In this guide
- RADAR registration is mandatory for all Brazilian importers and takes 30-60 days.
- ICMS tax varies by state in Brazil, affecting your total landed cost.
- Siscomex electronic filing is required for import clearance in Brazil.
- EXW shipments require a reliable agent in China to handle export formalities.
EXW and FOB are the two Incoterms you’ll see most often on quotes for shipping from China to Brazil. But the difference isn’t just academic—especially for Brazilian importers. The choice determines who controls the export process in China, when responsibility (and risk) shifts to you, and where hidden costs can appear, including export clearance, port handling, and the complex Brazilian taxes like II, IPI, and ICMS. If you’re importing to São Paulo, Rio, or anywhere else in Brazil, understanding these terms is critical to avoiding delays, unexpected charges, and compliance traps.
This guide is written for Brazilian importers. We’ll break down exactly who pays what, when risk transfers, and why EXW is riskier for many Brazil-bound shipments. You’ll see Brazil-specific port and airport procedures, RADAR registration, Siscomex filing, and how the Incoterm affects your total landed cost. For the full picture—sea, air, customs, mode selection, and compliance routes—see our full Brazil shipping guide.
EXW vs FOB explained (what Brazilian importers need to know)
Before diving into cost and risk, let’s clarify what each term means for Brazil-bound shipments in plain language.
EXW (Ex Works): what it means
The seller makes the goods available at their premises—usually a factory or warehouse in China. That’s where their responsibility ends. You, the Brazilian importer, arrange pickup, transport to the port, export clearance, main freight, and everything from the factory gate onward. Handover happens at the seller’s door. EXW is the most “buyer-heavy” Incoterm for China→Brazil: you take control of the shipment from the very first mile. The seller’s invoice price will look lower, but only because they’re doing less. If you’re not equipped to manage the China origin side—including export formalities—EXW can become a logistical headache and delay your delivery to Brazil.
FOB (Free On Board): what it means
The seller delivers the goods to the Chinese export port and loads them onto the vessel. Once the cargo is on board, responsibility shifts to you: main freight to Brazil, destination port handling (THC at Santos or Paranaguá), import clearance via Siscomex, and last-mile delivery. Handover happens at the ship’s rail. FOB is the most common Incoterm for sea freight to Brazil: the seller handles the messy part (export clearance, trucking, port formalities in China), and you focus on ocean freight and Brazil-side logistics—the same tasks you’d handle under EXW, but without the China-side headaches.
Who handles what — at a glance
| Responsibility | EXW | FOB | CIF | DDP |
|---|---|---|---|---|
| Export clearance (China) | Buyer | Seller | Seller | Seller |
| Freight booking | Buyer | Buyer | Seller | Seller |
| Main transport cost | Buyer | Buyer | Seller | Seller |
| Cargo insurance | Buyer | Buyer | Seller (min.) | Seller |
| Import clearance (Brazil) | Buyer | Buyer | Buyer | Seller |
| Duties & consumption tax | Buyer | Buyer | Buyer | Seller |
| Domestic delivery | Buyer | Buyer | Buyer | Seller |
| Risk transfers at | Factory gate | Ship's rail | Dest. port | Buyer's door |
Key facts for Brazilian importers:
- EXW and FOB are the most common Incoterms for China-Brazil shipments.
- You must know who handles export and import formalities under each term.
- Both require a clear understanding of door-to-door vs port-to-port responsibilities.
Export clearance in China vs import clearance in Brazil (the key difference for Brazilians)
The main operational difference between EXW and FOB is who handles export clearance in China—and who is responsible for import clearance in Brazil. This split is where most Brazilian importers stumble, especially if they’re new to EXW.
Who handles export customs under EXW and FOB?
Under EXW, you (the buyer) are responsible for arranging export clearance in China. This means you need a local agent or freight forwarder who can handle the paperwork and navigate Chinese customs. Without this, your cargo could be stuck at the factory or rejected at the port. Under FOB, the seller arranges export clearance and covers all costs up to loading the goods on the vessel. You only take over once the cargo is on board, and focus on the Brazilian import side.
Brazil import clearance: Regardless of Incoterm, you must handle import clearance in Brazil. This requires active RADAR registration and filing your import declaration (DI) via Siscomex—the mandatory electronic platform. You’ll pay import duties (II), IPI, ICMS, and any port handling charges.
Why EXW can cause headaches for Brazilian importers
Many Brazilian importers choose EXW to save on upfront costs, but underestimate the complexity of China export clearance. We see frequent issues:
- Factories unwilling to provide export documents or cooperate with third-party agents.
- Lack of local representation leads to delays or failed clearance.
- Hidden costs for trucking, export licenses, and handling that weren’t included in the EXW quote.
