Letter from the table: The number that arrived after the cargo

RC/TR/2026/T.6 · 26 October 2026 · Stance: Amend

To the Trade Council,

At our last council session, on 20 October, I listened to us certify the pattern test for TR-001. I came away thinking about the word “landed.” It sounds like a finished number: the cost of getting something through customs and to your door. For a small importer, it can be a number that is still moving after the cargo has arrived.

On 18 September, I was trying to plan a purchase for my business here in Curitiba. I will not describe the goods; the point is not what I import but how I had to price the decision. The supplier’s invoice was US$2,400. With freight and insurance, the estimate I was working from was about R$13,800. I asked for a landed-cost figure before confirming, because I needed to know whether I could pay the full amount without squeezing the rest of the month.

The forwarder sent an estimate of roughly R$22,600. It listed freight and customs-related charges, and it included an estimate of taxes. I understood that this was not a binding tax assessment. In Brazil, the result depends on the goods’ classification, the customs procedure and the applicable federal and state taxes. The import declaration runs through Siscomex; the NCM classification matters, and ICMS is a state tax. I was not asking anyone to promise that a forecast could never change. I was asking what assumptions sat underneath it.

I tried to get that answer before authorising the shipment. I asked which exchange rate had been used, whether the tax estimate assumed the same NCM classification I had given, which charges were taxes and which were services, and what might still be added before release and delivery. The reply helped with some items, but the figure still did not tell me, in one place, what was fixed, what was estimated and what could change. I had to compare messages and build my own list.

When the final charges were assembled, the total was about R$27,450. Some movement was understandable: the exchange rate and the actual handling and customs steps were not identical to the estimate. But an increase of almost R$4,900 over the figure I had used to decide was not a rounding error for a small business. I delayed another payment and spent time checking each line with the people handling the shipment. That time has a cost too, although it never appears in a landed-cost total.

I know the rules are not a simple menu. A forwarder cannot decide the tariff classification for me by wishful thinking, and a quote cannot remove duties or taxes created by law. I also know that a small importer has obligations. We must provide accurate information, keep records and meet the applicable requirements. My complaint is not that the process contains uncertainty. It is that the uncertainty is often handed to the smallest party as a lump sum, without a clear map of where it comes from.

That is what I learned from the council session. Our reports show more than the existence of tariff shocks. They show a gap between a technically correct estimate and a figure a small trader can use to make a decision. If we write only “provide landed-cost transparency,” the phrase may be too easy to satisfy with a total and a disclaimer. The useful information is the breakdown and the assumptions, given early enough to act on.

I ask the council to amend the draft Small Importer Standard in three ways.

• Require a written estimate to separate government charges, freight, insurance, brokerage and other service fees, with the basis or rate used for each estimated amount where that information is available.

• Require the quote to state its material assumptions plainly, including the currency-conversion basis, the tariff classification used or still to be confirmed, and any known licensing or customs steps that could affect the amount or timing.

• When a material assumption changes, require an updated estimate and a short explanation before the next avoidable commitment is made, where practicable. A range is more honest than false precision; an unexplained final bill is not a range.

I would also keep the standard proportionate. A small trader should not need a customs specialist to understand the document. The guidance should say what the forwarder knows, what remains uncertain, who must confirm it and when the customer is likely to hear more. It should not make a forwarder responsible for setting tax law, or make an estimate a guarantee where the underlying facts can change.

The proposed size-based thresholds and phase-in for new trade rules matter. But even a threshold that exempts a small trader from a new requirement cannot help much if the trader cannot see the likely cost of the shipment already in motion. For me, the landed-cost issue is the bridge between a rule on paper and a decision made at a desk in Curitiba.