The Brazil Section 301 tariff 2026 is live. Since 12:01 a.m. Eastern Time on 22 July 2026, a 25% additional ad valorem duty has applied to most products of Brazil under HTSUS heading 9903.05.01. This is no longer a proposal or a comment window: it is a duty CBP is collecting right now.
So the question has changed. A month ago it was “will this happen, and can I influence it.” Today it is sharper and more commercial: do I absorb 25% on my Brazilian goods, or do I move, and if I move, where do I go and who acts as my importer of record there.
Most coverage of this tariff stops at the first half of that question. This guide answers both, because knowing a duty exists is not the same as knowing what to do about it. Below: exactly what is covered, which goods are carved out, how the narrow in-transit relief actually works at entry, and the sourcing alternatives if the maths no longer works.
Brazil Section 301 Tariff 2026: At a Glance
- What it is: a 25% additional ad valorem duty on most products of Brazil, under HTSUS 9903.05.01, set out in the USTR Notice of Action.
- Live since: 12:01 a.m. ET on 22 July 2026, finalised by USTR on 15 July after a year-long investigation.
- Exemptions: Annex I carve-outs at the HTS-subheading level, including beef, orange juice, coffee, civil aircraft and parts, energy, and pharmaceutical-use articles.
- Section 232 goods: excluded. The 25% does not stack on Section 232, but it does stack additively on standard duties, AD/CVD, and Section 122.
- In-transit relief: narrow, ocean freight only, under 9903.05.02, for goods loaded before 22 July and entered before 29 July 2026.
- If it does not work: the real decision is absorb or move. We cover both, including realistic alternative origins and IOR cover in each.
What the Final Brazil Section 301 Action Does
USTR initiated the Section 301 investigation into Brazil on 15 July 2025 at the direction of the President. Over the following year it held consultations with the Brazilian government, convened a two-day public hearing on 6 and 7 July 2026, and gathered more than 360 written comments and testimony from 77 witnesses. On 15 July 2026 the President issued a memorandum directing the action, and USTR published its Notice of Action the same day. CBP issued implementation guidance on 22 July under CSMS #69302472.
The investigation found six categories of Brazilian acts, policies, and practices to be unreasonable or discriminatory and to burden or restrict US commerce. These six findings are the legal foundation for the tariff:
- Digital trade and electronic payment services: Brazilian court orders affected US social media companies, and Brazil disadvantaged US firms in electronic payments in favour of a national champion.
- Unfair, preferential tariffs: through partial-scope arrangements with Mexico and India, Brazil grants lower tariff treatment to hundreds of Mexican and Indian goods, treatment not extended to US goods.
- Anti-corruption enforcement: USTR found Brazil fails to take sufficient action to combat bribery and corruption.
- Intellectual property protection: weak enforcement against counterfeits, lengthy patent examination especially for biopharmaceuticals, and inconsistent anti-piracy measures.
- Ethanol market access: Brazil discontinued balanced tariff treatment of ethanol in 2017 and has not provided reciprocity for US ethanol exports since.
- Illegal deforestation: Brazil has historically failed to effectively enforce its own legal framework against illegal deforestation.
One point to clear up early, because it is the single most common confusion: this is not the China tariff under a new name, and it is not the multi-country forced-labour action. It is Brazil’s own dedicated Section 301 tariff, on its own legal footing, arising from the six findings above. We come back to why that distinction matters for your duty stack below.
Which Brazilian Goods Are Exempt: The Two Carve-Outs
Carve-out 1: goods already covered by Section 232
Articles already subject to Section 232 tariffs are excluded from the Brazil Section 301 action. This covers steel, aluminium, copper and certain derivatives, autos and auto parts, specified vehicles, wood products, and semiconductor articles, all of which already carry Section 232 duties.
The 25% Section 301 duty does not stack on top of the Section 232 duty for these goods. For an importer of Brazilian steel or aluminium, the existing Section 232 exposure continues unchanged, but the new tariff does not add to it. The verification step is confirming a 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.
Carve-out 2: the Annex I exempt subheadings
The Final Notice includes an annex of specific HTS subheadings carved out of the duty. USTR retained nearly all the exemptions from its June proposal and added several after public comment. The exempt categories include beef, oranges and orange juice, coffee, civil aircraft and aircraft parts, jet engines and aerospace parts, energy products, pharmaceutical-use articles, vaccines, minerals, fertilizers, auto parts, iron ore pellets, aluminium oxide, wood products, spices, and dietary supplements.
