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Trade Council
Letter from the table: The cost that arrived after the shipment
To the Trade Council
I support TR-001. I am writing from my own records because an import can look affordable on the day you place an order and become a different financial decision by the time the goods are released. I am not asking the Council to argue that every difference is an error. I am asking that a small trader be able to see, early enough to act, what is known, what is estimated, what is excluded and what may still change.
On 12 February 2026, I asked a freight forwarder for an estimate for one small shipment of business inputs to Paraná. I had the supplier’s invoice and the basic shipment details. The written estimate put freight, insurance, clearance and delivery at R$14,600. It gave a provisional R$12,900 for import taxes and duties. I wrote R$27,500 in my notebook as the expected cost after arrival. The note said some local charges could vary, but it did not give a range or explain which charges were outside the estimate.
I asked whether R$27,500 was the amount I should use to decide if the order was viable. I was told, in effect, that it was an estimate and the final amount depended on the customs declaration. That was fair as far as it went. But I still did not know which assumptions would change the figure: the exchange rate, the customs value, the tariff classification, local handling, or something else. I could not make a useful comparison with another quote when each one grouped or qualified its costs differently.
I placed the order on 3 March. The shipment arrived on 24 March. Before that, I had tried to get a more complete written breakdown and to keep enough cash available for the final payment. The answer I could get was not a firm landed-cost range. I therefore kept the original estimate, plus a reserve I chose myself. That reserve was not based on a clear explanation; it was a guess about how much uncertainty I could absorb.
For an import cleared in Brazil, there are real reasons why the final amount may not be fixed at the quote stage. Federal import taxes and charges are distinct from state ICMS, and the applicable treatment can depend on such matters as the goods’ classification, customs value and circumstances of the import. ICMS is a state tax; for a shipment delivered in Paraná, that state context matters. The importer must provide accurate information through the customs process, including the relevant tariff classification. I am not asking forwarders to promise that a tax assessment, exchange rate or customs decision cannot change.
On 26 March, the import declaration was submitted. I received the final figures in pieces rather than as one clear reconciliation against the February estimate. The tax-and-duty disbursement was R$15,040, R$2,140 above the provisional figure. Freight, insurance, clearance and delivery came to R$16,880, including R$2,280 in additional local handling and terminal charges beyond the original R$14,600. The total after-arrival cost was R$31,920. Against the estimate, that was R$4,420 more.
The shipment was released on 3 April, eight calendar days after the declaration was submitted. I am not claiming that all eight days resulted from one person or one fee. The important point in my record is that, during that period, I was trying to match charges to assumptions while the goods were not available for use. A delay and a surprise charge are not abstract when the money has already left the account and there is no dependable date for the next step.
12 February: estimated after-arrival cost, R$27,500. 3 April: final after-arrival cost, R$31,920. Difference: R$4,420. Time from declaration submission to release: eight calendar days.
I queried the additional charges and asked for the documents behind them. I also compared the final bill with the estimate, line by line, and recorded which amounts had been provisional and which had not been shown as included. I could not make the original estimate answer the question I had actually needed answered: “How much cash should I expect to have committed before this shipment is usable, and what could make that amount rise?” The final paperwork helped explain
individual items, but it arrived too late to help me decide whether to order or plan the cash.
That is why I support the proposed standard. It should ask a forwarder to provide a plain-language landed-cost statement before booking, with separate lines for freight and insurance, estimated taxes and duties, clearance, local handling, terminal charges and delivery. The statement should identify what is included, what is excluded, the assumptions used, and which items are estimates rather than fixed charges. If an amount cannot yet be known, show a reasoned range where possible and say what event or information will narrow it. At arrival and after clearance, the customer should receive an updated reconciliation against the first estimate.
I also support size-based thresholds, practical guidance and a phase-in when new trade rules or tariffs apply. That should not mean waiving legitimate duties or lowering the standard of a customs declaration. It should mean that a small trader is not expected to absorb a new process without time, understandable instructions and a workable way to estimate the cost. A large operation can spread the work of checking rules and reconciling invoices across specialist staff. A very small operation often has to do it between everything else.
My position is therefore straightforward: make the cost visible before commitment, explain what can change, and show the change when it happens. I support TR-001 and ask the Council to carry these points into its draft. An estimate does not have to be a guarantee to be useful. It has to be clear enough that a small importer can make a decision with open eyes.
Luciana CarvalhoLead author · Trade CouncilCuritiba, Brazil