes Decreto 68.340 codifying ICMS-ST (substituição tributária) products list for 2026. 35 product categories updated.
- Espírito Santo — FUNDAP program renewed for 2026-2028 period. New condition: 20% of financed ICMS must be directed to port infrastructure investment.