Regulatory determination for equipment entering Brazil Português  ·  +55 81 99357-1390
ATIENZACOMEX

What we do

Six services, on two sides of the same border.

Four of them answer one question: who, in Brazil, is legally responsible for this equipment, and is that party equipped to be responsible for it. The other two answer the question that comes before it: whether the operation is possible at all this semester, and who the counterpart on the other side is going to be.

None of them involves taking title to goods, moving cargo, clearing customs or reselling. We work alongside your freight forwarder and your customs broker rather than replacing them.

01

Entry determination

A written opinion on one specific model: which compulsory certification, import licence or homologation reaches it, under which ordinance and which article, and what the exclusion paragraphs do or do not remove.

This is the service that most often ends in bad news, and that is the point of it. Being told in September that a machine cannot be sold as configured is inexpensive. Being told by an inspector after the container has arrived is not.

The opinion states what was determined, what was not, and the source of each. A question we could not settle is written as an open question, never rounded into an answer.

It is a technical and regulatory opinion. It cites the ordinance and the article so your own engineer or your own counsel can check every line of it without taking our word for anything.

02

Registration and homologation holding

Brazilian registration is held by a Brazilian party. For telecommunications products the rule is explicit: the applicant must be a person resident in Brazil or a legal entity constituted under Brazilian law, because the regulator requires a party inside the national territory answerable for information, warranty and technical assistance. For compulsory INMETRO certification, the registration is issued to the supplier responsible in Brazil, which for an imported product is normally the importer.

That creates a decision a foreign manufacturer cannot avoid: the registration goes in the name of a distributor, of a Brazilian company the manufacturer controls, or of an independent third party. Each choice has a different consequence the day the relationship ends, because the registration does not automatically follow the brand.

We can hold the registration, or set up and supervise the arrangement you prefer. We say plainly which of the three we think fits, including when the answer is that your existing distributor should keep it.

03

Point of contact and record custody

A named, staffed address in Brazil that receives correspondence from INMETRO, ANATEL, ANVISA, a certification body or a consumer protection authority, understands what is being asked, and answers it inside the deadline. And the place where the certificates, test reports, conformity declarations and ordinance versions are kept complete, current and retrievable.

This role carries real duties, not just a mailbox. Under the Brazilian consumer statute, a supplier who learns after market entry that a product is hazardous must notify the competent authorities and consumers. The same statute makes the importer answer for defect damages regardless of fault, alongside the foreign manufacturer. Somebody in Brazil is going to carry that. It should be somebody who knew it was coming.

Two things go wrong with the documentation, and both are ordinary. It sits with a distributor who later becomes an ex-distributor. Or certification is done once against an ordinance that is afterwards amended, and nobody re-reads the file against the new text. An amendment that widens scope reaches products that were compliant the week before. We hold the file, watch the ordinance it depends on, and tell you when the ground moves.

04

Labelling and Portuguese documentation

The Brazilian consumer statute requires product information to be correct, clear, precise, conspicuous and in Portuguese, covering characteristics, quantity, composition, warranty, origin and the risks the product presents. Compulsory certification adds its own identification plate, marking and warning requirements on top of that.

This is the cheapest thing on this page to get right and one of the most common reasons a perfectly good machine cannot be sold. A translated manual is not the same thing as a compliant one, and a marking that is correct in Europe is not automatically correct here.

05

Siscomex enabling and the semester ceiling

Before a Brazilian company can import or export at all, it has to be enabled in Siscomex, and that enabling carries a ceiling. Under the tax authority's rule, the limited modality caps operations at US$ 50,000 or at US$ 150,000 in each 180 day period, according to the financial capacity estimated for the company. Above that sits the unlimited modality, which has no ceiling, and a further modality reserved by the rule for listed companies and state-owned entities.

So the first question on any deal is not commercial. It is how much room the Brazilian side has left in the current period. A company on the lower band cannot take a US$ 200,000 order this semester, whatever it has agreed, and this is usually discovered after the price has been quoted.

We determine which modality a company sits in, what that leaves it for the period, and what the file has to look like to move it up. Raising the ceiling runs either as a review inside the tax authority's own system or as a digital process with accounting and banking evidence, with a ten day analysis window.

06

Market research and counterpart search

Two directions, one method.

To buy abroad: identifying and qualifying suppliers for a specific machine or input, checking what the equipment will require to enter Brazil, and doing that before anyone has paid for a sample. A buyer who discovers a certification requirement after the proforma invoice is signed is in the same position as a manufacturer who discovers it at the port.

To sell abroad: sizing the destination market, finding the importers, distributors or industrial buyers who actually handle that product there, and reading what the destination requires of the product before the first shipment. The barrier exists in both directions, and a Brazilian exporter meets somebody else's version of the same rule.

We introduce and we document. We take no commission on the trade and we never take title to the goods, and that is what keeps the research honest: there is no deal we are steering you toward.

What we do not do

We do not buy, sell or resell equipment, and we never take title to goods. We do not clear customs, move freight or operate a warehouse. We are not a law firm and we do not practise law. We are not a certification body and we do not issue certificates: that is done by bodies accredited by the regulator, and we would be conflicted if we did both. We do not promise an approval, a timeline or a result that depends on a third party.

And we do not tell a manufacturer that a competitor has no representative in Brazil. We can tell you what a public register contains on the day we read it. That is not the same statement, and we keep the difference.