Monthly Changes Digest
December 2025
The biggest month in a decade: EU-Mercosur signed, LC 227 tax reform supplementary law enacted, new TEC table for 2026, and TIPI/IPI table update. Everything changes in January.
December 2025 = the month everything converged
Three major events hit in December: the EU-Mercosur trade agreement was signed, the tax reform supplementary law was enacted, and the new TEC tariff table for 2026 was published. Together, these change the rules for every importer into Brazil.
Trade agreements
EU-Mercosur Agreement — formally signed
On December 20, 2025, the EU-Mercosur trade agreement was formally signed in Montevideo. The agreement covers trade in goods, services, investment, public procurement, geographic indications, and regulatory cooperation. Provisional application is expected to begin in early 2026 — meaning tariff reductions start before full ratification by all EU member states. For importers: start reviewing the tariff annexes now.
Tax reform
LC 227/2026 enacted (published December 30, effective January 13)
The supplementary law establishing detailed transition rules for CBS/IBS was enacted. Key provisions for importers: (1) CBS test rate of 0.9% and IBS test rate of 0.1% effective January 2026, (2) EFD-CBS declarations mandatory from March 2026, (3) CBS/IBS import module integrated into Siscomex, (4) ICMS incentive programs explicitly grandfathered through 2033 but with declining benefit as IBS ramps up.
Tariff changes
GECEX Resolution 623 — new TEC table for 2026
- Full TEC overhaul — first major update since the 2021-2022 series
- 180+ NCM codes adjusted across 12 HS sections
- Average TEC reduced from 11.2% to 10.8% (weighted by import value)
- Notable reductions: semiconductors (8541/8542) from 12% to 8%, pharmaceutical inputs (2933-2934) from 12% to 6%
- Some increases: sugar confectionery (1704) from 16% to 18% (safeguard against Argentine imports)
- Effective January 1, 2026
2026 TIPI table — IPI rates updated
- New TIPI (Tabela de Incidência do IPI) published via Decreto 12.168/2025
- IPI rates reduced on 45 NCM codes as part of pre-reform simplification
- Notably: most Chapter 84 (machinery) IPI rates reduced from 5% to 0%
- This is the final TIPI — IPI will be eliminated in 2027 when CBS takes over
Ex-Tarifário — year-end batch (Resolution 625)
- 103 new concessions — largest December batch in 3 years
- Priority sectors: renewable energy, semiconductor manufacturing, EV components
- 22 renewals approved for existing concessions expiring in Q1 2026
- Total active Ex-Tarifário concessions entering 2026: approximately 3,200
ICMS changes (CONFAZ)
Year-end CONFAZ meeting
- Convênio ICMS 160/25 — states agree on methodology for ICMS→IBS transition reporting. All states must publish IBS-compatible ICMS data starting Q2 2026.
- Convênio ICMS 163/25 — extends ICMS exemption on imported capital goods for renewable energy projects through 2028
- Paraná — updates Regime Especial for imports through Paranaguá. Enhanced benefits for EV component imports (Decreto 7.890).
- Pernambuco — extends PRODEPE automotive manufacturing incentives through 2028
Regulatory changes
- ANVISA — year-end resolutions: RDC 780/2025 updates the List A1 (controlled substances) requiring import license. 12 new substances added.
- MAPA — publishes 2026 inspection calendar and approved establishment lists for all bilateral protocols. UK dairy establishments added (14 plants approved).
- INMETRO — 2026 compulsory certification list finalized. New categories: portable power stations, robot vacuums, EV home chargers, USB-C adapters, LED drivers.
- IBAMA — updates Lista de Fauna e Flora (CITES Appendix enforcement) for 2026. New monitoring requirements for timber imports (4403, 4407).
2025 year in review
Tariffs
- 542 Ex-Tarifário concessions granted
- TEC adjusted on 290+ NCM codes
- Average TEC declined from 11.2% to 10.8%
- EU-Mercosur signed — biggest FTA in history
Tax reform
- LC 214/2025 (January) — main CBS/IBS law
- LC 227/2026 (December) — transition rules
- CBS/IBS test rates start January 2026
- EFD-CBS filing system operational
Customs
- DUIMP expanded to cover 75% of import volume
- Siscomex API v3.0 launched
- Average clearance time reduced 15%
Regulatory
- ANVISA fast-track for FDA/EMA-approved drugs
- ANVISA cosmetics overhaul (RDC 752)
- INMETRO: 12 new product categories
- 20+ new MAPA bilateral protocols