Brazil Section 301 Tariff 2026: USTR Proposes 25% Duty With a July 1 Deadline Every US Importer Must Act On

On June 1, 2026, the Office of the United States Trade Representative determined that a range of Brazil’s trade practices are actionable under Section 301 of the Trade Act of 1974, and proposed a 25% tariff on goods of Brazil in response. The proposal is not yet final. It is open for public comment until July 1, 2026, with a public hearing on July 6 and a statutory deadline of July 15, 2026 for USTR to take responsive action. The full Federal Register notice sets out the determination, the proposed action, and the exemption annex.

For any company importing Brazilian-origin goods, that timeline is the entire window to assess exposure, confirm whether a product sits inside or outside the proposed exemptions, and act before a 25% duty potentially lands on their landed cost. This guide breaks down exactly what was proposed, which goods are carved out, the dates that matter, and the specific steps importers should take now.

In short: the Brazil Section 301 tariff 2026 is a proposed 25% additional duty on certain Brazilian-origin goods, announced by USTR on June 1, 2026, with exemptions based on HTS classification and a public comment deadline of July 1, 2026.

The Brazil Section 301 tariff 2026 proposal matters even to companies that do not import directly from Brazil, because Brazilian-origin components and materials sit inside supply chains far beyond the obvious agricultural and steel categories. Aircraft parts, industrial machinery, electrical components, and a wide span of manufactured goods all have Brazilian content somewhere in the chain. The proposed action comes with significant carve-outs, and whether a specific product is exempt depends entirely on its Harmonized Tariff Schedule classification. For importers, the difference between an exempt HTS subheading and a covered one is the difference between business as usual and a 25% cost increase. Getting that classification right, and documenting it correctly, is the work that has to happen before July 1.

What the Brazil Section 301 Tariff 2026 Proposal Actually Says

The action follows a Section 301 investigation that the US Trade Representative initiated on July 15, 2025 at the direction of the President. After a public process that gathered testimony from over 30 witnesses and more than 295 comments and rebuttal comments, USTR determined on June 1, 2026 that six categories of Brazilian acts, policies, and practices are unreasonable or discriminatory and burden or restrict US commerce. The six findings are the legal foundation for the proposed tariff:

• Digital trade and electronic payment services: USTR found that Brazilian courts issued orders affecting US social media companies and that Brazil disadvantaged US companies in electronic payment services in favour of a national champion
• Unfair, preferential tariffs: Through partial-scope preferential arrangements with Mexico and India, Brazil grants lower tariff treatment to hundreds of Mexican and Indian goods across multiple sectors, treatment not extended to US goods
• Anti-corruption enforcement: USTR found that Brazil fails to take sufficient enforcement action to combat bribery and corruption
• Intellectual property protection: USTR cited insufficient enforcement against counterfeit goods, lengthy patent examination times particularly for biopharmaceutical patents, and inconsistent anti-piracy measures
• Ethanol market access: USTR found that Brazil discontinued balanced tariff treatment of ethanol in 2017 and has not provided reciprocal treatment for US ethanol exports since
• Illegal deforestation: USTR found that Brazil has historically failed to effectively enforce its own legal framework against illegal deforestation

On the strength of these findings, USTR published a Federal Register notice proposing a 25% Section 301 tariff on goods of Brazil, with two significant categories of carve-out that determine which importers are actually exposed. Understanding those carve-outs is the single most important step for any company sourcing from Brazil.

Brazil Section 301 Tariff 2026 Exemptions: The Two Carve-Outs That Decide Exposure

Carve-Out 1: Goods Already Covered by Section 232

Articles already subject to Section 232 tariffs are excluded from the proposed Brazil Section 301 action. This matters most for steel, aluminium, copper, and certain heavy equipment, which already carry Section 232 duties. The logic is that these goods are already subject to a separate tariff regime and are not double-counted under the new Section 301 proposal. For an importer of Brazilian steel or aluminium, the practical point is that the existing Section 232 exposure continues, but the proposed 25% Section 301 tariff does not stack on top of it. Confirming that a product genuinely falls under the Section 232 carve-out, rather than assuming it does, is an essential verification step.

