Letter from the table: A landed cost is not one number

To the Trade Council

I am writing from Curitiba, where I joined the Landed Cost Diary because I want the Council’s proposal to work for traders who have to make a decision before every part of the cost is knowable.

On 18 February 2026, I approved a small business import order. The supplier’s invoice was US$2,180. The freight forwarder’s first estimate showed R$4,960 for freight, handling and customs-related charges. I understood that estimate to be provisional. What I did not understand was how much of the final bill was still outside it, and which parts could change before the goods were released.

On 3 March, I asked the forwarder for an item-by-item estimate in reais. I received separate figures for freight and handling, but the tax lines were described as estimates and the basis for them was not set out in a way I could reconcile with the invoice. I then asked a customs broker to explain the tax calculation. The answer was useful, but it came after I had committed to the order and depended on details such as the product’s NCM classification, the customs value, the applicable federal taxes and the state ICMS treatment.

The shipment cleared on 24 March. The total paid in Brazil for freight, handling, customs and taxes was R$7,830. That was R$2,870 above the first estimate. The difference was not one surprise fee. It reflected a mixture of costs that were fixed or contractually quoted, and taxes and related charges whose calculation depended on the import entry and the applicable rules. I had to assemble the explanation from the forwarder’s bill, the customs broker’s message and the documents generated through the import process.

Brazil does have formal institutions and rules for this. Imports are processed through the federal customs system, and the Receita Federal administers federal customs and import-tax matters. The state also matters: ICMS is a state tax, and the applicable treatment and calculation can depend on the goods and the circumstances of the import. Import charges may include, among others, Import Duty, IPI, PIS/Pasep-Import and Cofins-Import, alongside ICMS. The classification and customs value are not details a trader can safely guess from a supplier’s invoice alone.

That structure is not the same as a single, final “landed cost” that a forwarder can promise at the quotation stage. A forwarder can describe its own fees and explain the assumptions used for an estimate. It cannot guarantee a tax authority’s assessment or make an uncertain classification certain. But that distinction should be visible to the customer before the order is placed, not reconstructed after the bill arrives.

I tried three things. First, I asked for a written estimate broken down by freight, service fees, government charges and other expected costs. Second, I asked which figures were firm, which were estimates and what assumptions had been used for classification, value and exchange conversion. Third, I asked whether the quote would be updated if the customs entry or the relevant rules changed before clearance. I received pieces of the answer, but not one document that put the assumptions and limits together. The time spent chasing it was itself a cost: I postponed another purchase while I checked whether the original order still made sense.

The Council’s proposed Small Importer Standard is right to ask for plain-language guidance, size-based thresholds and a phase-in when new trade rules or tariffs apply. I also support landed-cost transparency from forwarders. I ask that the text be amended so it does not imply that a forwarder can guarantee a final tax bill. Instead, it should require a clear, dated estimate that separates the forwarder’s own charges from government taxes and other third-party charges; identifies the classification, value and exchange-rate assumptions used; labels

each line as fixed, estimated or not yet known; and explains what event may cause an update.

For a small trader, “estimated” is not enough information. The estimate should say estimated on what basis, and what would make it change. If the forwarder cannot responsibly calculate a tax line, the document should say so and point to the next step: the customs broker, the relevant official guidance or the information still needed. When a new rule or tariff applies, a small trader should have a reasonable transition period and a plain explanation of which shipments are affected. These safeguards would make the standard more honest and more useful without making intermediaries responsible for decisions they do not control.