The Brazilian National Health Surveillance Agency (Anvisa) has recently amended its practice
for the issuance of Certificates of Free Pratique (CLP). It is anticipated that this will extend
the process from one to two days to as many as fifteen days and consequently increase the
costs associated with the import of goods that will be held in port for longer periods.
Furthermore, certain ports are intensifying their inspections requiring the renewal of expired
Sanitary Vessel Control certificates (SSCECs) before issuing the CLP. Anvisa advises that
the following procedures are now in place:
• CLPs can only be issued for a vessel after it has berthed. This will depend upon the
scheduling and availability of Anvisa’s inspection unless the CLP has been issued via
the Paperless Port (PsP);
• Anvisa has the discretion to determine if a CLP will be issued for a vessel via the PsP;
and
• no shore-based personnel are allowed onboard the vessel until the CLP has been
issued.
Although Free Pratique is generally granted via radio communication, health authorities at
some ports may require a full vessel inspection dependent upon the availability of inspectors.
It should also be noted that inspections are only performed during business hours (i.e.,
Monday through Friday from 9am to 5pm).
Vessels scheduled to arrive or berth outside of normal business hours will have their
operations delayed until Anvisa completes its inspection, declares Free Pratique and ensures
relevant SSCECs are valid. Such measures may cause vessels to deviate as terminals and
port authorities will prioritize vessels which have been declared to be in compliance. This may
be of particular concern for vessels looking to perform cargo operations during weekend
periods.
Some ports with particular concerns include:
• Paranaguá Port Complex. Free Pratique is available at a vessel’s berth following
inspection. A shortage of health inspectors, particularly during weekends, may
significantly delay cargo operations.
• Sāo Francisco do Sul Port Complex. Free Pratique will only be issued at berths, post
inspection. There is a shortage of health inspectors both at night and during weekends.
Vessels which have been granted Free Pratique at prior Brazilian ports will be
prioritized for cargo operations.
• Fortaleza and Pecém. Vessels will only be granted Free Pratique after vessel
inspection.
The difficulties described above have very recently been complicated by the announcement
by the union representing employees of the eleven federal regulatory agencies responsible
for the supervision of, inter alia, port operations, that a 24-hour nationwide strike will take
place on July 4.
While this strike action is undergoing emergency judicial review in light of Brazilian law
inhibiting the withdrawal of labor from essential public services, it could nonetheless affect
ports and shipping in a manner exacerbating the problems described in the first part of this
Alert. Developments continue to be monitored in the meantime, and further reports will be
made as necessary.
