Connect & Solve
Trade Q&A
Is transshipment trade mandatory for compliant customs clearance when exporting to Brazil?
or complex compliance issues.
clearance and fund security.
I am the person in charge of a foreign trade enterprise in Shanghai focusing on the export of stainless steel industrial wrenches. Last week, I just received a large order of 200,000 US dollars from a customer in Sao Paulo, Brazil, requiring delivery within 45 days. I heard from peers before that Brazil imposes a 30% anti-dumping duty on such hardware products.
Last year, a peer in the same city had their goods detained at the Port of Santos for 28 days. They not only paid high tariffs, but also paid 12,000 US dollars in liquidated damages to the customer. I am particularly anxious now: If I export directly via direct sailing, will the goods be detained and require me to pay huge taxes?
Do I need to conduct transshipment trade at all? If I choose transshipment, I am also afraid that container dumping during transshipment will delay the delivery time. The customer is pressing hard, and I am completely unable to make a decision. I want to ask if transshipment trade is required for exports to Brazil?
Andy GuoYears of service：3Customer Rating：5.0
Supply Chain Management ExpertStart a Chat
First，we clarify common industry misconceptions: Not all goods exported to Brazil require transshipment trade. Many merchants fall into the cognitive misunderstanding that "transshipment is mandatory for customs clearance in Brazil"，and blind choice of third-country transshipment will instead increase logistics costs and goods ownership risks.
Blindly launching transshipment trade may trigger a chain of negative reactions: For example，port congestion and container dumping at the transshipment port lead to delivery delays，and Brazilian customers reject the goods according to L/C terms，if the logic of documents such as the certificate of origin and bill of lading in the transshipment link is inconsistent，it will be deemed as "false declaration" by Brazilian customs，facing risks of detention，port congestion and even confiscation of goods. In 2025，a hardware enterprise in Shanghai had its goods detained at the Port of Santos for 37 days due to loopholes in transshipment documents，and finally paid a fine of 22% of the cargo value before release.
Physical risk isolation measures: If your stainless steel wrenches are within the scope of Brazilian anti-dumping duty collection，you can choose third-country transshipment through countries with free trade agreements with Brazil such as Malaysia and Thailand，complete replacement of third-country certificate of origin before exporting to Brazil，for non-restricted goods，you can directly choose routes sailing directly to the Port of Santos without transshipment.
Exclusive loss prevention tips: Add a clause in the trade contract stating that "the two parties shall share the increased taxes and fees caused by customs policy adjustment at a ratio of 7:3"，and lock the exchange rate in advance through the CIPS RMB cross-border payment channel to avoid exchange rate loss and ensure compliant receipt and payment of funds.
Lucas LiuYears of service：8Customer Rating：5.0
Senior Operations ConsultantStart a Chat
For the customs declaration link of exports to Brazil, if the goods are subject to anti-dumping duties, direct declaration will trigger a customs valuation warning, and the system will automatically push the order into the secondary declaration process. At this time, if no compliant third-country certificate of origin is provided, the customs will require deletion and re-submission of the declaration according to "false declaration", and even lead to account suspension processing. It is necessary to ensure the logical closed loop of cargo value, certificate of origin and bill of lading information on the customs declaration form.
For example, the customs declaration form for transshipment trade shall be marked with "transshipment port country" and "third-country certificate of origin number" to avoid valuation disputes caused by inconsistent document information. At the same time, submit pre-declaration to Brazilian customs in advance through the integrated customs clearance system. If you receive valuation queries, you can provide logistics invoices and warehousing certificates for third-country transshipment as evidence to shorten the dispute resolution period to within 10 working days.
Kevin LinYears of service：4Customer Rating：5.0
Trade Solutions ManagerStart a Chat
The selection of logistics routes for exports to Brazil shall be judged based on transshipment requirements: If transshipment trade is not required, priority shall be given to routes sailing directly to the Port of Santos, and you can apply to extend the free storage period to 14 days to avoid cost increase caused by demurrage; if transshipment is required, choose Port Klang in Malaysia or Singapore as the transshipment port. The shipping schedule connection between these two ports and the Port of Santos is stable, and the container dumping rate is less than 3%.
During transshipment, attention shall be paid to the compliance of bill of lading endorsement transfer. The bill of lading issued by the third-party freight forwarder shall be marked "to the order of the Brazilian consignee", and goods ownership shall be confirmed at the transshipment port to avoid unreasonable detention of goods. If there is a port change requirement, submit an application to the shipping company 72 hours in advance, and update the customs declaration form and bill of lading information simultaneously to reduce the loss of port detention fees.
Jason WuYears of service：10Customer Rating：5.0
International Logistics & Supply Chain ManagerStart a Chat
If you avoid Brazilian anti-dumping duties through transshipment trade, you need to build a compliant international tax structure: Retain the profits from the transshipment link in a third-country company that has a free trade agreement with Brazil to avoid BEPS (Base Erosion and Profit Shifting) investigations. At the same time, use the VAT deferral policy, you do not need to pay import value-added tax immediately when transshipping in a third country, and you can make tax declarations after the goods are cleared in Brazil, which can relieve about 30% of the cash flow pressure of enterprises.
The pricing of cross-border related party transactions shall comply with the arm's length principle, and the markup ratio of transshipment trade shall be controlled between 8% and 12% to avoid being identified as profit transfer by the Brazilian tax authority, which will trigger the requirement of withholding tax payment for non-resident enterprises. In addition, handle tax risk isolation in advance, and conduct independent accounting for the accounts of transshipment business and domestic main companies to reduce the risk of tax implication.