CBP guidance also confirms carve-outs for certain religious-use products such as select foods and essential oils where supporting documentation is provided, humanitarian donations of food, clothing and medicine, and informational materials including books, films, artwork, and news media.
Just as important is what did not survive. The exemption list shifted right up to the wire. After testimony, USTR pulled dissolving pulp and narrowed the chemicals exemption to pharmaceutical use only, so non-pharmaceutical uses of those chemicals now face the full 25%. And it firmly shut the door on apparel, footwear, paper, electrical machinery, farm and mining equipment, and organic sugar, all of which are covered. The most exposed categories overall are general machinery, many industrial goods, sugar, apparel, and footwear.
The critical point is that every exemption is defined at the HTS-subheading level, not by broad product category. A company cannot assume its Brazilian goods are exempt because the general category appears in the annex, and it cannot assume they are covered either, because a closely related product in an adjacent subheading may fall the other way. The only reliable answer comes from matching each product’s exact HTS subheading against the published annex. Our HS Code Finder confirms the classification so it can be checked line by line.
How the Duty Stacks, and the In-Transit Relief That Trips Importers Up
Two mechanical points decide what you actually pay, and both are easy to get wrong at entry.
Stacking. The 25% Brazil duty is additive. It applies on top of the standard Column 1 duty rate, on top of any antidumping or countervailing duties, on top of Section 122, and on top of other applicable fees, unless the product is exempt.
The one thing it does not stack on is Section 232: goods already subject to Section 232 are carved out entirely. It may, however, stack with future Section 301 measures, including the separate forced-labour and overcapacity actions, so a Brazilian product could in principle face this duty plus a later Section 301 tariff. This is exactly why the “is this the China tariff” confusion is costly: they are different actions, and the wrong assumption produces the wrong number on the entry.
In-transit relief, and where it fails. There is a narrow grace period under heading 9903.05.02, and it applies only to ocean freight. To qualify, goods must have been loaded onto a vessel and in transit on their final mode before 12:01 a.m. ET on 22 July 2026, and must be entered for consumption, or withdrawn from warehouse, before 12:01 a.m. ET on 29 July 2026.
Both conditions must be met, and this is where importers lose the relief they thought they had. A purchase-order date or booking confirmation does not establish eligibility: CBP looks for the actual bill of lading, loading records, and arrival evidence proving the vessel was already in transit before the cut-off.
Air freight does not qualify at all. And missing the 29 July entry deadline by a single day forfeits the exemption on cargo that was otherwise eligible, which is a real and avoidable way to pay 25% you did not need to. For any water-borne cargo already at sea, the entire priority this week is getting it entered before the window closes.
One further operational trap: goods admitted to a US Foreign Trade Zone on or after 22 July must be admitted under privileged foreign status under 19 CFR 146.41 unless they qualify for domestic status, and Chapter 98 provisions do not all behave the same way, with repair, alteration, and assembly programmes under certain subheadings remaining partially subject to the duty. The entry-line sequence also matters: CBP has reminded filers to report the Section 301 Chapter 99 heading in the correct order relative to other Chapter 98 and 99 provisions. These are the details that separate a clean entry from a rejected one.
The 25% is being collected now, and the exemption turns on your exact subheading and a clean entry. The difference between an advisor and an operator is that we do not just tell you the rule, we file the entry, defend the origin, and model the alternative. Carra Globe acts as your importer of record in 175+ countries, which means we can also answer the question the tariff really raises: if Brazil no longer works, where next.
Check your Brazil exposure, and your alternatives →
The Real Decision: Absorb the 25%, or Move
This is the section most coverage of this tariff leaves out, and it is the one that actually costs or saves money. Once you know a product is exposed, you face a commercial choice, not just a compliance task. There are broadly three responses, and the right one depends on your margin and your volume.
- Absorb it. For a product with healthy margin, or one where Brazil is genuinely the only viable source (some agricultural inputs, certain minerals), paying the 25% and passing part of it through in price may be the rational answer. The work here is a clean landed-cost model so you know the real number and can price against it.
- Requalify the origin. If the good is finished in Brazil from components made elsewhere, or merely routed through Brazil, the origin determination is worth revisiting carefully. Substantial transformation is a technical test, not a matter of where the invoice is raised, and getting it right can move a product out of scope legitimately. Getting it wrong is a false claim with penalties attached, so this is expert work, not wishful thinking.
