WHAT’S THE LATEST

The U.S. Trade Representative (USTR) has finalized a Section 301 action imposing an additional 25% ad valorem tariff on most products of Brazil. The tariff becomes effective July 22, 2026, and applies in addition to existing duties unless specifically exempted under Annex I or Annex II of the Federal Register notice.

The action concludes a year-long investigation into Brazil's practices on digital trade and electronic payments, preferential tariffs, anti-corruption enforcement, IP protection, ethanol market access and illegal deforestation.

Importers should immediately review Brazil-origin shipments, identify eligible exemptions and assess in-transit cargo that may qualify for temporary relief.

WHAT WE KNOW

Key Facts

Action

Section 301 of the Trade Act of 1974 — Final action against Brazil.
Rate

Additional 25% ad valorem, applied on top of the duty in the applicable HTS subheading (HTS 9903.05.01)
Effective

12:01 a.m. ET, July 22, 2026 — goods entered for consumption, or withdrawn from warehouse for consumption, on or after that time
In-transit relief

Act now. Goods loaded and in transit on the final mode before 12:01 a.m. ET July 22 and entered before 12:01 a.m. ET July 29, 2026 are not subject to the 25% (HTS 9903.05.02)
Second date

July 31, 2026 — patented pharmaceutical articles added to the Section 232-type exemption bucket (HTS 9903.05.07)
Scope

All products of Brazil except the exemptions listed in Annex I / Annex II of the FRN

 

Exemptions

USTR retained nearly all proposed exemptions and added several categories. Two items were removed:

  1. High-purity dissolving pulp (now dutiable), and
  2. The chemicals/ingredients exemption was narrowed to pharmaceutical-use only — non-pharma uses remain subject to the 25%.

Scope is defined at the HTS-subheading level in Annex I / II. Verify each SKU against the annex — and, for some categories, its end use — rather than relying on the category label:

Exempt category
HTS 9903 heading / note

Products already subject to Section 232 tariffs — aluminum/steel/copper & derivatives, autos & auto parts, medium/heavy-duty vehicles & parts, wood products, semiconductors

9903.05.07; note 50(a)(vi)

Listed raw materials & inputs — e.g., orange inputs, iron ore pellets, aluminum oxide, certain wood species, and the full subheading list in note 50(a)(ii)

9903.05.03; note 50(a)(ii)

Newly added exemptions — aluminum hydroxide; antiques/collectibles/art; certain seafood; pig iron; iron & steel waste and scrap; organic honey; unflavored instant coffee; used clothing; certain hides/furskins/leather; ash with precious metals

note 50(a)(iii); Annex II

Pharmaceutical-use articles only — listed chemicals/ingredients exempt only in pharmaceutical applications; non-pharma uses remain dutiable

9903.05.06; note 50(a)(v)

Civil aircraft, engines, parts & flight simulators (per GN 6 criteria)

9903.05.05; note 50(a)(iv)

Donations to relieve human suffering; informational materials; goods properly entered under Chapter 98 (with limits, e.g., 9802.00.80)

9903.05.08 / .09; note 50(a)

Personal-use goods in accompanied baggage

note 50(a)(i)

 

Full exempt HTS list and controlling terms: USTR Brazil Section 301 Final Action — Federal Register Notice (Annex I & II)

SEKO'S GUIDANCE

SEKO recommends importers take the following actions:

  • Map affected SKUs against the Annex I exempt subheadings; don't assume category-level relief without the HTS match.
  • Triage water-borne cargo loaded before July 22 and target entry before July 29 to capture the in-transit exemption.
  • Confirm Section 232 overlap (aluminum/steel/copper, autos & parts, wood, semiconductors) to avoid duplicative duty; verify pharmaceutical end use for 9903.05.06 items.
  • Model landed cost with the additive 25% stacked over existing Column 1, AD/CVD, and other duties.

SEKO's Customs Brokerage and Trade Compliance team can run an exposure screen against your Brazil-origin HTS lines, flag in-transit shipments eligible for the July 29 window, and adjust entry filing and landed-cost models accordingly. Contact your SEKO account representative or the Customs Brokerage Services team to arrange a review.

SEKO will monitor CBP implementation guidance (CSMS) and provide updates as developments warrant. If you have questions, please reach out to your SEKO representative, or email us at hello@sekologistics.com.