Customs Clearance on Water: Brazil Drops the AEO Requirement

On March 16, 2026, Siscomex Import Notice No. 18/2026 opened customs clearance on water to every import operation filed through Brazil’s DUIMP (Declaração Única de Importação, the country’s new single import declaration). AEO certification is no longer required. Before this notice, only companies enrolled in the Authorized Economic Operator program could file while the vessel was still sailing. Now any DUIMP-based import can be declared and risk-assessed in transit. For freight forwarding ops teams in Brazil, the work sequence shifts: what used to begin after discharge can begin days before the vessel berths.

Customs clearance on water moves risk assessment ahead of discharge

In conventional clearance, each step waits for the one before it. The vessel berths, the terminal discharges the cargo and registers the arrival notice (presença de carga), the customs broker files the import declaration, and the Receita Federal (Brazil’s federal tax and customs authority) assigns one of four inspection channels: green, yellow, red, or gray. The gap between discharge and cargo release is where demurrage, detention, and bonded warehouse fees pile up.

Clearance on water breaks that sequence. The customs broker files the DUIMP while the vessel is still sailing. The Receita Federal receives the declaration, runs risk analysis, and assigns a channel before the cargo reaches the quay. A green channel means clearance can close on the day of discharge, because the documentary review already happened during the voyage. Three to five business days between discharge and release can shrink to hours.

The idea is simple: use sailing time for documentary and regulatory work so the cargo is not sitting at the terminal generating storage costs while paperwork catches up.

Before the expansion, only AEO-certified importers had access

Clearance on water already existed in Brazilian trade, but only for a small group. The AEO program, regulated by Normative Instruction RFB No. 1,985/2020, offered it to importers certified at the Silver, Gold, and, more recently, Reference levels. The intent was to give companies with strong customs compliance a faster path through the port.

AEO certification, though, demands compliance infrastructure, internal controls, and recurring audits that most mid-sized importers cannot justify. The majority of shipments a Brazilian freight forwarder handles come from importers without AEO status. So clearance on water was on the books, but almost nobody used it. Declarations kept getting filed after discharge.

Siscomex Notice No. 18/2026 changed the eligibility test. Instead of requiring AEO certification, it requires only that the operation be filed through DUIMP. As the migration from the legacy DI (Declaração de Importação) to DUIMP continues through 2026, with full DI shutdown expected by year-end, the number of eligible operations grows with every batch of HS codes that enters the new process.

The operational gain is in the days between berthing and release

Import costs grow by the day. Bonded warehouse fees at Santos, Paranaguá, or Itajaí are charged per period, with progressive tiers that jump every five or ten days. Container demurrage kicks in when the carrier’s free time expires, and free time starts at discharge. Detention starts when the container leaves the terminal.

None of this is news to ops teams. Clearance on water cuts the gap between discharge and pickup. If risk assessment runs during the voyage and returns a green channel, clearance closes as soon as the terminal registers the cargo arrival. The cargo can be picked up the same day or the day after discharge.

Under the conventional flow, that gap runs three to five business days for shipments with no pending issues, covering declaration filing, risk assessment, and Receita Federal review. System congestion or high port volume stretches it further. Releasing cargo on day one versus day five can mean an extra storage tier and demurrage charges the importer did not budget for.

For the freight forwarder’s ops team, clearance on water turns a reactive task into a plannable one. The operator checks the vessel’s ETA, works backward to figure out when documentation must be ready, and schedules the DUIMP filing with the customs broker.

Documentation must be ready before the vessel arrives

Clearance on water pulls the documentary effort forward, before discharge. Every document the customs broker needs for the DUIMP must be complete, verified, and in hand while the vessel is still sailing.

The freight forwarder’s ops team needs all of this resolved before filing: the final commercial invoice with correct value, HS code (NCM), quantity, and Incoterm; the packing list cross-checked against the invoice; the carrier’s bill of lading issued, with consignee, notify party, container, weight, and volume matching the other documents; the CE Mercante (Brazil’s cargo manifest registration) filed in Siscomex Carga, linking the cargo to the bill of lading; and, when the HS code requires it, the import license (LI or LPCO) approved by the relevant regulatory agency, whether ANVISA, MAPA, Inmetro, or another body.

If any of these arrive incomplete or inconsistent, the DUIMP either cannot be filed or goes in with errors that require amendment. Amending a declaration that is already in the system and already under Receita Federal review restarts part of the analysis, which defeats the purpose. Among freight forwarders in Brazil, the most common bottleneck is the final commercial invoice. Many exporters send a proforma before shipment and only issue the commercial invoice afterward. If the operator waits for that invoice to arrive by email, the filing window can close before the vessel berths.

The fix is straightforward: request the final invoice from the shipper or overseas agent earlier. When the operator includes this in the pre-alert, asking for the commercial invoice alongside the B/L copy, the document arrives in time to verify and forward to the customs broker before berthing.

Red channel on water still requires physical inspection after discharge

Filing on water does not eliminate the possibility of a red channel. The Receita Federal applies the same risk criteria whether the declaration was filed before or after discharge. If the shipment draws a red channel, the physical inspection only happens after the cargo arrives at the terminal and is available for examination.

The time savings in that case are partial. The documentary review that accompanies physical inspection in the red channel will have been completed or at least advanced during the voyage. When the inspector schedules the examination, the documents are already reviewed and the focus is on the cargo itself. Total clearance time still comes in shorter than the conventional flow because part of the work was done at sea.

Yellow channel, which requires only documentary review, benefits more. The document examination runs on water, and by the time the cargo arrives, clearance is already well advanced or finished.

Ops teams should set expectations with the importer accordingly. Same-day release at discharge applies to the green channel. Other channels still benefit from earlier filing, but final clearance depends on steps that can only happen once the cargo is at the terminal.

Frequently Asked Questions

What is customs clearance on water in Brazilian imports?

It is the procedure where the import declaration (DUIMP) is filed and risk-assessed by Brazil’s Receita Federal while the vessel is still sailing to the destination port. By running customs analysis before discharge, the time between cargo arrival and release at the terminal gets shorter.

Do I need AEO certification to use customs clearance on water?

No. Since March 2026, under Siscomex Import Notice No. 18/2026, any operation filed through DUIMP can use clearance on water. AEO certification is no longer a prerequisite. Before this change, only AEO-certified importers had access.

Does customs clearance on water guarantee a green channel?

No. The channel depends on the Receita Federal’s risk analysis and the data in the declaration. Filing the DUIMP early does not change which channel the shipment gets. The advantage is that if it comes back green, release can happen the same day as discharge because the review was already finished during the voyage.

How Tier2 Cargo tracks the process before the vessel berths

Tier2 Cargo’s import workflow includes milestones that track each stage from booking to settlement. The operator records the vessel’s ETA, which documents have been received, and when the DUIMP was filed. When the customs broker reports the risk assessment result, that milestone gets updated, so the operator can see whether the shipment was assessed on water or still needs action after discharge.

This lets the operator work each shipment based on where it actually stands. Green channel shipments assessed on water go into the pickup queue as soon as the terminal registers the cargo arrival. Yellow or red channel shipments get early attention so supplementary documentation is ready when the inspector asks for it.

Learn about Tier2 Cargo or get in touch.

Making clearance on water routine instead of exceptional takes two things: a document collection process that works before the vessel berths, and a system that shows where each shipment sits in this flow. The first comes down to pre-alert discipline with the overseas agent. The second requires a freight forwarding system that treats customs clearance as part of the process, with the right fields and milestones to track what happens before, during, and after discharge.