Carve-Out 2: The Annex of Exempt HTS Subheadings

The Federal Register notice includes an annex listing more than 1,600 Harmonized Tariff Schedule subheadings that would be exempt from the proposed tariff. Within that annex, roughly 430 lines apply specifically to civil aircraft uses, a significant carve-out for the aerospace sector given Brazil’s role in the global aircraft and aircraft-parts supply chain. The annex spans a wide range of HTSUS chapters, covering categories across chapters 02, 05, 07 through 12, 14, 15, 16, 18 through 22, 25 through 34, 36, 38 through 40, 44, 47, 48, 56, 68, 70 through 76, 79 through 81, 83 through 85, 88, 90, 91, 94, 96, and 98.

The breadth of the exemption annex is the reason a blanket assumption either way is dangerous. A company cannot assume its Brazilian goods are hit, because the product may sit in an exempt subheading. Equally, it cannot assume its goods are safe, because a closely related product in an adjacent subheading may be covered while the exemption applies only to a specific classification. The only reliable answer comes from confirming the exact HTS subheading of each product against the published annex.

The Dates That Matter: A 19-Day Action Window

The Section 301 process runs on a fixed statutory schedule, and the most important dates fall within a tight window in summer 2026. An importer that wants to influence the outcome, or simply to be ready for it, is working against this calendar.

The key takeaway: importers have less than three weeks to assess exposure and act before the comment window closes on July 1.

The comment process is genuinely consequential. The original investigation drew testimony from over 30 witnesses and more than 295 comments, and USTR has emphasised that it continues to engage intensively with Brazil to seek resolution. The scope of the final action, including which products remain exempt, can be shaped by the comments USTR receives. An importer with significant Brazilian exposure has a real interest in participating, either directly or through a trade association or counsel, before the July 1 deadline.

Who Is Actually Exposed: Sector by Sector

Aerospace and Aircraft Parts

Brazil is a significant player in the global aerospace supply chain, and aircraft and aircraft parts are among the most heavily exposed categories on paper. The roughly 430 civil aircraft lines in the exemption annex are therefore highly significant. An aerospace importer should not assume blanket protection from those exemptions, nor assume blanket exposure. The correct step is to map every Brazilian-origin aircraft part against its specific HTS subheading and confirm whether that subheading is named in the civil aircraft exemption lines. A part that qualifies for the civil aircraft exemption is protected. A closely related part outside the exemption may face the full 25%. The classification is the deciding factor.

Industrial Machinery and Electrical Equipment

The exemption annex covers parts of chapters 84 and 85, which include machinery and electrical equipment, but the coverage is at the subheading level, not the whole chapter. A company importing Brazilian industrial machinery, motors, electrical components, or equipment needs to verify each product’s classification individually. Some subheadings within these chapters are exempt and some are not. For importers of capital equipment and industrial components, the exposure analysis is product-specific and cannot be generalised from the chapter level.

Steel, Aluminium, Copper, and Heavy Equipment

Goods already covered by Section 232, including steel, aluminium, copper, and certain heavy construction equipment, are excluded from the proposed Section 301 tariff. These importers continue to manage their existing Section 232 exposure, but the new 25% proposal does not add to it. The verification step here is confirming that a given product genuinely falls under the Section 232 regime rather than sitting in a gap where neither the 232 carve-out nor a Section 301 exemption applies.

Agriculture, Ethanol, and Consumer Goods

Ethanol market access is one of the six findings underpinning the action, and agricultural and food categories appear extensively in the exemption annex across chapters 02 through 22. Importers of Brazilian food products, beverages, and agricultural goods should expect a mixed picture where many but not all categories are exempt. As with every other sector, the answer is at the subheading level. Coffee, juices, sugar, and processed foods each carry distinct classifications that must be checked individually against the annex.

