Doing Business in Brazil: Licenses, Models, and What to Know in 2026

Key points

• Doing business in Brazil as a foreign company does not always require opening a local subsidiary — the right operating model depends on your commercial objectives and timeline.
• Foreign companies must work through overlapping federal, state, and municipal regulatory layers before selling or importing goods in Brazil.
• The RADAR license (Receita Federal) is the primary gateway for import operations — without it, no goods can clear Brazilian customs.
• An Importer of Record (IOR) eliminates the need to obtain local licenses, hire local staff, or establish a legal entity for product testing and market entry.
• Brazil’s 2026 NCM update (ADE RFB nº 1/2026) extinguished 5 codes and modified 24 total — companies with active shipments need to verify their product classifications before the next shipment.
• Tax optimization tools — Bonded Warehouses, Drawback, and regional incentives — are available from day one and belong in your entry cost model, not your third year of operation.

Index

1. Introduction
2. The regulatory landscape foreign companies face
3. Three ways to operate legally in Brazil
4. The RADAR license: the non-negotiable first step for importers
5. Digital compliance in Brazil: Gov.br, NF-e, and the DUIMP
6. Tax optimization for importers: Bonded Warehouses, Drawback, and regional incentives
7. How the 2026 tax reform affects your entry strategy
8. When an Importer of Record replaces local licenses
9. The 2026 NCM update: what changed and what it means for importers
10. Regulatory compliance checklist for foreign companies
11. Frequently asked questions
12. Conclusion

Introduction

Doing business in Brazil involves one of the most layered regulatory environments in Latin America — and the decisions made in the first months often determine whether a market entry succeeds or stalls. For foreign companies, the first challenge is not finding customers. It is understanding what legal and operational structure is actually required before the first product reaches a Brazilian buyer or warehouse.

The answer depends heavily on what you plan to do: import goods for resale, test the market with a small shipment, demonstrate products at a trade fair, or build a permanent commercial presence. Each path carries a different set of licenses, registrations, and tax obligations — and choosing the wrong model can mean months of delays, unexpected costs, or exposure to fines.

This guide covers what foreign companies actually need to operate in Brazil in 2026, which permits are truly mandatory, where tax optimization tools sit in the compliance picture, and where an Importer of Record arrangement can eliminate most of the regulatory burden without requiring a local legal entity.

The regulatory landscape foreign companies face

Brazil’s regulatory framework for foreign companies operates on three levels simultaneously: federal (Receita Federal, MDIC, ANVISA, INMETRO), state (SEFAZ, state environmental agencies), and municipal (operating permits, fire safety certificates). A foreign company that ignores any of these layers risks having products blocked at customs, operations interrupted, or goods seized.

At the federal level, the Receita Federal oversees import licensing and tax compliance. ANVISA controls the entry of health, food, pharmaceutical, and cosmetic products. INMETRO and ANATEL govern technical certifications for electronics, machinery, and telecommunications equipment. These are not optional certifications for companies in regulated sectors — they are conditions of market access.

ANVISA has progressively aligned its review processes with international standards. For medical device manufacturers, participation in the Medical Device Single Audit Program (MDSAP) allows the MDSAP audit to replace the on-site B-GMP factory inspection by ANVISA — and under RDC 850/2024 (effective April 2024), manufacturers holding a MDSAP certificate can now obtain B-GMP certificates valid for four years instead of two. This is a meaningful reduction in audit overhead for European manufacturers already operating under ISO 13485 or participating in MDSAP. The broader alignment with international standards is continuing as part of ANVISA’s 2024–2025 regulatory agenda, which includes updates to GMP requirements for food processing and cosmetics surveillance norms.

At the state level, ICMS (the state value-added tax on goods) creates significant variation in effective tax burdens depending on where goods are received and sold. Some states offer fiscal incentives that substantially reduce the import tax load — a structural consideration that belongs in your market entry analysis, not your third year of operation.

Municipal requirements — operating permits (Alvará de Funcionamento), health permits from the local Vigilância Sanitária, and fire safety certificates (AVCB) — apply specifically to companies with a physical establishment in Brazil. If your strategy does not involve opening a local entity, these requirements typically do not apply to your initial operations.

For a broader overview of how public supervisory bodies interact with import operations, see Novatrade’s guide to public supervisory authorities in Brazil.

