Diego Rodríguez Paez
Director of Logistics and Industry Practice
AMI
Brazil’s Port of Santos is adding 3 million TEU of new capacity and by regulatory design, every operator currently running a Santos terminal is barred from bidding on it. APM Terminals, MSC, CMA CGM, and DP World have proposed a workaround that lets the same players keep their combined grip on the port. We think Brazil’s antitrust regulator will say no to this.
Here’s why, and what it means for whoever walks away with Tecon 10.
Brazil’s Port of Santos is building Tecon 10: four new berths, $1.1 billion, adding 3 million TEU of capacity, a roughly 50% increase to the port’s total, up to 9 million TEU. Every existing Santos terminal operator — APM Terminals and MSC’s jointly-owned BTP, CMA CGM’s Santos Brasil, DP World’s Embraport — is barred from the first bidding round on competition grounds. BTP alone controls roughly 35% of Santos’s container volume and generated $412 million last year, so this exclusion hurts.
APM Terminals and MSC’s TiL have proposed a workaround: both bid, and whichever wins buys out the other’s 50% stake in BTP, preserving their combined position while technically satisfying the divestment rule. It’s now with Brazil’s antitrust authority, Cade.
AMI’s call: Despite Cade approving the APM–TiL swap as filed, we expect Maersk and MSC to lose the first Tecon 10 round outright, and the berths go to a bidder with no existing Santos terminal. The whole point of Antaq’s exclusion rule was to stop Santos’s dominant operators from extending their grip on the port. A structure that lets the same two companies simply choose which of them owns the combined position doesn’t change the underlying concentration; it just relabels it.
The politics run the other way from the regulation: Brazil’s presidential chief of staff publicly argued for dropping the incumbent barriers, and even that political pressure is reportedly unlikely to move Antaq off its position. A regulator that won’t bend to the president’s office isn’t going to accept a structure that preserves the exact market concentration its own rule was designed to prevent. The consequence is measurable and worth writing down now: BTP’s roughly 35% share of Santos volume begins eroding the day the Tecon 10 berths come online, and on a 9-million-TEU port we expect the two incumbents’ combined share to sit meaningfully below where it does today by 2032.
If that’s right, the operators most exposed are the ones with no fallback, and that’s precisely where Hapag-Lloyd’s Aracruz bet becomes the more interesting story. While Maersk and MSC are spending regulatory capital trying to keep their position at Santos, Hapag-Lloyd’s terminal arm, Hanseatic Global Terminals, signed a deal in December 2025 to build a greenfield terminal at Aracruz, in Espírito Santo state, a joint venture with Brazilian conglomerate Imetame Group, targeting mid-2028 operation with 1.2 million TEU of capacity.
What is the impact for the other port terminal operators? Aracruz is what a fallback looks like when it is built two years before it is needed: a greenfield site outside the concentration problem, a local partner already holding land and permits, and enough capacity to be a genuine Santos alternative rather than a hedge.
For Maersk, MSC, and DP World, the harder version of that problem is timing: the alternative must be identified and optioned while Cade is still deliberating, not after the ruling lands.
How AMI Can Help You
We can provide rocket fuel for your decision-making with:
- Santos Tecon 10 Bid & Concentration Study: Models post-2032 share erosion for incumbent operators.
- Corridor Alternatives & JV Screen: a ranked short list of Aracruz-equivalent greenfield sites, credible local partners, and feeder reroutes with recapturable volume attached.
What Happens After Tecon 10?
Understand how Santos market dynamics could shift and where the next generation of port capacity opportunities may emerge.
SPEAK WITH AN AMI ANALYSTWhy You Need Our Help
Ports companies are forward thinkers: they have already war-gamed this situation.
But contingency plans are not always based on certainties.
Market conditions change rapidly—and contingency plans from months ago can age like cheese left in the sun.
With AMI, on your side, you get:
- The lay of the regulatory land that stretches all the way to 2032 so you can plan for a longer term
- A strong list of greenfield alternatives that’s ready BEFORE the ruling so you can move quickly
- A local team in place monitoring changes not just in 2027, but in 2028, 2029, and beyond so your planners have fresh data to fuel next steps, NOT outdated data
- The confidence to decide not just now, but later—even as conditions change
Contact us so we can begin helping you map out your moves as the Santos bidding process unfolds.
Winning Tecon 10 Isn’t the Only Way to Win
The operators best positioned for 2032 are planning beyond Santos today. Let AMI help you identify the next move.
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