The recently published Coana Ordinance No. 115/2023 sets the average dollar exchange rate at R$ 4.6638 for calculating the estimated financial capacity of taxpayers who, in 2023, file administrative proceedings for the purposes of qualification/review of the estimate in the Registration and Tracking of Customs Brokers’ Activities (RADAR) system.
The recently published Coana Ordinance No. 115/2023 sets the average dollar exchange rate at R$ 4.6638 for assessing the estimated financial capacity of taxpayers who, during 2023, submit administrative proceedings for the purpose of qualification or review of the estimate in the Registration and Tracking of Customs Brokers’ Activities (RADAR) system.
RADAR qualification must be obtained before the start of operations and is required for the user to access the SISCOMEX environment, a system that enables the integration of registration, monitoring and control activities for each stage of these operations. To request qualification, the applicant must follow the guidelines and conditions set out in Normative Instruction No. 1,984/2020 and Coana Ordinance No. 72/2020.
The aforementioned regulations provide for the classification of applicants into different categories, depending directly on their operational and financial capacity, which limits the volume of imports permitted. The categories currently in force are:
- Express: intended for publicly traded corporations with shares listed on a stock exchange or over‑the‑counter market, as well as state‑owned companies or mixed‑capital companies, with no limits on the value of imports and exports.
- Limited up to US$ 50,000: for applicants whose financial capacity is estimated at an amount equal to or less than US$ 50,000, allowing semi‑annual imports with a customs value up to this limit, and no limit in the case of exports.
- Limited up to US$ 150,000: for applicants whose financial capacity is estimated at an amount greater than US$ 50,000 and equal to or less than US$ 150,000, allowing semi‑annual imports with a customs value up to this limit, and no limit in the case of exports.
- Unlimited: for applicants whose financial capacity exceeds US$ 150,000, with no limits on imports or exports.
If the operator believes their financial capacity exceeds their current classification—that is, greater than US$ 50,000 or US$ 150,000—they may request an automatic review of their estimate through the Habilita System available on the Siscomex Single Portal or by submitting documents via the opening of an electronic process in the E-CAC environment.
The review via the Habilita System is based on tax payment information available in the database of the Brazilian Federal Revenue Service, and may result in either an increased financial capacity or, depending on the context, a reduction in financial capacity.
In the case of review via electronic process, the request must be accompanied by proof of financial and operational capacity, with the required documents specified in Coana Ordinance No. 72/2020. These documents may vary depending on the possible justifications outlined in the same regulation, such as bank account balances and investments, tax payments, and the use of tax exemptions.
For the conversion and verification of whether the financial capacity exceeds the limits, the declarant must use the average dollar exchange rate. For requests filed in 2023, this rate is set at R$ 4.6638, as established by the aforementioned Coana Ordinance No. 115/2023.
Thus, for the year 2023, the minimum amounts to be demonstrated as financial capacity for classification into higher categories are:
– Limited category up to US$ 150,000.00: R$ 234,000.00
– Unlimited category: R$ 701,000.00
