RADAR and Siscomex: who can actually import into Brazil

This page covers who needs it, what the modalities are and what they limit, the three ways an import can be structured, and where import licensing fits. Facts are marked where they come from a secondary source rather than the official text.

The short answer

RADAR is granted by the Receita Federal to a Brazilian legal entity or an individual acting in their own name. A foreign company cannot hold it. If you are exporting to Brazil, the accredited party is either your Brazilian customer, your own Brazilian subsidiary, or a service provider importing on your behalf under one of the structures below.

The governing act is Instrução Normativa RFB nº 1.984 of 27 October 2020, in force since 1 December 2020. A later instruction, IN RFB nº 2.292 of November 2025, amends it; we have that amendment from a legal database rather than from the official normative text, which did not render for us.

Who has to be accredited

Anyone who will act as declarante de mercadorias in Siscomex, meaning the party filing the import or export declaration. That covers private legal entities and individuals acting in their own name.

The baseline requirements published by the Receita Federal are an active CNPJ, adherence to the electronic tax domicile (DTE), partners whose CPF status is regular or pending regularisation, and no existing suspension or disqualification.

The three modalities, and what they actually limit

The modalities are frequently described wrongly, including by trade advisory sites that present them as three price tiers. They are not. Only one of them is about value.

Expressa is defined by the type of company, not by transaction size. It covers publicly traded S.A. companies and their wholly owned subsidiaries, plus state owned enterprises and mixed economy companies. There is no value ceiling.

Limitada is the value based modality, and it has two levels: an estimated financial capacity of US$ 50,000.00 or US$ 150,000.00 per consecutive six month period, measured on the customs value of the goods.

Ilimitada has no value ceiling. It is assigned automatically once the estimated financial capacity exceeds US$ 150,000.00 per six month period; there is no separate track record requirement in the act, contrary to what several trade advisory sites claim.

If operations exceed the ceiling of a modality, the declarant is reassessed and moved into a different modality or limit. Financial capacity can be recalculated by the Receita Federal at any time from its own data.

The estimate itself (Portaria Coana nº 72/2020, article 2) is taxes actually paid, IRPJ, CSLL, PIS/Pasep and COFINS, or social security contributions if larger, over the current year and the four previous years, divided by the average USD exchange rate for the same five years. Declared but unpaid taxes, instalments and tax assessments do not count. The current USD divisor used in that formula is not published anywhere we could confirm; the last one we found, R$ 3.52423, applied to 2015-2019 in the original 2020 act, and later Coana updates could not be opened.

Inscrição estadual (state tax registration) is not a RADAR requirement. Article 21 of IN RFB 1.984/2020 lists connection to the electronic tax domicile (DTE), an active CNPJ, and CPF status "regular" or "pending regularisation" for all partners. After incorporation, CNPJ, inscrição estadual and RADAR run in parallel rather than one gating the other.

Source note: the modality definitions and the US$ 50,000 and US$ 150,000 thresholds come from the Receita Federal's own pages, and from IN RFB 1.984/2020 as amended by IN RFB 2.292/2025 (consolidated text) and Portaria Coana 72/2020 as amended by Portarias Coana 10/2021, 44/2021, 83/2022 and 93/2022.

How to raise a Limitada RADAR limit

Only companies in the Limitada modality can apply for a revisão de estimativa (IN RFB 1.984/2020 article 29). Five grounds are available, each with its own evidence and calculation (Portaria Coana 72/2020 article 4 for the grounds, article 11 for the calculation):

1. Funds in company accounts, including capital paid in cash: previous month's balances divided by the average exchange rate. Evidence is three months of bank statements, three months of balancete, transfer confirmations showing the sender, and loan contracts. This is the ground that works for a company with foreign shareholders, since paid-in share capital on paper does not move the limit by itself, only money actually in the account does.
2. Tax exemptions or immunities: taxes paid, plus taxes demonstrably not paid because of the benefit.
3. Simples Nacional (DAS): not available to a company with foreign participation, because LC 123/2006 excludes it from Simples Nacional in the first place.
4. CPRB: revenue over the last 60 months divided by 20.
5. Company started or resumed activity less than 5 years ago: taxes paid in the last 6 months multiplied by 10, with evidence of operational capacity such as a lease, utility bills or warehouse contracts.

Receita Federal has 10 days to decide; if it misses the deadline, the revision is deemed approved. If Receita requests more documents, the 10 day term restarts (IN RFB 1.984/2020 article 56 §1 and §3). A new Ltda with a foreign founder almost always starts at Limitada, US$ 50,000 per six months, and raises it through ground 1 once funds are actually in the account.

How long accreditation takes

Article 56 of IN 1984/2020 sets a ten day period for analysis, counted from the request to attach documents to the digital file, with automatic approval if the request is not decided in that time. That reading comes from a secondary reproduction of the text rather than from the official gazette, so treat the ten days as indicative and plan on longer.

Accreditation can be reviewed at any time. The official page on regularisation analysis does not state how often that happens, and we are not going to invent a cycle.

A foreign company cannot be the importer of record

This is the question European exporters ask most often, and the answer is no.

