Brazilian Federal Revenue Service Normative Instruction No. 2,326, of May 20, 2026, introduced significant changes to Normative Instruction No. 2,090/2022, which regulates the declaration and control of the customs value of goods imported into Brazil. The main objective of the update was to incorporate new understandings and technical instruments issued by the Technical Committee on Customs Valuation (CTVA) of the World Customs Organization (WCO), aligning Brazilian practice with international customs valuation standards.

Among the main changes, the inclusion of Explanatory Note 7.1 and Advisory Opinions 26.1 and 27.1 to the Single Annex of IN No. 2,090/2022 stands out. These documents complement the technical guidelines on the application of valuation methods foreseen in the GATT/WTO Customs Valuation Agreement, especially in situations involving price formation, indirect payments, royalties, linkage between the parties and elements that may impact the transaction value declared by the importer.

Furthermore, the amendment to Article 29 of IN No. 2,090/2022 expressly reinforces the use of the CTVA Explanatory Notes as interpretative instruments applicable by customs authorities. In practice, this tends to increase legal certainty and uniformity in the interpretation of valuation criteria, but also increases the level of technical requirements for importers and foreign trade operators.

The update has a direct impact on companies that carry out imports with related parties, royalty transactions, complex international contracts, or differentiated pricing structures. This is because the Federal Revenue Service now has even more robust technical foundations for analyzing potential under-invoicing, customs value adjustments, and compatibility between the declared price and the actual conditions of the transaction.

From a practical standpoint, IN No. 2,326/2026 reinforces the need for:

• Detailed documentation of pricing strategies;
• Consistency between international contracts, invoices, and customs declarations;
• Review of transactions between related companies;
• Pay attention to indirect payments and royalties linked to imports;
• Strengthening customs governance and document compliance.

The trend is towards increasingly technical and integrated oversight, especially in the context of the modernization of Brazilian foreign trade and the new import process, where data consistency and traceability of operations are becoming central.

Source: Anvisa, Legis Web