What “enquadramento” means, and how the export operation is classified

The classification of the export operation at the Siscomex, a procedure known as “enquadramento”, involves several details and requires knowledge and support of Customs Broker experts. To understand it better, we have interviewed Ricardo Garlope – a lawyer, customs broker and director of Sindaerj (Customs Brokers Union in Rio de Janeiro). He provides some information about the Declaração Única de Exportação (Unified Export Declaration), how it is elaborated, and the details about the “enquadramento” procedures of the operations.

Keep reading and deepen your knowledge of this subject!

What is the Unified Export Declaration (Declaração Única de Exportação)?

The Unified Export Declaration (DU-E) is a document that centralizes all information (Customs procedures, commercial, financial and fiscal information, among others) about an export operation, which may be useful for the Customs clearances elaboration. It concerns an electronic documentation.

Its content consists of data that characterize the operations of the goods exported. Besides, it defines how the operation has to be classified. Finally, it is part of the Novo Processo de Exportação (New Export Process) that was incorporated to the Portal Único do Comércio Exterior (Unified Foreign Trade Portal), the SISCOMEX, and aims to make the existing procedures simpler.

How is the DU-E elaborated?

In the past, the declaration was prepared via the Registro de Exportação (RE, i.e., Export Register). The information was inputted at the Export Declaration and the Simplified Export Declaration electronic forms. Garlope explains it: “Previously, we used a platform composed of modules. Therefore, it was necessary to fill in the export register.”

According to Garlope, it had to be done irrespective of quantities. “You had to summarize the export entries required for the continuation of the Customs clearances, no matter how many they were”, he says.

Nowadays, the DU-E is in force, and it replaced the RE and its related documents. According to Garlope: “The DU-E is registered at the Portal Único Siscomex. The process is initiated by the accreditation of the exporters, to enable their operation in the foreign commerce (RADAR – System of Registration and Tracking of the Activities of Players within Customs Scope), and by the linking of its legal representative, the Customs broker.”

Data importation

We have two formats to elaborate de DU-E: importing data from the invoice, and the one without data importation. The first one is compulsory, according to the legislation, since the document is elaborated based on the export invoice data. However, there are a few exceptions in which case the obligation to import invoice data is exempted:

• Donations, goods of travelers not included in the concept of baggage or military use (with or without return);
• Unaccompanied baggage;
• Return of goods abroad before registering the Import Declaration;
• Inherited goods, etc.

Garlope brings some additional Information about this exemption: “the option not to apply the invoice data importation is an exception, not a standard procedure. The standard procedure is to have the export operation linked to at least one export invoice. If the exporter is not an ICMS (Tax on Circulation of Goods and Services) taxpayer and is not subject to “Inscrição Estadual” (State Register, i.e., registered at the State of its residence as an ICMS taxpayer) – therefore, exempted – the DU-E data is all inputted manually.

What are the advantages of the DU-E?

Garlope briefly describes the benefits of the DU-E: “the first benefit is the safety of the information sent to the fiscal authorities of the State of company’a registration or of Federal spheres. Once the data of the goods to be exported is migrated, the remaining fields to be filled refer to Customs operations procedures and international commerce.”

Furthermore, he associates the implementation of the DU-E to the technology development, pointing out advantages. “With the DU-E, the registration activities migrated from a modular system platform to a web environment. As so, a much more agile format has been implemented, avoiding reworks”, says Garlope.

He then concludes: “by registering the DU-E on line, all information provided by the exporter at the moment of the export invoices issuance at the local State Revenue Secretaries, is automatically migrated to the DU-E, and such information are not subject to alterations”.

What does the classification of the export operation involve?

The field “enquadramento” comprehends codes and patterns. They identify the particulars of the operation and the nature of the goods exported. Garlope explains how the process works: “the classification options are preset in the system. Therefore, the exporter must, in case his operation is not regarded as a “usual export”, chose the option that best fits to his process.”

How is the classification compatibility verified?

The incompatibility of the classification data of the export operations tends to block the DU-E registration procedure. Consequently, the data must be carefully and accurately inputted. For this purpose, a compatibility verification is done between the data and the Declaration register.

Garlope briefly explains the process: “the verification is done automatically, based on the information inserted. For example, if the goods are bound for Asia and an EU classification is selected, the system will display the incompatibility.”

According to him, several companies recently had to correct the registration of some products inputted in their own internal systems, due to errors connected with the Statistic Unit. He mentions that “once the DU-E imports the invoice data, the description and fiscal classification must be absolutely correct.”.

Finally, to avoid this sort of problem, he stresses the necessity of importers and exporters revising their products database. “They need to make sure the descriptions comprehend all the elements required to enable an exact identification of the goods or products, as well as the confirmation of the fiscal classification elected, and the corresponding administrative and tax procedures applicable.”

Who elaborates the DU-E and does the classification procedure of the export operation?

The DU-E may be registered autonomously and by an outsourced company, or by specialists employed for this purpose.

Garlope gives his opinion about these alternatives, starting from the autonomous classification: “self qualification and professional training is one of the objectives that must be pursued by professionals of any segment. Processes are developed with more agility and efficiency when the professionals involved understand what is communicated”, he points out.

Next, he talks about the employment of specialists: “however, the customs registers comprehend, in most cases, extramural elements. Thus, the ideal would be to use of a specialist for this purpose.”

In his point of view, it is necessary to prioritize knowledge, experience, and a regular and continuous activity in that given segment. “Therefore, when it refers to Customs segment and Customs related procedures, the ideal is always to rely on the services of a professional Customs Broker”, he concludes.

Wilson Sons has an expertise in all documentation involved in the maritime transport, including the classification of the export operation. As so, we are prepared to execute the process with the required quality. You can rely on our services!

If you wish to know more about what we can offer you, contact us without delay!