Brazil opens consultation on solid-bulk barge-to-ship transshipment rules

Brazil’s waterway regulator, ANTAQ, has opened Public Subsidy Process SRG No. 2/2026 on potential rules for solid-bulk “barge-to-ship” transshipment operations. The consultation, published on 17 September, seeks evidence and comments on a preliminary Regulatory Impact Analysis under Theme 1.3 of ANTAQ’s 2025–2028 Regulatory Agenda. Submissions are open through 23:59 Brasília time on 15 October, and ANTAQ will hold a webinar on 23 September at 10:00.

The process is not a new operating restriction or a final rule. It is an early regulatory-design stage intended to determine whether, and how, ANTAQ should codify requirements for direct transfers of solid bulk from barges to ocean-going ships. The Agency’s regulatory agenda identifies the growing use of this model in Brazil’s North region and the need to incorporate the activity’s specific regulatory aspects into its rules.

The consultation is material because the existing treatment can turn on the precise configuration of an operation and the status of the facility or operator. In a December 2024 decision concerning the direct discharge of vegetable bulk from barges to bulk carriers berthed at a terminal, ANTAQ found that the transfer did not require a separate authorisation in that specific case because the operator was already authorised; prior communication to the granting authority was nevertheless required. Conversely, an October 2025 ANTAQ decision on an offshore solid-bulk transshipment proposal found that the applicable regulatory classification was an authorised Cargo Transshipment Station (ETC). Those decisions illustrate why parties should not assume that one project’s treatment applies automatically to another.

For shipowners, charterers, terminals, barge operators and cargo interests, the immediate action is procedural rather than operational: review the preliminary impact-analysis material when available, identify practical issues that could affect berth interfaces, ship/barge mooring arrangements, loading sequences, draft and stability controls, cargo accounting, environmental safeguards, communications and responsibility allocation, and submit evidence before the deadline. Contracts for planned northern export-chain movements should also preserve flexibility for future permit, notification, equipment and operating-procedure requirements.

Why this matters: barge-to-ship transfers can extend export logistics beyond conventional quay capacity and support inland-waterway cargo flows, but they also concentrate marine-interface, cargo-control and liability questions at the point of transfer. A clearer, proportionate framework could improve planning and consistency. Until ANTAQ completes its assessment and any subsequent rulemaking, operators should base compliance plans on the facts and approvals of each operation—not on broad assumptions about a developing market practice.