The Ministry of Development, Industry, Trade and Services (MDIC), through the Secretariat of Foreign Trade (SECEX), has issued SECEX Ordinance No. 418/2025, regulating the introduction of Drawback Services. This new rule amends the existing Drawback Suspension regime (established under SECEX Ordinance No. 44/2020) to extend the tax benefit to service contracts related to exports, moving beyond the traditional focus on inputs and goods acquisition.
The Drawback Suspension is a special customs regime that permits foreign goods to enter Brazil with the suspension of various taxes, provided those inputs are used in the manufacture of a domestic product destined for export. The suspended taxes include the federal Import Duty (II), Excise Tax on Industrialized Products (IPI), Social Integration Program (PIS), Social Security Financing Contribution (Cofins), and the Additional Freight for the Merchant Marine Renewal Fee (AFRMM), alongside the state Value-Added Tax on the Circulation of Goods and Services (ICMS). The regime is administered through a Drawback Authorization granted by the Department of Foreign Trade Operations (DECEX), a unit within the MDIC.
With the advent of SECEX Ordinance No. 418/2025, services may now be included when opening new Drawback Authorizations or amending existing ones (granted as of January 1, 2023, and still in effect). Eligible services must be directly and exclusively linked to the export or delivery abroad of products manufactured under the drawback regime. Practically, beneficiaries will primarily link export-logistics services such as transport (road, rail, air, and water), storage, weighing and cargo measurement, customs clearance, and cargo insurance.
Additionally, training, installation, and assembly services for exported goods are covered, alongside other services of a similar nature listed in Annex 1 to the Ordinance. Crucially, for these covered services, payment of PIS/Pasep and Cofins is suspended on both the import of such services and their domestic procurement.
The Drawback regime currently stands as one of Brazil’s principal export incentives; from March 2024 to March 2025, exports supported by the Drawback Suspension regime totaled USD 69.1 billion, representing 20.5% of total exports (USD 336.6 billion). The extension of the regime to services significantly broadens the scope of relief and enhances the benefit for operators, offering a direct positive impact on the strategic planning of costs tied to exporting and delivering goods abroad.
Glossary
Ministry of Development, Industry, Trade and Services (MDIC) – Federal ministry that oversees industrial policy and foreign trade in Brazil.
Secretariat of Foreign Trade (SECEX) – Secretariat within the MDIC responsible for foreign trade policy and regulation.
SECEX Ordinance – Administrative rule (Portaria) issued by SECEX that regulates foreign trade regimes; here, No. 418/2025 extends drawback to services and No. 44/2020 governs Drawback Suspension.
Drawback Suspension – Special customs regime that suspends federal taxes on imported or domestic inputs used in the manufacture of goods for export.
Drawback Services – Extension of Drawback Suspension that allows suspension to apply to services directly and exclusively linked to exports or delivery abroad.
Drawback Authorization – Administrative authorization issued by DECEX approving the use of the drawback regime for a specific project and setting its conditions and targets.
Department of Foreign Trade Operations (DECEX) – Unit within the MDIC that analyzes applications and grants Drawback Authorizations.
Import Duty (II) – Federal tariff on imports of goods.
Excise Tax on Industrialized Products (IPI) – Federal excise tax on manufactured products.
PIS/Pasep – Federal social contributions levied on gross revenue; subject to suspension under the drawback regime when legal requirements are met.
Cofins – Federal social contribution on gross revenue; also subject to suspension under the drawback regime when legal requirements are met.
Additional Freight for the Merchant Marine Renewal Fee (AFRMM) – Federal fee levied on maritime freight to fund the Brazilian merchant marine; may be suspended under drawback in eligible cases.
ICMS – State-level value-added tax on the circulation of goods and certain services; administered by Brazil’s states and, in some contexts, subject to suspension or relief under drawback.
