DUIMP Product Catalog: Where Compliance Begins

Since April 27, 2026, every maritime or air import into Brazil involving products under regulatory agency controls (ANVISA, MAPA, Inmetro, and others) must be filed as a DUIMP (Declaração Única de Importação, Brazil’s single import declaration) through the Portal Único Siscomex. The legacy DI (Declaração de Importação) still works for other transport modes until December, but the DI is going away. It is being phased out by waves of HS code (NCM in Brazil’s Mercosur nomenclature), and the official schedule from Brazil’s Federal Revenue Service targets the end of 2026 for the remaining transport modes.

During the migration, many importers and customs brokers found that the DUIMP depends on something the DI never required: the Product Catalog (Catálogo de Produtos). Without a product registered and approved in the catalog, linked to the importer’s tax ID, the system rejects the declaration outright. If your catalog is not ready, customs clearance does not start.

The DUIMP does not start without an approved catalog entry

Under the DI, the importer typed product data directly into the declaration, shipment by shipment. Every import meant re-entering the same fields: HS code, product description, position-specific attributes, manufacturer and exporter data. The Product Catalog works differently. The importer registers each product once, with the technical and commercial information its HS code position requires, and that entry stays available for all future DUIMPs. The declaration pulls data from the catalog. The operator picks the product and fills in the shipment-specific fields.

Once everything is registered, the workflow is simpler. The hard part is getting there. An importer with two hundred products must register all of them before filing the first DUIMP for each one. The registration demands precision, too: each HS code position has its own set of attributes, defined by the Federal Revenue Service, that must match the actual product.

A customs broker handling this knows that the catalog pushes upfront a verification effort the DI used to spread across many shipments. If the HS code was wrong on a DI, the problem stayed in that one declaration. If the HS code is wrong in the catalog, the mistake carries into every DUIMP that references that product.

What the catalog requires: HS code, attributes, and foreign operator

Registering a product in the Portal Único catalog involves three elements the customs broker must get right.

HS code classification. Brazil’s NCM (Nomenclatura Comum do Mercosul) controls which attributes the system asks for and which regulatory agencies get involved. A wrong HS code causes two problems at once: the attributes the system presents do not match the actual product, and the administrative treatment (requirements from ANVISA, MAPA, Inmetro, or another agency) may be wrong. Since February 2026, the NCM table has gone through two rounds of updates: thirteen new codes were added, five were removed, and six had their descriptions changed. On October 1, 2026, additional codes take effect. Anyone with a catalog of hundreds of products should check whether any registered code has changed.

NCM-specific attributes. Each position in the nomenclature may require specific information: composition, dimensions, capacity, application, packaging type. These attributes are defined by the Portal Único Product Catalog, and the Federal Revenue Service can update them without much notice. The customs broker registering the product needs to actually know the product. The system accepts any value in the field, but risk assessment during customs selection compares what was declared against what inspectors find.

Foreign operator. Each product in the catalog must be linked to the overseas manufacturer or exporter, identified by name, country, and, when available, tax identification number. The system cross-references this with customs valuation treatment and mutual recognition agreements. A product registered with the wrong operator may get a different administrative treatment than expected.

Catalog errors surface during customs selection

As we covered in our post on customs selection under the DUIMP depends on the data, the Product Catalog is the source of much of the data that drives channel assignment. An incorrect HS code, a generic attribute value, a foreign operator that does not match the commercial invoice: these are the kinds of signals the Federal Revenue Service’s risk management system picks up.

The DUIMP inspection channel (green, yellow, red, or grey) considers the importer’s history, the origin of the goods, the tariff classification, and how consistent the declared data is. The catalog feeds three of those four variables. A product registered in a rush, with vague attributes or an approximate HS code, raises the odds of landing in a yellow or red channel.

In documentary inspection (yellow channel), the officer compares the DUIMP data against supporting documents: commercial invoice, packing list, certificate of origin, bill of lading. If the catalog says one thing and the invoice says another, the discrepancy needs an explanation. In physical inspection (red channel), customs compares the actual product against the declaration. Generic catalog attributes like “material: miscellaneous” or “application: industrial” draw attention because they do not describe the product in a way anyone can verify.

A poorly built catalog causes rework in two places. In the catalog itself, because the product entry must be corrected for future shipments. And in customs clearance, because the DUIMP already filed must be amended, with all the delays and penalty risk a Siscomex amendment brings.

Maintaining the catalog is ongoing work, and it scales with the portfolio

Building the catalog for the first time is obvious work: importers and customs brokers know they have to register every product before operating under the DUIMP. Keeping the catalog current gets less attention, but over a year it takes more time.

Three situations force catalog updates. New products must be registered from scratch, with HS code, attributes, and foreign operator, before any DUIMP can be filed. HS code changes by the Federal Revenue Service or Mercosur also require review. GECEX Resolution 852/2026 changed duty rates for more than 1,200 products, and the resolutions that create and retire codes require importers to confirm that their existing products are still correctly classified. The third situation is a change of overseas supplier: a new foreign operator must be linked to the product, and the previous entry does not carry over.

For an importer with ten or twenty products, the catalog is manageable with a spreadsheet and a quarterly review. For one operating hundreds of items, with suppliers across multiple countries and HS codes spread across different chapters, the catalog turns into a database that needs governance: who registers, who reviews, who approves, and how often someone checks whether the codes are still valid.

A customs broker serving multiple importers faces this at a larger scale. Each client has its own catalog, each catalog has its own HS codes, and the responsibility for the accuracy of what gets declared in the DUIMP falls on whoever signs. From what we have seen working with freight forwarders in Brazil, catalog maintenance is one of the tasks that has grown the most in customs brokerage since the DUIMP became mandatory.

Frequently Asked Questions

What happens if the product catalog is not approved before filing a DUIMP?

The Portal Único system will not let you file a DUIMP for a product that is not in the importer’s catalog. The filing is blocked until the product is registered and approved. A missing catalog entry delays customs clearance by however long the registration takes to complete and validate.

How can I tell if an HS code in the product catalog has been retired or changed?

The Federal Revenue Service publishes NCM table changes through GECEX (Executive Management Committee) resolutions and technical bulletins for electronic invoicing. Importers need to watch these publications and compare their catalog codes against the current table. Since February 2026, five codes have been retired and thirteen created. The next update takes effect on October 1, 2026.

Does the product catalog replace filling out the DUIMP?

No. The catalog stores fixed product data: HS code, attributes, and foreign operator. The DUIMP still requires shipment-specific information such as customs value, Incoterm, shipment weight, transport data, and clearance details. The catalog saves you from re-entering product data, but each declaration still needs to be completed with the specifics of that import.

How Tier2 Cargo organizes the data that feeds the catalog

The data that goes into the Product Catalog in the Portal Único is the same data freight forwarders and customs brokers already record during the import process: HS code, product description, exporter and manufacturer details, weight, volume, value. In Tier2 Cargo, these fields are part of the workflow from the quote through to settlement. The system keeps partner records (including the foreign operator) and product data linked to each shipment, so you can check consistency between your internal records and what will be declared in Siscomex.

When the freight forwarder uses Autodocs to extract data from commercial invoices and packing lists, the fields come into the process already validated against rules for HS code format, container number (ISO 6346), port (UN/LOCODE), and currency (ISO 4217). The cross-check a customs broker would otherwise do manually between the document and the system happens at extraction, before anyone opens Siscomex.

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If you are building or reviewing a Product Catalog now, a practical first step is to map your products by HS code chapter and check which codes were affected by the 2026 resolutions. Reviewing by chapter is faster than going product by product, and it cuts the risk of filing a DUIMP with a retired code.