Brazil’s Tax Reform has reached DUIMP

Brazil’s Consumption Tax Reform is no longer only a future project for importing companies. On September 27, 2026, the production environment of the Single Import Declaration — DUIMP — began to include fields related to CBS and IBS.

The update enables calculation of the new taxes by item and adds information that directly affects taxation, including the state and municipality of the place of consumption, legal grounds and additional values included in the tax base.

Although the amounts calculated in 2026 are not yet due, their presence in production is a milestone: data required by the new model is already entering real import operations.

The change starts before customs clearance

The first impact is not tax payment. It is the quality of information available before shipment. Product description, tariff classification, transaction type, economic destination, commercial documents, expenses and legal grounds need to form a coherent whole.

Incorrect or incomplete information can be repeated throughout the operation:

• cost estimates
• product records and purchase orders
• commercial invoices and DUIMP
• inbound tax documents
• appropriation of tax credits

The place of consumption becomes more important

The new DUIMP data includes the state and municipality of the place of consumption. This should not automatically be confused with the port of entry, customs facility, trading-company address or initial warehouse.

The answer must reflect the legal and economic nature of the transaction. Direct imports, imports on behalf of a third party, imports to order and goods destined for different establishments may require different analyses. Filling the field with the most visible address without checking the buyer, modality and effective place of consumption creates technical risk.

Orders placed in 2026 may arrive in 2027

An international purchase can involve months of production, booking, transit, clearance and inland transport. Orders placed in the last quarter of 2026 may therefore clear customs after the 2027 rules begin.

• replacement of PIS and Cofins by CBS
• IBS collection at a transition rate
• simultaneous ICMS during the transition
• the start of the Selective Tax for covered goods
• zero IPI for most products, subject to Manaus Free Trade Zone exceptions

The impact is not limited to nominal tax rates

Comparing the current and new systems requires more than adding rates. Importers must assess payment timing, availability and timing of credits, the tax base, cash-flow effects, coexistence of IBS and ICMS, differentiated treatments and compatibility among ERP, tax documents and DUIMP.

Decree 12,955/2026 generally requires CBS on imports of tangible goods to be paid by delivery, while allowing advance payment at declaration registration. It also provides credits for amounts effectively paid when regular-regime conditions are met. Even where credit is available, the cash outflow and recovery period remain relevant.

Product data has an even greater financial effect

NCM, technical description, attributes, unit of measure, purpose, origin, manufacturer, foreign operator and legal treatments cannot be managed as isolated fields. Differences among master data, commercial documents and the declaration can cause inconsistent calculations and rework after the cargo is already in transit or storage.

The central task is not merely to add fields, but to assign responsibility for the origin, validation and maintenance of information.

Some definitions are still evolving

The principal legislation has been published, including Complementary Law 214/2025, Decree 12,955/2026 and CGIBS Resolution 6/2026. Technical acts, layouts and operational guidance continue to change.

Current projections should clearly record their assumptions. Treating rates, procedures or system behavior still subject to regulation as definitive creates false precision. Procurement, tax, accounting, finance, technology, logistics and customs teams should use the final quarter of 2026 to identify operations crossing the year and compare tax and financial scenarios.