- Missed deadlines for vessel cut-off, resulting in cargo being “rolled” to the next sailing.
FOB eliminates most of these headaches by shifting export clearance duties to the seller, who is familiar with local requirements.
- EXW requires a reliable local agent in China—without one, expect delays or failed clearance.
- Chinese factories may not be registered for export or unwilling to cooperate with third-party forwarders.
- FOB is safer unless you have proven, trusted representation on the ground.
Can you manage EXW from China to Brazil?
If you have a trusted local agent or forwarder in China who can handle export clearance, EXW can work and sometimes save money—especially for large, regular shipments. But for most Brazilian SMEs and first-time importers, FOB is far more predictable. If you’re considering EXW, ask your agent:
- Can they arrange all export documents and licenses?
- Are they familiar with Chinese customs and port procedures?
- Can they guarantee timely pickup and delivery to port?
If not, stick to FOB.
Key facts:
- Brazilian importers must have active RADAR registration to clear goods in Brazil.
- Export clearance in China can be problematic under EXW without a reliable local agent.
- Customs clearance via Siscomex is mandatory for all shipments.
Who pays what? (cost breakdown for China to Brazil under EXW vs FOB)
The Incoterm you choose determines who pays for each segment of the shipment—from factory pickup in China to final delivery in Brazil. Let’s break down the typical cost timeline.
Cost timeline: factory in China to your door in Brazil
| Stage | EXW: Who Pays? | FOB: Who Pays? |
|---|---|---|
| Factory pickup | Buyer | Seller |
| Inland trucking (China) | Buyer | Seller |
| Export clearance (China) | Buyer | Seller |
| Port handling (China) | Buyer | Seller |
| Ocean freight | Buyer | Buyer |
| Port handling (Brazil) | Buyer | Buyer |
| Import duties & taxes (II, IPI, ICMS) | Buyer | Buyer |
| Last-mile delivery in Brazil | Buyer | Buyer |
ICMS (state tax) and import duties (II, IPI) are always paid by the Brazilian importer, regardless of Incoterm. The main difference is who covers the origin-side costs in China.
EXW cost responsibilities (China to Brazil)
Under EXW, you pay for:
- Factory pickup and trucking to port
- Export clearance (including paperwork, licenses, fees)
- Port handling and loading charges
- Ocean freight
- Brazilian port handling (THC at Santos, Paranaguá, or Rio)
- Import duties: II (0-20%), IPI (0-15%), ICMS (7-18% varying by state)
- Last-mile delivery to your warehouse
Key trap: EXW often looks cheaper at first glance, but hidden China-side costs can add up quickly. If your agent isn’t experienced, you could face delays, extra fees, or even failed shipments.
FOB cost responsibilities (China to Brazil)
Under FOB, the seller pays for:
- Factory pickup and trucking to port
- Export clearance in China
- Port handling and loading charges
You pay for:
- Ocean freight
- Brazilian port handling
- Import duties (II, IPI, ICMS)
- Last-mile delivery
FOB gives you a predictable cost structure and reduces risk on the China side.
Key facts:
- ICMS varies by state and impacts total landed cost (see state tax impact).
- Import duties (II, IPI) and port charges are paid by the Brazilian importer.
- FCL vs LCL cost breakdown can affect your responsibilities.
Risk transfer points (when responsibility shifts for Brazil-bound cargo)
Incoterms don’t just define who pays—they define when risk and liability transfer from seller to buyer. For Brazil-bound shipments, this matters for insurance, claims, and operational control.
EXW: risk at the Chinese factory
Under EXW, risk transfers to you at the seller’s premises—before the cargo leaves the factory. If cargo is damaged, lost, or delayed during trucking to the port or export clearance, it’s your problem. You need to arrange insurance from the factory gate onward.
Key risk: If your agent fails to clear export, or cargo is damaged en route to port, you bear the loss.
FOB: risk at the port of loading
Under FOB, risk transfers once the goods are loaded onto the vessel at the port in China. The seller is responsible for any issues up to that point—including trucking, export clearance, and port handling. Once cargo is on board, you take over: insurance, ocean freight, and Brazil-side logistics.
Key risk: If cargo is damaged or lost during ocean transit or at the Brazil port, it’s your responsibility.
Summary table:
| Incoterm | Risk transfers at | Who covers insurance before handover? |
|---|---|---|
| EXW | Seller’s factory/warehouse | Buyer |
| FOB | Port of loading, on vessel | Seller (up to vessel), Buyer (after) |
Key facts:
- Under EXW, risk transfers at the seller’s premises in China.
- Under FOB, risk transfers once cargo is loaded on the vessel.
- Cargo insurance for Brazil is essential, especially for EXW.
