Import licensing in Brazil: LI automatica, LI nao automatica and the shift to LPCO

The short answer

Import licensing runs on Portaria SECEX nº 249, of 4 July 2023, read in the consolidated text (Texto Compilado) published on the Siscomex site. Article 3 splits licensing into two tracks.

Licenciamento automático is granted once the formal requirements are met and the form is filled in completely. No agency forms a view on whether the shipment should go ahead. Article 11 sets the reference period at 10 days.

Licenciamento não automático goes to an anuente, a government body with authority over that class of goods, and the licence issues only after that body has reviewed the request. Article 12 sets the reference period at 60 days.

The useful question about any product, then, is not whether a licence is needed. It is which track the product sits on. A company that assumes the automatic track and turns out to be on the other one has lost roughly two months of its shipping calendar, and that discovery tends to arrive late, once the goods are already booked.

Automatic does not mean invisible either. The automatic track is conditional on the formal requirements being met and the form being completed in full, the licence has a fixed validity, and the agencies behind the non-automatic track run product level regimes of their own. ANVISA and MAPA both appear on the official anuente list, and each also runs a product level regime of its own, covered separately, covered here: ANVISA registration and MAPA registration.

Automática and não automática side by side

	LI automática	LI não automática
Basis in the act	Portaria SECEX 249/2023, article 3, I	Portaria SECEX 249/2023, article 3, II
Who decides	Issued on formal compliance, no review of the merits	An anuente body reviews the request first
Reference period	10 days (article 11)	60 days (article 12)

Both figures are the periods written into the act. Neither is a promise about how any individual filing will move. Licence validity is a separate question from either period, and article 15 sets it at 180 days, covered below.

When a non-automatic licence is required

Portaria SECEX 249/2023 does not draw the boundary by product family. It draws it by situation, and the situations it names are these.

Situation	Where it sits in the act
Goods subject to tariff or non-tariff quotas	Portaria SECEX 249/2023
Assessment of national similarity (similaridade nacional)	Article 26
Used goods	Articles 29 to 34
Restrictions flowing from UN Security Council measures	Portaria SECEX 249/2023
Suspicion of a breach of foreign trade legislation	Article 43

Two of these catch companies that were not expecting them. Used goods have a block of the act to themselves, articles 29 to 34, so a second hand production line bought as ordinary capital equipment falls under a chapter of its own rather than under the general rule. And article 43 turns on a suspicion of a breach of foreign trade legislation, which is a fact about the operation rather than about the goods.

How long a licence lasts, and the shipment that left before the rule changed

Article 15 sets the validity of an import licence at 180 days.

The act also contemplates licensing after the goods have shipped, but narrowly. Article 6 §3 together with article 15 §1 allows it in exceptional cases where the goods were shipped before a new licensing requirement came into force, with the bill of lading serving as evidence of the shipping date. The drafting is tied to that one situation, a rule change catching a cargo already at sea, and the act frames it as exceptional rather than as a general route for a licence that was simply not obtained in time.

The anuente bodies

An anuente is the government body whose consent, anuência, the non-automatic track requires. The official list published on the government's invest and export portal names 15 of them.

Body	Area named on the official list
ANVISA	Sanitary and health control
MAPA	Agricultural products
INMETRO	Metrology and certification
IBAMA	Environmental control
Comando do Exército	Area not recorded in the source used here
DPF (Federal Police)	Area not recorded in the source used here
ANEEL	Area not recorded in the source used here
ANCINE	Area not recorded in the source used here
DECEX	Area not recorded in the source used here
DNPM	Area not recorded in the source used here
ANP	Area not recorded in the source used here
CNPq	Area not recorded in the source used here
EBC / Correios	Area not recorded in the source used here
MCT	Area not recorded in the source used here
SUFRAMA	Area not recorded in the source used here

That page carries a publication date of 11 July 2022. It is the official list, and it is also four years old at the time of writing, which is long enough for a list of government bodies to drift out of date.

One gap is visible on its face. ANATEL is commonly named in the market as the anuente for telecommunications equipment, and it does not appear on this list. This page does not state that ANATEL is or is not an anuente, because the official source available does not say so either. What the gap does establish is a working method: confirm anuência against the specific NCM classification of the goods in Siscomex, rather than against any published list of agencies, this one included. A list tells you which agencies exist. It does not tell you whether your tariff code carries a consent requirement, and only the second answer is the one that stops a container.

When cargo arrives without the licence it needed

The consequence sitting behind the licensing rules is pena de perdimento, forfeiture of the goods. A legal commentary on customs forfeiture cites article 689, XVI of the Regulamento Aduaneiro, Decreto 6.759/2009, covering goods imported without an import licence or equivalent document where issuing that document was prohibited or suspended. The same commentary points to article 700, under which forfeiture as a customs administrative penalty applies only in cases the law expressly provides for.

That citation comes from a secondary legal source. The text of Decreto 6.759/2009 was not checked directly against the official gazette while preparing this page, so treat the article numbers as an indication of where the provision sits rather than as a verified quotation. The point that matters commercially survives the caveat in any case: the downside of a missing licence is measured against the value of the goods, not against a fee schedule.

From DI to DUIMP, and from LI to LPCO

DUIMP is not yet universal. The old declaration, DI, and DUIMP coexist while DI is switched off in stages, and the official schedule for that shutdown lives on a Siscomex page that is actively maintained: it was last updated on 26 August 2026, carries version number 26, and has a version history going back to 7 October 2025.