- Move the source. For exposed, price-sensitive, movable goods, the honest answer is often to source elsewhere. This is where a tariff guide usually goes silent, because most publishers cannot help you actually do it.
If moving is the answer, the practical question is where, and who clears the goods for you there. The realistic alternative origins depend on the product. For machinery and industrial goods, other Latin American producers and parts of Southeast Asia are common substitutes. For footwear and apparel, which Brazil largely lost its exemption on, Vietnam, Indonesia, and India are the established alternatives. For agricultural and food products, the answer is category-specific and sometimes there is no clean substitute, which is itself useful to know before you waste time looking.
The catch every importer hits is that entering a new sourcing market means having an importer of record there, someone legally able to bring the goods in, hold the compliance, and pay the duty.
That is precisely the gap Carra Globe fills. We act as importer of record across 175+ countries, so the alternative origin you identify on paper is one we can actually operate, rather than a market you then have to go and solve from scratch. A law firm can tell you Brazil is expensive. A tariff calculator can tell you the rate. Neither can be your declarant in Vietnam next month. That is the difference between advice and a route out.
Who Is Exposed: Sector by Sector
Aerospace and aircraft parts
Brazil is a significant player in the global aerospace supply chain, and civil aircraft, jet engines, and aircraft parts are among the exemptions USTR retained. That is a meaningful carve-out, but it is not blanket. Map every Brazilian-origin part against its specific HTS subheading and confirm it falls within the civil aircraft exemption lines. A part that qualifies is protected; a closely related part outside the named subheadings may face the full 25%. The classification is the deciding factor.
Industrial machinery and electrical equipment
This is one of the most exposed areas, and CBP guidance confirms electrical machinery was specifically kept in scope. General industrial machinery, motors, and electrical equipment from Brazil are largely covered by the 25% duty, with machinery exempt mainly for civil aircraft use. A company importing Brazilian capital equipment or industrial components needs to verify each product’s classification individually, because the exemption is narrow and end-use dependent. For importers of industrial and electrical goods, this is where the real cost exposure sits, and where the “absorb or move” decision above bites hardest.
Steel, aluminium, copper, and heavy equipment
Goods already covered by Section 232, including steel, aluminium, copper and certain derivatives, autos and auto parts, and semiconductors, are excluded from the Brazil Section 301 duty. These importers continue to manage their existing Section 232 exposure, and the 25% does not add to it. The verification step is confirming a product genuinely falls under Section 232 rather than sitting in a gap. For the detail of the current Section 232 regime, see our guide to Section 232 full customs value 2026.
Apparel, footwear, and consumer goods
Apparel and footwear are squarely in scope: USTR declined to exempt them, so Brazilian-origin clothing and shoes now carry the full 25%. These are also among the most movable supply chains, which makes them the clearest candidates for the “move the source” response, with Vietnam, Indonesia, and India as established alternatives. Consumer goods more broadly are a mixed picture at the subheading level, so each line still has to be checked, but for exposed, price-sensitive apparel and footwear the sourcing question is usually the real one.
Agriculture, ethanol, and food
Agricultural and food categories fared relatively well. Beef, oranges and orange juice, coffee, and a range of other food products are carved out, and hundreds of additional agricultural lines were removed after industry comment. But the picture is mixed: sugar, notably, remains exposed, and each food category carries a distinct classification that must be checked individually. Where a food input has no clean alternative source, absorbing the duty may be the only option, which is exactly why knowing the classification and the substitute landscape early is worth the effort.
Why an IOR and Origin Verification Are Decisive Here: Operators, Not Just Advisors
A country-specific 25% tariff turns two routine parts of compliant importing into high-value determinations: accurate country-of-origin determination and accurate HTS classification. Both sit at the heart of the Importer of Record’s responsibility, and both now carry 25 percentage points of duty on the outcome. This is where the distinction between a firm that explains the tariff and a firm that clears the shipment stops being marketing and starts being money.
Country of origin is the first pressure point. A 25% duty on goods of Brazil makes origin commercially critical. Goods finished in Brazil from components sourced elsewhere, or routed through Brazil, raise substantial transformation questions that were once a routine documentation step and are now a high-value determination, because the difference between Brazilian origin and another origin is 25 percentage points.