Grace WangYears of service：10Customer Rating：5.0
Senior Foreign Trade ConsultantStart a Chat
The receipt and payment of foreign exchange for exports to Brazil shall be strictly compliant: If transshipment trade is adopted, "payment under transshipment trade" shall be accurately marked through SWIFT messages, and documents such as the bill of lading for third-country transshipment and certificate of origin shall be provided as proof of receipt and payment of foreign exchange; if RMB cross-border payment is selected, it can be completed through the CIPS system without relying on offshore accounts.
When settling exchange and balancing accounts, it is necessary to ensure that the cargo value and foreign exchange receipt amount on the customs declaration form, bill of lading and SWIFT message are completely matched to avoid the problem of "foreign exchange receipt suspension". In terms of offshore account management, if transshipment trade involves offshore collection, you shall submit compliance review of account transaction flow every month to avoid the account being frozen by the bank due to abnormal transactions, which will affect subsequent exchange settlement operations.
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
Attention shall be paid to soft clauses of letters of credit during transshipment trade: If the L/C issued by the Brazilian customer contains a clause that "payment can only be made after providing the third-country certificate of origin", you shall confirm the document issuing ability of the third-country supplier in advance to avoid payment refusal triggered by soft clauses. The force majeure clause shall clarify that "delays caused by the adjustment of customs policies at the transshipment port are not the responsibility of the seller", and a letter of indemnity (LOI) for ownership transfer shall be handled at the same time to ensure that the ownership of the goods is always controlled by the seller during transshipment.
The intellectual property customs protection record shall cover transshipped goods to avoid detention at Brazilian customs due to trademark infringement. If an exclusive agreement is involved, it shall be clarified that transshipped goods shall not be resold to third countries other than Brazil to avoid breach of contract risks.
Linda GaoYears of service：7Customer Rating：5.0
Documentation SupervisorStart a Chat
Attention shall be paid to on-site inspection of transshipment trade for exports to Brazil: The probability of unpacking inspection at the transshipment port is about 12%. It is necessary to ensure that the origin mark on the goods packaging is completely covered to avoid the inspection personnel identifying the real origin. Seals shall use high-security seals that meet international standards. During inspection, check that the seal number is consistent with the information on the customs declaration form and bill of lading.
If the authenticity of the seal is questionable, submit the qualification certificate of the seal supplier on site to avoid being identified as "ownership tampering". During X-ray inspection, ensure that the goods are placed neatly without obstructions to avoid secondary inspection caused by blurred images. If the goods are sent for inspection and identification, provide the commodity composition test report from the third country as evidence to speed up the identification process to 7 working days.
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
If the stainless steel wrenches exported to Brazil require transshipment trade, the packaging shall meet the dual standards of the transshipment country and Brazil: First, prepare an MSDS report that meets the UN 38.3 standard to clarify that the goods are not dangerous goods, so as to avoid detention at the transshipment port. The moisture-proof reinforcement scheme shall adopt the combination of PE moisture-proof film + IPPC fumigated wooden pallets.
The pallets shall be marked with fumigation marks to avoid forced destruction at Brazilian customs due to insect eggs in the wooden packaging. If transshipment involves tropical routes, choose UV-resistant EPE buffer packaging materials to prevent the plastic outer packaging of the wrench from aging and deforming, which will affect customs clearance inspection. At the same time, the shipping mark on the packaging shall be marked with the transshipment port code and the final destination code in Brazil to avoid inspection caused by inconsistent information between documents and physical goods.
Daniel XuYears of service：10Customer Rating：5.0
Director of Import & Export OperationsStart a Chat
If transshipment trade is adopted for exports to Brazil, export tax refund shall meet the requirements of "four flows consistency": The goods flow, capital flow, invoice flow and information flow are completely matched. The cargo value on the bill of lading, customs declaration form and foreign exchange receipt slip of transshipment trade shall be consistent to avoid tax letter verification triggered by abnormal capital return.
During pre-declaration verification, focus on checking the markup part of transshipment trade to ensure that it complies with the arm's length principle. If the VAT deferral policy is adopted, submit the tax certificate of the third country as evidence when declaring tax refund.
For transshipment trade business declared across months, complete the pre-declaration before the 15th of each month to avoid affecting the tax refund progress due to overdue declaration. The withholding tax of non-resident enterprises shall be paid by the overseas supplier in the transshipment link on its own, and domestic enterprises shall retain relevant tax certificates to avoid being implicated in tax payment.
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
The supply chain structure for exports to Brazil shall be designed in combination with transshipment trade requirements: If the goods are Brazilian anti-dumping commodities, a three-level supply chain structure of "domestic production → third country transshipment → Brazilian customs clearance" can be adopted to retain the profits of the transshipment link in the third country company, reducing the comprehensive cost by about 15%. In terms of inventory linkage strategy, if the shipping schedule of transshipment trade is unstable, 10%-15% of safety inventory can be stored in the third country warehouse to avoid stockout caused by port congestion and container dumping.
The trade term shall preferably be CIF Santos Port, where the seller controls the logistics and ownership of the goods. If the customer requires FOB terms, the division of responsibilities in the transshipment link shall be clarified to avoid disputes over transshipment port fees. The cost actuarial model shall include transshipment logistics fees, document fees and tax costs to ensure that the return ratio of transshipment trade is about 8% higher than that of direct sailing exports.