Three ways to operate legally in Brazil

Foreign companies entering Brazil typically choose between three operating structures, each with a distinct compliance profile:

The subsidiary route provides the deepest operational footprint but comes with six to twelve months of registration work, minimum capital requirements, and ongoing tax and labor compliance obligations. Most foreign companies find that the IOR model is sufficient for the first one to three years of Brazilian operations — and significantly cheaper to run.

For a detailed cost-benefit analysis of each model, Novatrade’s article on the benefits and challenges of a Brazil subsidiary covers the tradeoffs across tax, labor, and compliance dimensions.

The RADAR license: the non-negotiable first step for importers

Any company importing goods into Brazil — regardless of which operating model it uses — must have access to a RADAR license. Issued by the Receita Federal, RADAR (Registro e Rastreamento da Atuação dos Intervenientes Aduaneiros) is the credential that authorizes an entity to operate within the Siscomex import system. Without it, goods cannot be cleared at Brazilian customs.

Foreign companies that operate through an IOR bypass this requirement entirely: the IOR holds its own active RADAR and imports goods under its own license, assuming fiscal and legal responsibility for the shipment. This is one of the primary reasons why the IOR model accelerates time-to-market for foreign exporters.

For companies that choose to register their own Brazilian entity and handle imports directly, RADAR habilitation can take between 30 and 90 days depending on the company’s financial profile and import volume. The Receita Federal categorizes importers as Limitada (lower volume) or Ilimitada (higher volume), each with different documentation and financial requirements.

See Novatrade’s detailed guide on the customs clearance process in Brazil for a step-by-step breakdown of how RADAR operates within the Siscomex framework.

Digital compliance in Brazil: Gov.br, NF-e, and the DUIMP

One area where Brazil has made genuine progress is administrative digitization. The Gov.br platform now centralizes most federal registration and licensing procedures — including digital signatures with legal validity, integrated commercial registration, and company authentication — without requiring notarized physical documents. For foreign companies used to Brazilian bureaucracy from a decade ago, this is a real change: many procedures that once required weeks of notarization and apostille now complete in days.

The Nota Fiscal Eletrônica (NF-e) is now the universal standard for commercial transactions in Brazil, with adoption exceeding 99% across the formal economy. Every goods movement within Brazil — including from customs to warehouse to buyer — generates an NF-e, and the NF-e number is required at each transfer point. Foreign companies operating through a local partner or IOR should confirm their partner’s NF-e workflow before goods arrive, not after.

On the import side, the DUIMP (Declaração Única de Importação) replaced the legacy DI (Declaração de Importação) system and has been mandatory for all import operations since 2023. The DUIMP is a fully electronic declaration that integrates product classification, licensing requirements, and tax calculation in a single workflow within Siscomex. One practical consequence for importers: NF-e validations now cross-reference the NCM code against the DUIMP, so an incorrect product classification generates both a customs problem and a tax document rejection simultaneously.

Tax optimization for importers: Bonded Warehouses, Drawback, and regional incentives

The Brazilian tax system on imports is one of the most complex in the world — but it also contains a set of legal optimization tools that experienced importers use from day one. Most foreign companies discover these mechanisms in year two or three, after paying the full tax burden unnecessarily.

Bonded Warehouses (Entrepostos Aduaneiros) allow imported goods to be stored in Brazil without paying import taxes until the goods are actually sold or released into the national market. For companies testing demand, managing seasonal inventory, or selling to multiple buyers with staggered delivery, this regime separates the moment of import from the moment of tax payment — which can have a significant effect on working capital. Goods stored under the bonded regime can also be re-exported without triggering the original import taxes at all. Novatrade operates its own bonded warehouse solution; details on scope and product categories are available on the Bonded Warehouse service page.

Drawback is a tax suspension regime available to companies that import inputs to manufacture goods for export. It comes in two forms. Drawback Suspensão suspends import duties, IPI, PIS, and COFINS on the imported inputs for the duration of the production cycle. Drawback Integrado — the more widely used version since its introduction — consolidates the suspension into a single act and allows the regime to cover both imported and domestically purchased inputs. For European manufacturers setting up production or assembly operations in Brazil, Drawback can substantially reduce the cost of imported components.

