Complementary Law No. 216 introduced significant innovations to Brazil’s export promotion policy, creating incentive mechanisms for micro and small exporting companies and aligning fiscal and customs incentives with the increasing importance of services associated with goods exports.
The key features of Complementary Law 216/2025 are as follows:
- Acredita Exportação Program
Targeted at micro and small enterprises (MSEs), the Acredita Exportação Program ensures the refund of tax credits on export transactions through Reintegra. The program aims to include MSEs in the system of fiscal and customs incentives for exports, thereby expanding the national export base.
- Drawback Services
Complementary Law 216/2025 established the Drawback-Services regime, allowing the inclusion of services directly linked to the export of goods produced with imported inputs or acquired domestically with tax suspension or exemption. Covered services include transportation, warehousing, brokerage, and logistics. The new regime is regulated by Joint Ordinance SECEX/RFB No. 3/2025 and SECEX Ordinance No. 418/2025, and has been in force since their publication.
- Enhancement of Recof
Complementary Law 216/2025 also expanded the Special Customs Regime for Industrial Warehousing under Automated Control (RECOF) to include services related to the production process and the export of manufactured goods. The new regime will take effect on January 1st, 2026.
The extension of the special customs regimes of Drawback and RECOF to services has the potential to reduce the indirect tax burden on exports, enhance the competitiveness of Brazilian companies in the international market, and align Brazil with best global practices in foreign trade, particularly in sectors where logistics and related services account for a significant share of export costs. The Customs Law team at LBM Advogados is available to provide guidance and assess the impact of Complementary Law No. 216/2025 on your company’s operations.