Brazil’s import system essentials (RADAR, Siscomex, and required certifications)
Brazil’s import process is more complex than many other markets. You must be prepared for registration, electronic filing, and product certifications—regardless of Incoterm.
RADAR registration: your gateway to importing
Every importer must be registered with RADAR (Registro e Rastreamento da Atuação dos Intervenientes Aduaneiros). Without RADAR, you cannot clear goods through customs. Registration takes 30-60 days and typically involves legal or consultancy fees (BRL 5,000-15,000). Start this process well before your first shipment.
Key facts:
- RADAR registration is mandatory for all importers.
- Lead time: 30-60 days.
- No direct government fee, but professional fees usually apply.
Siscomex: mandatory electronic filing
All import declarations must be filed via Siscomex (Sistema Integrado de Comércio Exterior). You need to submit your Import Declaration (DI) electronically before cargo arrives. Delays or mistakes in Siscomex filing are a leading cause of customs delays.
Typical clearance timeline:
- Sea freight: 5-15 days (can be longer if inspections are triggered)
- Air freight: 2-7 days
INMETRO and MAPA: when you need extra certifications
Depending on your product, you may require:
- INMETRO Certification: For electrical, electronic, and certain regulated goods. Timeline: 30-90 days. Cost: BRL 5,000-20,000.
- MAPA Phytosanitary Certificate: For agricultural or plant-based products.
If certification is required, factor this into your lead time and costs. Learn more about INMETRO and ANATEL certification.
Key facts:
- RADAR registration can take 30-60 days and is mandatory for all importers.
- INMETRO or MAPA certification may be required depending on the product.
What to watch out for (common mistakes Brazilian importers make with EXW and FOB)
Every year, we see Brazilian importers run into the same traps—often because of misunderstanding EXW, FOB, or Brazil’s unique requirements.
Not verifying ISPM 15 compliance for pallets
Brazil enforces ISPM 15 for all wood packaging. If your pallets don’t have the correct heat treatment or mark, customs can reject or destroy your cargo. This is stricter than many other countries. Always verify with your supplier and see our pallet guide.
Underestimating RADAR registration lead time
RADAR registration isn’t instant. If you haven’t started the process, your cargo could arrive before you’re authorized to clear it, leading to storage costs and delays.
Overlooking ICMS variations by state
ICMS (state tax) varies from 7-18% depending on destination. Many importers budget based on São Paulo rates, but ship to other states and face unexpected tax bills. Always check the ICMS rate for your delivery location (see tax breakdown).
Incomplete or late Siscomex filing
Siscomex filing must be accurate and timely. Errors or late submission can trigger customs holds, inspections, and demurrage fees. Have a broker or consultant review your documents before submission.
Relying on EXW without a trusted Chinese agent
EXW only works if you have a reliable agent in China. Without one, you risk failed export clearance, missed sailings, and lost cargo. FOB is safer unless you have proven representation.
- Missing or incorrect ISPM 15 marks on pallets leads to cargo rejection.
- Arriving cargo before RADAR registration is complete results in storage fees.
- Budgeting for São Paulo ICMS but shipping to higher-tax states causes surprise costs.
- Incomplete Siscomex filings delay customs clearance.
- Choosing EXW without a trusted agent in China risks failed shipments.
Key facts:
- Non-compliant pallets can lead to cargo rejection at Brazilian ports.
- Late or incorrect Siscomex filing causes customs delays.
- Last-mile delivery pitfalls can add extra costs.
Bottom line: EXW vs FOB for China to Brazil (making the right choice)
For most Brazilian importers, FOB is safer and more predictable—especially if you don’t have trusted representation in China. EXW can offer savings, but only if you’re equipped to manage export clearance and local logistics. Always factor in Brazil’s unique requirements: RADAR registration, Siscomex filing, ISPM 15 compliance, and ICMS variations by state. Mistakes in any of these areas can cost you weeks and thousands in extra fees.
If you’re unsure about which Incoterm to choose, or need help with compliance and logistics, request a quote and our team will guide you through the process. For deeper details on mode selection, landed cost, and import duties, see our full Brazil shipping guide and related topics.
Choose the term that matches your capability—not just the lowest quote. With the right planning, you’ll avoid Brazil’s most common import traps and keep your cargo moving.
ReferenceGlossary· 32 terms
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- ANATEL Certification
- Agência Nacional de Telecomunicações Certification. Required approval for telecommunications and wireless products imported into Brazil.
- cargo insurance
- Insurance covering loss or damage to goods in transit. Arrange it from the moment risk transfers to you—under EXW that's at the factory gate; under FOB at the ship's rail.
- clearance
- Customs clearance. Process of presenting goods and documents to customs and obtaining release for import or export. Export clearance (who files it) is the key difference between EXW and FOB.