From the operator’s side of the desk, this is the moment CBP scrutiny actually lands: an origin claim on a Brazilian entry now needs to be backed by bill-of-materials and manufacturing evidence that will survive a request for information, not just a supplier’s assertion on a commercial invoice. The IOR named on the entry owns that declaration and its defence.
HTS classification is the second. With exemptions defined at the subheading level, the precise classification of each product determines whether the duty applies at all. A classification that places a product in an exempt subheading avoids the duty; an error that places it in a covered one 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, and it is the tedious, line-by-line work that a licensed operator does as routine and an advisor simply flags. For the broader enforcement environment that makes this non-negotiable, see our guide to the CBP customs audit landscape in 2026.
What Importers of Brazilian Goods Must Do Now
- Inventory every Brazilian-origin product, mapped to its exact HTS subheading. You cannot assess exposure without knowing the precise classification of each product. List every Brazilian-origin item, its current subheading, its supplier, its annual import value, and its expected entry dates. This is the document that tells you, line by line, what is exempt and what is now dutiable at 25%.
- Check each subheading against the annex and the Section 232 carve-out. For every product, confirm whether its subheading is exempt, whether it falls under the Section 232 carve-out, or whether it is exposed to the full 25%. This is precise, line-level work where a single subheading determines the outcome. Use our HS Code Finder to confirm each classification before checking it against the annex.
- Triage any ocean cargo for the in-transit window before 29 July. For water-borne shipments loaded before 22 July, target entry before 12:01 a.m. ET on 29 July to capture the relief, and make sure the bill of lading and loading records are in hand to prove eligibility. Miss the deadline and the 25% applies. Air freight does not qualify.
- Recalculate landed cost on every exposed product, then decide: absorb, requalify, or move. Model the duty-inclusive landed cost with the additive 25%, then make the commercial call. Use our landed cost guide to build the full stack. For exposed, movable goods, price the alternative origin alongside the Brazilian one so the decision is made on numbers, not instinct.
- Confirm your origin documentation and IOR arrangement can withstand scrutiny, in Brazil and anywhere you move to. A 25% country-specific tariff raises the stakes on origin accuracy. Ensure your country-of-origin determinations are documented and defensible, and make sure that wherever you source next, you have an importer of record able to operate there. Our Importer of Record services cover classification verification and origin analysis across 175+ countries.
The Bigger Signal: No Single Alternative Origin Is Permanently Safe
The Brazil action does not stand alone, and importers now have several moving parts to track at once. It landed in the same window as the expiry of the Section 122 surcharge and the separate multi-country Section 301 forced-labour action at 10% or 12.5%. It is worth repeating that these are distinct: the Brazil 25% comes from Brazil’s own dedicated investigation and stands entirely apart from the multi-country forced-labour measure, which we cover in our guide to Section 301 tariffs 2026. Confusing them produces the wrong duty calculation.
But the strategic point is bigger than Brazil. This is the first major country-specific Section 301 tariff of the post-IEEPA era, arriving after the Supreme Court removed IEEPA as a tariff tool, which suggests the administration is leaning harder on Sections 301 and 232 to pursue objectives IEEPA can no longer serve.
For importers who spent the last few years diversifying away from China, the Brazil determination carries an uncomfortable lesson: no single alternative origin is permanently safe, and Brazil may be a template for future actions against other non-China sourcing markets as the same scrutiny applied to China extends to the countries that absorbed its redirected trade.
That is the real case for building on a compliant, flexible import structure rather than a single-country bet. The discipline that manages Brazil exposure today, defensible origin, accurate classification, and an importer of record that can operate wherever you source, is the same discipline that protects against the next country-specific action, wherever it lands. A business set up to move is a business that treats a tariff like this as a manageable decision. A business locked into one origin is exposed every time the map is redrawn.
Frequently Asked Questions: Brazil Section 301 Tariff 2026
Is the 25% Brazil tariff in effect now?
Yes. USTR finalised the action on 15 July 2026 and the 25% duty took effect at 12:01 a.m. ET on 22 July 2026, under HTSUS 9903.05.01. It is being collected now.
This is a change from the June 2026 position, when the tariff was still a proposal open for comment. That comment window has closed and the duty is live, so the priority now is confirming each product’s exemption status and deciding whether to absorb or move.
