What EU-Mercosur does not change

The direct answer

The EU-Mercosur trade agreement changes one number: II, the import duty charged at the Brazilian border on goods entering the country. It does not change IPI, PIS/COFINS, ICMS, ANVISA registration or notification, MAPA establishment registration, INMETRO certification, Portuguese-language labelling, or the RADAR accreditation an importer needs to operate in Siscomex.

A duty cut lowers the II line in a landed-cost calculation, and because IPI and ICMS are both calculated on a base that includes II, a lower duty trims those two taxes by a small amount as well. The rates themselves do not move. Whether a product can legally enter Brazil at all is decided by a separate set of rules: ANVISA for health-regulated goods, MAPA for wine and animal products, INMETRO for anything on its compulsory certification list. None of that sits inside the trade agreement. A company that could not sell a product in Brazil before the agreement, for lack of a registration, still cannot sell it after the agreement takes effect.

What EU-Mercosur changes in the tax stack, and what it does not

Brazil calculates import taxes in a fixed order: II first, then IPI, then PIS/COFINS, then ICMS grossed up. AFRMM, the merchant marine renewal fee, and the Siscomex declaration fee sit outside that chain, charged separately. EU-Mercosur touches exactly one line in that order, II. Every other line is calculated the same way, at the same rate, before and after the agreement.

Tax	What it is charged on	Rate	Changed by EU-Mercosur
II (import duty)	Customs value, CIF plus freight, insurance and terminal handling	Set per tariff line, reduced under the agreement's staging schedule (categories run from immediate elimination to sixteen annual steps)	Yes, this is the one line the agreement changes
IPI	Customs value plus II	Product-specific; the rate itself is unchanged, but the amount collected falls slightly because the II component of its base falls	No
PIS/COFINS-Importação	Customs value only	Standard 11.75% combined (PIS 2.1%, COFINS 9.65%, Lei 10.865/2004 art. 8); perfumery and cosmetics run a separate single-stage regime at 20.00% combined (PIS 3.52%, COFINS 16.48%). Some codes also carry a temporary COFINS-Importação surcharge, 0.6% in 2026 falling to 0.4% in 2027 under Lei 14.973/2024	No
ICMS	Customs value plus II plus IPI plus PIS plus COFINS plus customs expenses, grossed up "por dentro"	18% standard / 25% supérfluos in São Paulo; 22% standard / 39% supérfluos effective in Rio de Janeiro (including the FECP surcharge)	No
AFRMM	Ocean freight	8% for long haul and cabotage; 40% for river and lake transport of liquid bulk in the North and Northeast	No
Siscomex fee	Per customs declaration	R$115.67 plus R$38.56 per additional item, R$154.23 for two items	No

Because IPI is charged on customs value plus II, a lower II trims the IPI amount slightly even though the IPI rate is untouched. The Portal Único Siscomex simulator, queried 7 September 2026 for a shipment from Germany at a customs value of R$100, shows what that looks like in practice: IPI on centrifugal pumps (NCM 8413.70.90) came out at a derived rate of 0%, on lip make-up (3304.10.00) at 14.30%, on filled chocolate (1806.31.10) at 3.25%, and on wine (2204.29.10, using the general "EX IPI" code) at 6.50%. None of those rates changes because of EU-Mercosur, only the II component feeding into the base.

PIS/COFINS-Importação is charged on customs value alone, not on II or IPI, so a duty cut has no effect on this line in either direction. ICMS, grossed up "por dentro" on a base that includes II and IPI, moves by the same small margin as IPI does. Wine and cosmetics fall into the higher supérfluos band in both states above; chocolate and pumps do not.

Because the ICMS rate cancels out of the percentage-saving formula mathematically, a lower II does eventually show up as a smaller landed cost, though never at the full headline rate. Across four worked product codes, a duty cut of 12.6 to 18 percentage points produced a landed cost fall of 10.0% to 13.9%, or 74% to 79% of the headline cut, averaging about 77%. The gap is PIS/COFINS and AFRMM, both charged on the customs value regardless of the duty rate. (Those model runs used an 18% ICMS rate for every product, including wine and cosmetics, which understates their absolute landed cost since both actually sit in the supérfluos band; the percentage-saving figure is not affected, since the ICMS rate cancels out of that particular calculation.)

The regulatory side: ANVISA, MAPA, INMETRO

Three regulatory systems decide whether a shipment can enter Brazil at all, independent of any tariff line. None of them appears in the EU-Mercosur agreement.

ANVISA, the health regulatory agency, sorts products into two tracks depending on risk class: registro, a full registration process, or notificação, a lighter process for lower-risk categories. Which track applies, and what it requires, is set out in the agency's own resolutions: RDC 907/2024 for cosmetics, personal hygiene products and perfumery, and RDC 843/2024 with IN 281/2024 for food. The agreement does not touch either regulation and contains no provision that substitutes for either track.

MAPA, the agriculture ministry, requires foreign establishments that export wine or animal-origin products to Brazil to be registered before their products can be imported. The ministry's own guidance on beverage and wine imports is explicit about the scope: the requirement, in its own words, "não discute acordos comerciais... aplica-se universalmente a todas as importações comerciais" (it does not depend on trade agreements, and it applies universally to all commercial imports). A tariff preference does not create an exception to that.

INMETRO runs compulsory certification through the PAC. Whether a product needs INMETRO certification is tied to its NCM code, the same code the customs system uses to classify goods for duty purposes, not to where the product comes from. A European exporter and a domestic Brazilian producer selling under the same NCM code face the same certification requirement.