Why an IOR and Origin Verification Matter More Under a Section 301 Action

A proposed country-specific tariff sharpens the importance of two things that are always part of compliant importing but become decisive when a 25% duty is at stake: accurate country-of-origin determination and accurate HTS classification. Both sit at the heart of the Importer of Record’s responsibility.

Country of origin is the first pressure point. A 25% tariff on goods of Brazil makes the origin determination commercially critical. Goods finished in Brazil from components sourced elsewhere, or goods routed through Brazil, raise the same substantial transformation questions that apply in any origin analysis. From our experience managing import programmes, the origin question that was a routine documentation step becomes a high-value determination the moment a country-specific tariff is proposed, because the difference between Brazilian origin and another origin is now 25 percentage points of duty. The IOR named on the entry is responsible for the accuracy of that origin declaration.

HTS classification is the second pressure point. With more than 1,600 exempt subheadings, the precise classification of each product determines whether the tariff applies at all. A classification that places a product in an exempt subheading avoids the tariff entirely. A classification error that places it in a covered subheading triggers the full 25%, and a misclassification in the other direction creates a different compliance exposure. The IOR’s classification work is the line between paying the tariff and being correctly exempt. For the broader CBP enforcement environment that makes classification accuracy non-negotiable in 2026, see our guide to the CBP customs audit landscape in 2026.

Are your Brazilian-origin goods exposed to 25% cost exposure, or correctly classified under an exempt subheading? Carra Globe’s HS Code Finder and classification verification give you line-level certainty before July 1.

Five Actions for Importers of Brazilian Goods Before July 1

1. Build a complete inventory of every Brazilian-origin product you import, mapped to its exact HTS subheading. This is the foundation for everything else. You cannot assess exposure to the proposed tariff without knowing the precise classification of each product. List every Brazilian-origin item, its current HTS subheading, and its annual import value. This inventory is the document that tells you, line by line, what is exempt and what is exposed
2. Check each HTS subheading against the published exemption annex and the Section 232 carve-out. For every product in your inventory, confirm whether its subheading appears in the more than 1,600 exempt lines, whether it falls under the Section 232 carve-out, or whether it is exposed to the full 25%. The civil aircraft exemption lines are especially important for aerospace importers. This is precise, line-level verification work where a single subheading determines the outcome. Use our HS Code Finder to confirm the classification of each product before checking it against the annex
3. Recalculate landed cost on every exposed product at the 25% rate. For any product that is not exempt, model the landed cost with the proposed 25% tariff applied. This tells you the real financial exposure if the tariff is finalised as proposed on July 15. A product with thin margins and full exposure may need a sourcing or pricing decision well before the tariff takes effect. Use our landed cost guide to build the full duty-inclusive cost for each exposed line
4. Decide whether to submit a comment or hearing request before the deadlines. If you have significant exposure, the comment process is a genuine opportunity to influence the scope and exemptions of the final action. Written comments are due July 1 under docket USTR-2026-0331, and hearing requests are due June 22 under docket USTR-2026-0397. A well-documented comment explaining the impact on your business, your workforce, or your supply chain can inform how USTR shapes the final exemptions. Many importers will leave this to trade associations; companies with material exposure should consider participating directly or through counsel
5. Confirm your origin documentation and IOR arrangement can withstand scrutiny. A 25% country-specific tariff raises the stakes on origin accuracy. Ensure your country-of-origin determinations for Brazilian goods are documented, defensible, and supported by manufacturing and bill-of-materials evidence. The Importer of Record on each entry is responsible for the accuracy of both the origin declaration and the classification. Our Importer of Record services include classification verification and origin analysis for importers managing tariff exposure across changing trade measures

How This Fits the Wider 2026 Enforcement Picture

The Brazil action does not stand alone. It arrives in the same window as the June 3, 2026 customs enforcement executive order that tightened the rules on every Importer of Record, the suspension of de minimis treatment, and a broader USTR push that includes proposed Section 301 actions tied to forced labour enforcement across dozens of economies. The common thread is that origin, classification, and the identity and accountability of the importer of record are all under heightened scrutiny at once. A company that has built clean classification practices, defensible origin documentation, and a compliant IOR arrangement is positioned to handle a country-specific tariff like the Brazil proposal as a manageable analysis. A company that has not is exposed on several fronts simultaneously.