Which Brazilian goods are exempt from the 25% tariff?
Two categories: goods already covered by Section 232, and the products in Annex I, which include beef, orange juice, coffee, civil aircraft and parts, energy, and pharmaceutical-use articles. Exemptions turn on exact HTS subheading.
Apparel, footwear, electrical machinery, farm and mining equipment, paper, and organic sugar were specifically kept in scope. Coverage is at the subheading level, so each product’s classification must be checked against the annex to determine its status.
Does the Brazil tariff stack on other duties?
It stacks additively on standard Column 1 duty, antidumping and countervailing duties, and Section 122, but it does not stack on Section 232. Goods already subject to Section 232 are exempt from the Brazil action.
It may also stack with future Section 301 measures, including the separate forced-labour and overcapacity actions, so an exposed product could later face this duty plus another Section 301 tariff. Landed cost models should add the 25% to the existing stack.
How does the in-transit relief work?
It applies only to ocean freight, under heading 9903.05.02. Goods must have been loaded and in transit before 22 July, and entered for consumption before 12:01 a.m. ET on 29 July 2026. Both conditions apply.
A booking confirmation is not enough: CBP looks for the bill of lading and loading records proving the vessel was in transit before the cut-off. Air freight does not qualify, so any eligible ocean cargo at sea should be entered before the 29 July window closes.
Is the Brazil tariff the same as the 46-country Section 301 tariff?
No. The Brazil 25% duty comes from Brazil’s own dedicated Section 301 investigation into digital trade, tariffs, IP, ethanol, and deforestation. The multi-country 10% or 12.5% action is a separate forced-labour Section 301 measure.
The two are unrelated actions on different legal footings and should not be confused. Brazil’s rate is specific to Brazil, and a Brazilian product could in principle be affected by both if it also fell within the scope of the forced-labour action.
My Brazilian product is not exempt. Should I absorb the tariff or change source?
It depends on margin, volume, and whether a clean substitute exists. Confirm the classification, model the landed cost with the 25% added, then weigh absorbing it against sourcing elsewhere. For movable goods, moving often wins.
The practical barrier to moving is having an importer of record in the new market. Carra Globe acts as IOR across 175+ countries, so an alternative origin can be operated rather than just identified. Where goods are re-exported, drawback may also recover part of the duty.
For companies importing Brazilian-origin aerospace parts, industrial equipment, electrical components, apparel, or other goods, the 25% Section 301 tariff makes classification, origin, and sourcing strategy an immediate priority. Carra Globe’s Importer of Record services include HTS classification verification, country-of-origin analysis, landed cost modelling, and IOR cover across 175+ countries, so we can both defend your Brazilian entries and operate the alternative if you decide to move. To understand the full IOR role first, see our explainer on what an Importer of Record is and does.
This guide is for informational purposes only and does not constitute legal or customs advice. The Brazil Section 301 tariff, its exemption annex, and the in-transit provisions are subject to change as USTR and CBP issue further guidance. Always consult a licensed US customs broker or trade attorney before making classification, sourcing, or entry decisions.
Brazil Section 301 Tariff 2026: The 25% Duty Is Live, Where It Hits, and Where to Go Instead
Table of Contents
The Brazil Section 301 tariff 2026 is live. Since 12:01 a.m. Eastern Time on 22 July 2026, a 25% additional ad valorem duty has applied to most products of Brazil under HTSUS heading 9903.05.01. This is no longer a proposal or a comment window: it is a duty CBP is collecting right now.
So the question has changed. A month ago it was “will this happen, and can I influence it.” Today it is sharper and more commercial: do I absorb 25% on my Brazilian goods, or do I move, and if I move, where do I go and who acts as my importer of record there.
Most coverage of this tariff stops at the first half of that question. This guide answers both, because knowing a duty exists is not the same as knowing what to do about it. Below: exactly what is covered, which goods are carved out, how the narrow in-transit relief actually works at entry, and the sourcing alternatives if the maths no longer works.
Brazil Section 301 Tariff 2026: At a Glance
What the Final Brazil Section 301 Action Does
USTR initiated the Section 301 investigation into Brazil on 15 July 2025 at the direction of the President. Over the following year it held consultations with the Brazilian government, convened a two-day public hearing on 6 and 7 July 2026, and gathered more than 360 written comments and testimony from 77 witnesses. On 15 July 2026 the President issued a memorandum directing the action, and USTR published its Notice of Action the same day. CBP issued implementation guidance on 22 July under CSMS #69302472.