System	Governs	Trigger	Changed by EU-Mercosur
ANVISA	Health-regulated products: cosmetics, food, supplements, sanitizers, medical devices and similar categories	Registro or notificação, set by risk class under RDC 907/2024 for cosmetics, RDC 843/2024 for food	No
MAPA	Wine and animal-origin products	Foreign establishment registration, required for all commercial imports regardless of trade agreement	No
INMETRO	Products on the compulsory certification list	Tied to the NCM code of the product, through the PAC	No

There is a structural reason none of this was ever likely to change, and it sits in the text of the agreement itself, not in an interpretation of it. The TBT (technical barriers to trade) chapter of EU-Mercosur contains exactly one product-specific annex: automotive. There is no cosmetics annex, no good manufacturing practice annex, and no mutual recognition annex for any other sector. In its own Q&A material, the European Commission describes regulatory cooperation under the agreement as taking place "on a voluntary basis", not as a binding harmonisation commitment. A voluntary cooperation clause with no product annex cannot, on its own, override or replace a national registration requirement. If EU-Mercosur had set out to change ANVISA, MAPA or INMETRO procedures, that intention would show up as an annex or a binding obligation. It does not show up, because it is not there.

Labelling still has to be in Portuguese

Product labelling for the Brazilian market is governed by RDC 81/2008, and it has nothing to do with tariffs. The regulation states plainly that "será vedada a entrega ao consumo de produtos importados com identificação ou rotulagem em idioma estrangeiro" (the release for consumption of imported products identified or labelled in a foreign language is prohibited).

That requirement applies to a product regardless of its country of origin, its tariff category, or whether it benefits from any preference under EU-Mercosur. An exporter whose product needed Portuguese-language labelling before the agreement needs the same labelling after it. A lower duty does not create a labelling exemption, and nothing in the agreement text purports to grant one.

In practice this means the label itself is part of the compliance file, alongside the customs declaration. Ingredient lists, warnings, net content, importer identification and any mandatory disclosures have to appear in Portuguese before the goods can be released for sale, on a track that runs independently of the tax calculation described above.

The importer still needs RADAR, and often an import licence

Before any of the tax or regulatory questions above become relevant, the Brazilian importer of record has to be accredited in RADAR, the customs system that authorises a company to operate in Siscomex and file import declarations. RADAR accreditation is a separate administrative process from both the tariff schedule and the ANVISA, MAPA or INMETRO registrations described above. EU-Mercosur does not create, remove or simplify it. The accreditation itself is governed by Instrução Normativa RFB nº 1.984/2020, and it applies regardless of where the goods come from.)

Depending on the product, the shipment may also need an import licence, checked before shipment or before customs clearance depending on the licensing regime attached to the NCM code. Products subject to ANVISA registro, MAPA registration or INMETRO certification typically also carry a licensing requirement tied to those approvals, because the licence is where the customs system confirms that the underlying regulatory approval exists. A tariff preference under EU-Mercosur has no bearing on whether a licence is required, and none on how it is processed.

For an exporter used to EU customs procedures, the practical point is that RADAR and any required import licence sit with the Brazilian importer of record, not with the exporter, and both are administrative gates that exist independently of the duty rate on the product.

What this means for your launch timeline

Treat the duty rate as a single line in a cost spreadsheet. It affects margin and price, and the size of the effect depends on the tariff category, the base rate, and how far into the staging schedule a given shipment falls. It has no bearing on when the product can legally reach the Brazilian market.

The registrations are the calendar. ANVISA registro or notificação, MAPA establishment registration where it applies, INMETRO certification where the NCM code requires it, RADAR accreditation for the importer, Portuguese-language labelling, and any import licence: these are the steps that set the earliest possible launch date, and none of them moves faster because a duty rate fell. A company that sequences its market entry around the tariff schedule, rather than around the regulatory file, risks finding that the product is priced correctly and still cannot be sold.

This page does not state how long any of these approvals take. Processing time is not a fixed number, and any duration published as fixed would be wrong the moment a specific agency or product category made it so. What is fixed is the sequence: the regulatory file has to close before the tariff line matters at all.

Sources

• Portal Único Siscomex, tax simulator (II, IPI, PIS, COFINS by NCM code), queried 7 September 2026.
• ANVISA registro versus notificação classification: RDC 907/2024 for cosmetics, personal hygiene products and perfumery, in force since 23 September 2024 and replacing RDC 752/2022; RDC 843/2024 with IN 281/2024 for food, in force since 1 September 2024 and replacing RDC 27/2010. Checked 7 September 2026.
• gov.br/agricultura, MAPA guidance on beverage and wine imports. Checked 7 September 2026.
• RDC 81/2008, ANVISA, foreign-language labelling prohibition. Checked 7 September 2026.
• Lei 10.865/2004, art. 8, including the perfumery and cosmetics single-stage regime added by Lei 13.137/2015 (PIS/COFINS-Importação rates). Checked 7 September 2026.
• RICMS/SP, Decreto 45.490/2000, art. 52 and art. 55 (São Paulo ICMS standard and supérfluos rates). Checked 7 September 2026.
• Lei 10.253/2023 and Lei 2.657/1996, art. 14, VII, with LC 210/2023 (Rio de Janeiro ICMS standard and supérfluos rates plus FECP). Checked 7 September 2026.
• Ministério de Portos e Aeroportos (gov.br), AFRMM rates; legal basis Decreto-Lei 2.404/1987. Checked 7 September 2026.
• Portaria ME 4.131/2021, Siscomex declaration fee, with IN RFB 2.024/2021 as secondary confirmation only. Checked 7 September 2026.
• European Commission, EU-Mercosur Q&A material on regulatory cooperation and the TBT chapter's annex structure. Checked 7 September 2026.

Tax rates and the customs simulator figures on this page were verified on 7 September 2026. Brazilian tax and regulatory rules change; confirm current rates and requirements before pricing or scheduling a shipment.