RSM Brasil



The Brazilian Authorized Economic Operator Program (AEO), regulated by the Brazilian Secretariat of the Federal Revenue (RFB), certifies international trade stakeholders which present low operational risks, concerning both cargo physical security and tax and customs compliance.

Those certified as AEO shall benefit from several operational preferences, including being able to use the AEO seal, which states the company’s reliability before clients and authorities.

The long-awaited Ordinance n. 85 from November 14, which regulates the customs clearance of import "on the water” for AEO companies , was published last Friday on November 17, by the Federal Revenue, through the General Coordination of Customs Administration (COANA).

In practice, this means that the goods of the importer certified by the Program may be cleared before arriving at the customs office, in order words, during the transport by ship, while still in the sea.

As conditions for the importer to enjoy this benefit, it is necessary that the operation be carried out by waterway, the Import Record (DI) be the type of "Consumption" or Admission in the Free Zone of Manaus (ZFM), and the licensing, if there is any, be deferred at the time of registration of the DI. In this case, the DI in the "on the water AEO clearance" modality must be registered in advance, before the arrival of the cargo and without arrival date information.

This regulation represents a significant development for the Program, since it gives the importer an extremely important benefit, not only to reduce costs in the process of clearance, for example, those related to storage, but also, to save time previously spent in the process. It may represent a significant competitive advantage over those that have not yet been certified.

It should be emphasized that this type of import clearance can only be used by a legal entity certified as AEO-Compliance Level 2 (AEO-C Level 2) or AEO-Full (AEO-P), according to specific legislation the Brazilian Authorized Economic Operator Program.

It should also be noted that goods subject to physical inspection of consenting agencies cannot be subject to the clearance modality related in the aforementioned Ordinance.

RSM is available to assist in any questioning about the AEO as well as its implementation.













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Daniel Maia
Partner | Global Trade Practice Leader
[email protected]


Luiza Campos

Manager | Tax & Global Trade

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