Accreditation is available to Brazilian private legal entities and to individuals acting in their own name. Separately, the Receita Federal's guidance on CNPJ registration for a company domiciled abroad lists a narrow set of purposes: holding real estate, vehicles or bank accounts, financial operations registered with the central bank, and investments through the securities commission. Import activity is not among them.

Neither document states the prohibition in a single sentence, so we state it as what follows from both: importing into Brazil requires a Brazilian entity with a CNPJ and RADAR accreditation. Practically, that means one of the three structures below.

The three import structures

Por conta própria. The Brazilian company buys the goods abroad with its own funds and imports in its own name, for its own use or resale. This is the default case, defined by what it is not.

Por conta e ordem de terceiro. One company is engaged to handle the customs process in its own name for goods bought abroad by another company, the adquirente. Article 2 of IN RFB nº 1.861/2018. The Receita Federal is explicit that concealing the real acquirer is a violation, and the adquirente is jointly liable for the taxes.

Por encomenda. The importing company buys the goods abroad with its own funds and imports in its own name for onward sale to a pre agreed encomendante. Article 3 of the same instruction. The importer owns the goods throughout and pays the foreign supplier itself.

In both of the last two, each party has to hold its own RADAR accreditation and the relationship has to be registered through Portal Único, with the counterparty's CNPJ declared and the prior contract attached.

Source note: IN RFB nº 1.861/2018 as the governing act is consistent across several independent sources; the article level text was read from a secondary reproduction. The joint liability point and the prohibition on concealing the acquirer come from the Receita Federal's own guidance.

Import licensing

Separate from accreditation, many goods need an import licence. The rules are in Portaria SECEX nº 249 of 4 July 2023.

An automatic licence is granted once the form is complete and the formal requirements are met, with a ten day period under article 11. A non automatic licence goes to a consenting agency for review, with a sixty day period under article 12. A licence is valid for 180 days under article 15.

Non automatic licensing applies to goods under tariff or non tariff quotas, cases requiring assessment of domestic similarity, used goods, United Nations Security Council restrictions, and cases where a breach of foreign trade legislation is suspected.

Fifteen agencies act as consenting bodies. The ones most European exporters meet are ANVISA for health regulated goods, MAPA for agricultural and animal products, INMETRO for goods on the compulsory certification list, and IBAMA for environmental controls. The official list we could open was last published in 2022, and ANATEL does not appear on it despite being widely described as a consenting body for telecoms equipment. We are flagging that gap rather than filling it.

Goods arriving without a licence that was required face seizure under the customs regulation. That reading comes from a secondary legal source citing Decreto 6.759/2009, and we have not verified the article text directly.

DUIMP: the declaration is changing, the accreditation is not

Brazil is replacing the old import declaration (DI) with the DUIMP, filed through Portal Único. As of 7 September 2026 the DUIMP is not universally mandatory and the two coexist.

The Receita Federal publishes a shutdown schedule for the DI. The version current as of 14 September 2026 still gives 11 October 2026 for maritime bulk cargo and 1 December 2026 as the final stage covering government bodies and thirteen documented edge cases, including consignments with several consenting agencies, multiple tax regimes, previously registered licences, individual importers, and operations with an encomendante or adquirente.

Those are planned dates, not guarantees. Check the current schedule before assuming which channel applies to a specific shipment.

What the transition does not change is who has to be accredited. RADAR remains a requirement regardless of which declaration is filed. The change is to the format of the declaration and to how much data is registered before the cargo arrives.

What the EU-Mercosur agreement does not do here

Nothing on this page is affected by the trade agreement. Accreditation, the choice between import structures, and licensing through the consenting agencies remain national rules, unchanged by the tariff schedule.

This was checked rather than assumed, though the check relied on a Brazilian legal analysis of the agreement's customs provisions rather than a line by line reading of the customs chapter.

Sources

• Accreditation: Instrução Normativa RFB nº 1.984 of 27 October 2020, in force 1 December 2020, as amended by Instrução Normativa RFB nº 2.292/2025 (consolidated text, legisweb.com.br); Portaria Coana 72/2020, as amended by Portarias Coana 10/2021, 44/2021, 83/2022 and 93/2022 (consolidated text, legisweb.com.br). Modality definitions and the US$ 50,000 and US$ 150,000 thresholds also come from Receita Federal pages on gov.br.
• Import structures: Instrução Normativa RFB nº 1.861 of 27 December 2018, articles 2 and 3. Joint liability and the prohibition on concealing the acquirer from Receita Federal guidance on gov.br.
• CNPJ for a company domiciled abroad: Receita Federal guidance page, gov.br, last updated 10 September 2024.
• Import licensing: Portaria SECEX nº 249 of 4 July 2023, consolidated text, articles 3, 11, 12 and 15, PDF obtained from gov.br/siscomex. List of consenting agencies from gov.br, published 2022.
• DI shutdown schedule: gov.br/siscomex, Cronograma de Desligamento da DI, version current 14 September 2026, re-checked live on 24 September 2026.
• Effect of the EU-Mercosur agreement on customs procedure: Brazilian legal analysis published March 2026, secondary source.

Facts on this page were checked on 24 September 2026. Brazilian customs procedure is in the middle of a transition and the DI shutdown dates are planned rather than fixed. Check the date before relying on anything here.