- cut-off
- Deadline by which cargo or documents must be received to make a specific sailing or flight. Missing it usually means a day's delay.
- DAP
- Delivered At Place. Seller delivers to a named place (e.g. buyer's warehouse) and unloads; buyer handles import clearance, duties, and Consumption Tax. IOR is the buyer.
- DDP
- Delivered Duty Paid. Seller pays all costs to the buyer's door, including clearance, duties, and Consumption Tax. True DDP means the recipient pays nothing at delivery.
- demurrage
- Charge when cargo stays at the terminal beyond the free time allowed. Often due to late docs or delayed pickup.
- door-to-door
- Service from shipper's door to consignee's door. The forwarder or carrier coordinates all legs, including pickup and delivery.
- export clearance
- Customs process to release goods for export before departure. Who arranges it depends on Incoterm: seller under FOB/FCA, buyer under EXW.
- EXW
- Ex Works. Seller makes goods available at their premises; buyer arranges pickup, export clearance, freight, and everything beyond. Risk transfers at the factory gate—the earliest of all Incoterms.
- factory gate
- The seller's premises where goods are made available. Under EXW, risk and responsibility transfer here—before any trucking or loading.
- FCA
- Free Carrier. Seller delivers to a named place (CY, CFS, or terminal); buyer books main freight and arranges insurance. Hand-off and risk transfer at delivery to the carrier—a clear, verifiable point. Fits containers (FCL/LCL) better than FOB; for air, use FCA or CIP.
- FCL
- Full Container Load. You book an entire container (e.g. 20GP or 40HC); only your cargo inside.
- FOB
- Free On Board. Seller delivers to the ship and clears export; buyer arranges freight and import from ship's rail. Risk transfers when goods are on board the vessel. Sea freight only—use FCA for air. For containers, the 'on board' moment is often unclear; FCA (CY/CFS) can be cleaner.
- forwarder
- Freight forwarder. Company that books transport, arranges documentation, and often coordinates customs on your behalf.
- ICMS
- Imposto sobre Circulação de Mercadorias e Serviços. Brazil's state-level value-added tax applied to goods and services, including imports.
- import declaration
- Document filed with customs to clear goods for import. Lists contents, value, HS codes, permits. Under DAP the buyer's broker files; under DDP the seller's broker or IOR files.
- Incoterms
- International Commercial Terms. Standard rules (EXW, FOB, CIF, DDP, etc.) defining who pays, who clears customs, and when risk transfers at each stage.
- inland trucking
- Road transport from factory to port or port to consignee. Distance and regional congestion affect cost and lead time; match port to factory and destination.
- INMETRO Certification
- Instituto Nacional de Metrologia, Qualidade e Tecnologia Certification. Mandatory product safety and quality certification for regulated goods in Brazil.
- IPI
- Imposto sobre Produtos Industrializados. Federal excise tax on manufactured goods, levied at importation.
- ISPM 15
- International Standards for Phytosanitary Measures No. 15. Treatment standard for wood packaging (pallets, crates)—heat treatment or fumigation mark required. Non-compliant wood blocks Japan import release.
- landed cost
- Total cost to get goods to the final destination: transport, handling, customs, duties, taxes, and last-mile. Use it to compare modes, not headline rate alone.
- last-mile
- Final leg of delivery from port, airport, or warehouse to the consignee's address. May include remote-area or residential surcharges.
- LCL
- Less than Container Load. Your cargo shares a container with others; priced per CBM (plus CFS and handling at both ends).
- phytosanitary certificate
- Official document issued by the exporting country's plant protection authority (e.g. GACC for China). States species, origin, and that the consignment is pest-free and meets Japan's import conditions. Required by MAFF for plant-derived goods.
- pickup
- Factory collection. Truck books, loads at origin, and transports cargo to the CFS, CY, or airport. Distance, multi-supplier stops, and cargo readiness affect cost.
- port-to-port
- Service from origin port to destination port only. You (or your forwarder) arrange pickup and delivery separately.
- risk transfer
- The moment when responsibility for loss or damage passes from seller to buyer. Under EXW at the factory gate; under FOB at the ship's rail; under FCA at delivery to the carrier (CY/CFS). Insure from that point.
- ship's rail
- The point at which goods cross onto the vessel. Under FOB, risk transfers here—the seller bears it until loading; the buyer from then on.
- Siscomex
- Sistema Integrado de Comércio Exterior. Brazil's official electronic customs system for managing import and export declarations.
- THC
- Terminal Handling Charge. Fee for loading/unloading containers at the port terminal. At origin, the buyer pays under EXW and the seller under FOB; at destination, the buyer pays in both cases.
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