For importers who have been diversifying supply chains away from China and toward other origins, the Brazil action is also a reminder that no single alternative origin is permanently safe from trade measures. The Brazil determination may well prove to be a template for future Section 301 actions against non-China sourcing markets, as the United States extends the same scrutiny it has applied to China toward the countries that have absorbed redirected trade. The same origin and classification discipline that protects against one country’s tariff exposure protects against the next. For how this plays out across alternative sourcing markets, see our guide to trade diversion and IOR compliance in 2026.

Frequently Asked Questions

Is the 25% Brazil tariff in effect now?

No. As of June 2026 the 25% tariff is a proposal, not a final rule. USTR published the proposed action on June 1, 2026, is collecting public comments through July 1, and faces a statutory deadline of July 15, 2026 to take responsive action, which it may finalise, modify, or defer while negotiations with Brazil continue.

Because it is a proposal, importers have a window to assess exposure and, if they choose, to participate in the comment process before any tariff takes effect. The outcome on July 15 is not predetermined. USTR has stated it continues to engage intensively with Brazil to seek resolution of the underlying concerns.

Which Brazilian goods are exempt from the proposed tariff?

Two categories are carved out: goods already covered by Section 232 tariffs such as steel, aluminium, and copper, and more than 1,600 HTS subheadings listed in the exemption annex, including roughly 430 lines specific to civil aircraft uses. Whether a product is exempt depends on its exact HTS subheading.

The exemption annex spans many HTSUS chapters, but coverage is at the subheading level, not the chapter level. A product cannot be assumed exempt because its chapter appears in the annex. Each product’s specific classification must be checked against the published list to determine its status.

How can my company submit a comment on the Brazil Section 301 action?

Written comments are due by July 1, 2026 and must be submitted electronically through the USTR comments portal under docket number USTR-2026-0331. Requests to appear at the July 6 public hearing are due by June 22, 2026 under docket number USTR-2026-0397.

The comment process is a genuine opportunity to inform the scope of the final action. A comment that documents the specific impact of the proposed tariff on your business, supply chain, or workforce can influence how USTR shapes the final exemptions. Companies with material exposure should consider participating directly or through a trade association or trade counsel.

Does the Brazil tariff stack on top of existing Section 232 duties?

No. Goods already subject to Section 232 tariffs, such as steel, aluminium, and copper, are excluded from the proposed Brazil Section 301 action. The 25% Section 301 tariff does not stack on top of the existing Section 232 duty for those goods.

The practical step for importers of these materials is to confirm that the product genuinely falls under the Section 232 regime. A product sitting in a gap, neither clearly under Section 232 nor named in the Section 301 exemption annex, could be exposed to the new tariff, so the carve-out should be verified rather than assumed.

What should I do if my Brazilian product is not exempt?

Recalculate the landed cost with the 25% tariff applied to understand the real exposure, then evaluate your options: submitting a comment before July 1, reviewing whether an alternative compliant origin exists, adjusting pricing, or confirming the classification is correct in case an exempt subheading applies.

The most important first step is confirming the classification is accurate, because a significant share of products sit in the exemption annex. If the product is genuinely exposed, the landed cost recalculation tells you the scale of the impact and informs whether a sourcing, pricing, or commenting response is warranted before the July 15 statutory deadline.

For companies importing Brazilian-origin aerospace parts, industrial equipment, electrical components, or other regulated goods, the proposed Section 301 tariff makes accurate classification and origin determination an urgent priority before July 1. Carra Globe’s Importer of Record services include HTS classification verification, country-of-origin analysis, and landed cost modelling to help importers understand and manage tariff exposure across changing trade measures. To understand the full IOR role before reviewing your exposure, see our explainer on what an Importer of Record is and does.