Regional investment incentives — managed by SUDAM (Superintendência do Desenvolvimento da Amazônia) for the Amazon region and SUDENE (Superintendência do Desenvolvimento do Nordeste) for the Northeast — offer income tax reductions of up to 75% for qualifying projects in those areas. These are sector-specific and require formal approval, but for companies evaluating where to establish a production or distribution base in Brazil, the fiscal difference between a São Paulo operation and an approved SUDAM or SUDENE project can be substantial enough to affect the site selection decision.

For a more detailed look at import tax reduction strategies available to foreign companies, see Novatrade’s guide on 9 strategies to minimize import taxes in Brazil.

How the 2026 tax reform affects your entry strategy

Brazil’s tax reform — approved in late 2023 and entering its implementation phase in 2026 — restructures the country’s indirect tax system in ways that directly affect import costs and operating economics for foreign companies.

The reform replaces PIS, COFINS, IPI (partially), ICMS, and ISS with two new taxes: CBS (Contribuição sobre Bens e Serviços, federal) and IBS (Imposto sobre Bens e Serviços, subnational). The transition period runs through 2033, meaning companies that enter the Brazilian market now will operate under a hybrid system for nearly a decade.

For importers, the reform has two direct consequences. The CBS applies to imported goods at the federal level from 2026, replacing PIS/COFINS on imports. The consolidation of ICMS into IBS is expected to reduce the inter-state tax arbitrage that has long made certain states more attractive as import hubs. Companies currently using state fiscal incentives to reduce effective import costs should model how their landed-cost structure changes as the reform phases in — the ICMS-based incentives that work today will not all survive the transition intact.

It is also worth noting that the DUIMP now maps NCM codes directly to IBS/CBS classification codes (ClassTrib) for each NF-e. This means product classification errors have a broader downstream effect under the new system than they did before — they cascade from customs into tax document generation simultaneously.

For an in-depth analysis of how the reform affects import operations specifically, see Novatrade’s guide to Brazil’s tax reform and its implications for foreign companies.

When an Importer of Record replaces local licenses

The most common misconception among foreign companies planning to enter Brazil is that importing requires establishing a legal entity first. For the majority of use cases — market testing, pilot shipments, trade fair demonstrations, and early-stage distribution — an Importer of Record arrangement handles the entire regulatory interface without requiring a CNPJ, local employees, or a Brazilian bank account.

Under an IOR structure, a licensed Brazilian entity (the IOR provider) imports goods on behalf of the foreign company, manages all customs documentation, pays applicable import taxes, and releases products to the foreign company’s Brazilian customer or warehouse partner. The foreign company retains full commercial control — pricing, customers, contracts — while the IOR assumes legal and fiscal responsibility at the border.

This model works particularly well for companies that need to operate in Brazil quickly, want to validate demand before committing to subsidiary costs, or import goods into regulated categories (health, cosmetics, electronics) where ANVISA or INMETRO approvals are needed before commercial sales can begin. An IOR provider with active regulatory relationships can also manage the ANVISA registration or INMETRO certification process in parallel with the import operations — reducing the total time-to-market compared to a company managing both tracks independently.

Novatrade operates as an IOR for European companies entering the Brazilian market. For companies evaluating whether the IOR model fits their current phase, Novatrade’s IOR service page covers scope, timelines, and product categories handled.

The 2026 NCM update: what changed and what it means for importers

In January 2026, the Receita Federal published ADE RFB nº 1/2026, updating the TIPI (Tabela de Incidência do Imposto sobre Produtos Industrializados) to reflect changes introduced by Resolução GECEX nº 812/2025 and three MERCOSUL resolutions (GMC nº 17, 18 and 19/2025). The update took effect on 1 February 2026.

In total, 24 NCM codes were affected: 5 were extinguished, 13 were created, and 6 had their descriptions changed. The extinguished codes cover product categories including protective helmets (6506.10.00, split into two subcodes based on visor configuration) and certain impregnated textiles (5903.90). The new codes include classifications for iron ore briquettes (2601.12.20), PFAS compounds (2915.90.70), polycarboxylate superplasticizer precursors (3907.29.92), and 5G base station antennas (8517.71.20).

The practical consequence is immediate: any NF-e that references an extinguished NCM code is rejected by SEFAZ with error 778 (“NCM inexistente”). Export declarations linked to DU-E face the same rejection in Siscomex. Companies with active product registrations, recurring import orders, or warehouse stock records that reference any of the 5 extinguished codes need to update their product master data before the next transaction.

