New immigration controls for seafarers entering Brazil have now been put on hold according to a recent draft directive.
In November 2020, foreign crew were being fined because they were in Brazil without a visa and without an ILO 185 SID. This was the result of the application by immigration of Resolution 42 issued by the National Council on Immigration, published 14/10/2020 which states in article 11:
"...the seafarer and other professionals on board the vessel may enter the country with a visiting visa, being exempt from it the holders of the international seafarer card issued under the terms of Convention 185 of the International Labour Organization."
This energic application of the Resolution resulted in the issuing of fines and prohibition to effect crew changes giving rise to considerable complaint not only from agents, but principally from consular representatives of countries signatory to ILO 185, all stating that due to covid restrictions it has not been possible for seafarers to obtain the required SID.
Immigration Control have since issued a draft directive (MOC 51/2020) addressed to all regional superintendents which is dated 10/12/2020 (circularized 11/12/2020) stating that on account of the covid crisis and difficulty that this has raised for seafarers to obtain ILO 185 SID, the requirement for this (established in article 11 of Resolution 42 issued by the National Council on Immigration, published 14/10/2020) has been made more flexible.
Up until 15th June 2021 seafarers from countries signatories to ILO 185 and that have not yet obtained SID, may enter Brazil using ILO 108 identification (seaman's book).
Fines that have been applied on account of Resolution 42 and the lack of a SID shall be subject to review upon application and we are at your / Members disposition to prepare the required submission if need be.