Two dates on that schedule are worth holding.

Date	Stage
11 October 2026	Maritime bulk and liquid bulk cargo (marítimo granel)
1 December 2026	Government bodies plus special and edge cases, 13 documented scenarios

The 13 scenarios in the final stage include operations with more than one anuente body, operations under multiple tax regimes, cases with a previously registered LI, individual importers, and operations involving an encomendante or an adquirente.

Both dates are a plan as published on 26 August 2026, not a guarantee. A page on version 26 with a revision history running back a year is a page that has moved before. This is also why any statement about who can or must use DUIMP right now dates quickly. Rather than working from a general description of the conditions, check the current shutdown schedule for the specific channel a shipment uses.

What the transition changes, in outline: a single declaration replaces the LI plus DI pairing, more data is registered in advance through Portal Único before the cargo arrives, and LI is progressively replaced by LPCO. The direction is confirmed by the official schedule. The operational detail comes from commercial guides rather than from the acts themselves.

One of those details is worth flagging precisely because it is attractive. A commercial guide describes LPCO as an umbrella licence, one LPCO covering several DUIMP declarations instead of one LI per operation. That would be a real simplification for anyone shipping the same goods repeatedly. It has not been verified here against the text of the relevant Portaria Coana, so treat it as an expected simplification rather than as a feature to plan a supply chain around.

What the transition does not change is the accreditation underneath it. Habilitação no Siscomex, the RADAR licence, stays mandatory regardless of whether a given operation runs on DI or DUIMP. Nothing in the official shutdown material touches accreditation; this is an inference from IN RFB 1.984/2020 remaining in force, not a quoted statement. The move changes the declaration format and the process around it, not who is allowed to be the declarant in the first place. That subject has its own page: RADAR and Siscomex accreditation.

Does the EU-Mercosur agreement change this?

No. A customs law analysis of the agreement published on 17 March 2026 addresses its customs effects and does not touch import licensing: LI procedure, the anuência requirement and the roles of ANVISA, MAPA, INMETRO and IBAMA all remain matters of national regulation. The same analysis finds no effect on Siscomex accreditation or on the import modalities.

The source is a legal analysis rather than the text of the agreement itself, and the customs chapters were not read line by line for this page, so the finding is reliable at the level of professional commentary rather than at the level of a primary citation.

What the agreement does change sits on the tariff side: staged tariff elimination, preferential rules of origin with bilateral cumulation, and self-certification of origin. Those are covered separately, along with the list of things that stay exactly as they were: The EU-Mercosur agreement and what the agreement does not change.

What to check before you ship

The confirmed material on this page reduces to a short set of checks.

Confirm which track the goods sit on before the shipping date is fixed, since article 11 and article 12 set 10 days and 60 days respectively and the difference is not recoverable later.

Check the five situational triggers named in Portaria SECEX 249/2023: quotas, national similarity under article 26, used goods under articles 29 to 34, United Nations Security Council restrictions, and article 43, which attaches to a suspected breach rather than to the goods.

Verify anuência against the NCM classification in Siscomex rather than against a published list of agencies, given that the official list available is dated 11 July 2022.

Count the 180 days set by article 15, and treat article 6 §3 and article 15 §1 as covering one narrow case, a cargo shipped before a new licensing requirement took effect, evidenced by the bill of lading.

Read the DI shutdown schedule on the Siscomex site for the specific channel and cargo type in question, and re read it before each planning cycle, given the 11 October 2026 and 1 December 2026 stages and the page's revision history.

Keep RADAR accreditation and tax treatment on a separate track from licensing. They interact with it, but they are not the same filing, and import taxes work on their own rules.

Sources

• Licensing tracks, reference periods, triggers for the non-automatic track and licence validity: Portaria SECEX nº 249, of 4 July 2023, Texto Compilado, PDF published on gov.br/siscomex; articles 3, 6 §3, 11, 12, 15, 26, 29 to 34 and 43. Primary source.
• The 15 anuente bodies: gov.br invest and export portal, page "Órgãos Anuentes", published 11 July 2022. Official but dated. ANATEL does not appear on it and is not asserted here as an anuente.
• Pena de perdimento, Decreto 6.759/2009 articles 689 XVI and 700: a published legal commentary on customs forfeiture, secondary source. The decree text was not checked directly against the official gazette while preparing this page.
• DI shutdown stages of 11 October 2026 and 1 December 2026, the 13 edge case scenarios, and the coexistence of DI and DUIMP: gov.br/siscomex, "Cronograma de Desligamento da DI", page updated 26 August 2026, version 26, revision history from 7 October 2025. Primary source, and a plan rather than a commitment.
• LPCO as an umbrella licence covering several DUIMP declarations: a commercial customs guide, secondary source, not verified against the relevant Portaria Coana. Presented here as an expected simplification only.
• EU-Mercosur having no effect on licensing, anuência or accreditation: a customs law analysis published 17 March 2026, secondary source. The agreement text was not read directly for this page.

Facts on this page were checked on 7 September 2026. The DI shutdown schedule in particular is a live document that has been revised repeatedly, and the anuente list cited is from 2022. Check the current text of Portaria SECEX 249/2023 and the current Siscomex schedule before relying on any date or period given here.