For companies importing products in the affected categories, confirming correct NCM classification is not a formality — it is the difference between a shipment clearing customs and a shipment stalled at the border. Novatrade’s NCM classification and revision service covers pre-shipment code verification for companies that want to confirm their classification before the next order.

Regulatory compliance checklist for foreign companies

The specific requirements depend on your operating model and product category, but the following checklist covers the baseline obligations for most foreign companies doing business in Brazil:

For companies focused on import operations without establishing a local entity, the first two groups in this checklist are the operational reality. The third and fourth groups apply only when a subsidiary or physical commercial location is part of the plan.

Frequently asked questions

Do I need a CNPJ to start doing business in Brazil?

Not necessarily. Foreign companies that use an Importer of Record (IOR) operate under the IOR’s CNPJ and RADAR license. The foreign company itself does not need a Brazilian legal entity to import goods, test the market, or sell through local distribution partners. A CNPJ is only required if you establish your own legal entity in Brazil.

How long does it take to start operating in Brazil as a foreign company?

With an IOR, operations can begin in two to six weeks from the first shipment preparation. Opening a Brazilian subsidiary typically takes six to twelve months, including CNPJ registration, RADAR habilitation, and state-level registrations. The IOR route is used by most companies for initial market entry precisely because of this timeline difference.

Which products require ANVISA approval before import?

ANVISA oversight applies to health products broadly: pharmaceuticals, medical devices, diagnostic equipment, cosmetics, food supplements, and certain food categories. Some products require full registration — which can take 12 to 36 months — while others are eligible for simpler notification or exemption procedures. Medical device manufacturers already holding a MDSAP certificate can use the streamlined B-GMP path introduced under RDC 850/2024, which removes the need for a separate on-site factory inspection by ANVISA. An IOR provider with active ANVISA relationships can determine the applicable route before the first shipment is planned.

How does Brazil’s 2026 tax reform affect import costs?

The CBS (federal) replaces PIS/COFINS on imports from 2026, and the IBS gradually absorbs ICMS through 2033. The net effect on landed costs depends on your product category and the fiscal regime under which your Brazilian entity (or IOR) operates. Companies using state ICMS incentives to reduce import costs should model how those benefits erode as the reform phases in. The transition period creates both risk and planning opportunity — companies that map their tax position now will have more options than those that wait.

What is the difference between a Bonded Warehouse and standard import?

In a standard import, duties and taxes are paid when goods clear customs, regardless of when they are sold. Under the Bonded Warehouse (Entreposto Aduaneiro) regime, goods enter Brazil and are stored in a licensed facility without triggering import tax payment until they are released into the national market. Goods that are re-exported from a bonded warehouse never trigger the original import taxes at all. This regime is particularly useful for companies testing demand, managing seasonal inventory, or supplying multiple Brazilian buyers from a single stock point.

Can I bring products into Brazil temporarily for trade fairs without full import clearance?

Yes. Brazil’s Temporary Admission (Admissão Temporária) regime allows goods to enter the country for specific purposes — including trade fair demonstrations, equipment testing, and product exhibitions — with suspension of import taxes, provided the goods leave within the authorized period. This is a distinct regulatory pathway from standard commercial import and requires specific documentation at customs.

Conclusion

Doing business in Brazil as a foreign company is manageable — but only when the regulatory structure is understood before the first shipment is planned, not after the first delay. The most expensive mistakes in Brazilian market entry are not caused by bad products or poor timing. They are caused by choosing the wrong operating model for the current phase of expansion, or missing a tax optimization tool that was available from the start.

For companies at the market-testing or early import stage, an Importer of Record arrangement eliminates the RADAR, CNPJ, and subsidiary registration requirements entirely. For companies further along, mapping the interaction between the 2026 NCM update, the CBS/IBS transition, and available regimes like Bonded Warehouse and Drawback is the kind of work that protects margins over a multi-year horizon.

Novatrade has supported European companies entering the Brazilian market since 2010 — across import operations, IOR arrangements, ANVISA compliance, bonded warehouse, and local establishment. If you are evaluating your options for Brazil, speak with our team to map the right structure for your product category and timeline.