The investigation found six categories of Brazilian acts, policies, and practices to be unreasonable or discriminatory and to burden or restrict US commerce. These six findings are the legal foundation for the tariff:
One point to clear up early, because it is the single most common confusion: this is not the China tariff under a new name, and it is not the multi-country forced-labour action. It is Brazil’s own dedicated Section 301 tariff, on its own legal footing, arising from the six findings above. We come back to why that distinction matters for your duty stack below.
Which Brazilian Goods Are Exempt: The Two Carve-Outs
Carve-out 1: goods already covered by Section 232
Articles already subject to Section 232 tariffs are excluded from the Brazil Section 301 action. This covers steel, aluminium, copper and certain derivatives, autos and auto parts, specified vehicles, wood products, and semiconductor articles, all of which already carry Section 232 duties.
The 25% Section 301 duty does not stack on top of the Section 232 duty for these goods. For an importer of Brazilian steel or aluminium, the existing Section 232 exposure continues unchanged, but the new tariff does not add to it. The verification step is confirming a 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.
Carve-out 2: the Annex I exempt subheadings
The Final Notice includes an annex of specific HTS subheadings carved out of the duty. USTR retained nearly all the exemptions from its June proposal and added several after public comment. The exempt categories include beef, oranges and orange juice, coffee, civil aircraft and aircraft parts, jet engines and aerospace parts, energy products, pharmaceutical-use articles, vaccines, minerals, fertilizers, auto parts, iron ore pellets, aluminium oxide, wood products, spices, and dietary supplements.
CBP guidance also confirms carve-outs for certain religious-use products such as select foods and essential oils where supporting documentation is provided, humanitarian donations of food, clothing and medicine, and informational materials including books, films, artwork, and news media.
Just as important is what did not survive. The exemption list shifted right up to the wire. After testimony, USTR pulled dissolving pulp and narrowed the chemicals exemption to pharmaceutical use only, so non-pharmaceutical uses of those chemicals now face the full 25%. And it firmly shut the door on apparel, footwear, paper, electrical machinery, farm and mining equipment, and organic sugar, all of which are covered. The most exposed categories overall are general machinery, many industrial goods, sugar, apparel, and footwear.
The critical point is that every exemption is defined at the HTS-subheading level, not by broad product category. A company cannot assume its Brazilian goods are exempt because the general category appears in the annex, and it cannot assume they are covered either, because a closely related product in an adjacent subheading may fall the other way. The only reliable answer comes from matching each product’s exact HTS subheading against the published annex. Our HS Code Finder confirms the classification so it can be checked line by line.
How the Duty Stacks, and the In-Transit Relief That Trips Importers Up
Two mechanical points decide what you actually pay, and both are easy to get wrong at entry.
Stacking. The 25% Brazil duty is additive. It applies on top of the standard Column 1 duty rate, on top of any antidumping or countervailing duties, on top of Section 122, and on top of other applicable fees, unless the product is exempt.
The one thing it does not stack on is Section 232: goods already subject to Section 232 are carved out entirely. It may, however, stack with future Section 301 measures, including the separate forced-labour and overcapacity actions, so a Brazilian product could in principle face this duty plus a later Section 301 tariff. This is exactly why the “is this the China tariff” confusion is costly: they are different actions, and the wrong assumption produces the wrong number on the entry.
In-transit relief, and where it fails. There is a narrow grace period under heading 9903.05.02, and it applies only to ocean freight. To qualify, goods must have been loaded onto a vessel and in transit on their final mode before 12:01 a.m. ET on 22 July 2026, and must be entered for consumption, or withdrawn from warehouse, before 12:01 a.m. ET on 29 July 2026.
Both conditions must be met, and this is where importers lose the relief they thought they had. A purchase-order date or booking confirmation does not establish eligibility: CBP looks for the actual bill of lading, loading records, and arrival evidence proving the vessel was already in transit before the cut-off.
Air freight does not qualify at all. And missing the 29 July entry deadline by a single day forfeits the exemption on cargo that was otherwise eligible, which is a real and avoidable way to pay 25% you did not need to. For any water-borne cargo already at sea, the entire priority this week is getting it entered before the window closes.
One further operational trap: goods admitted to a US Foreign Trade Zone on or after 22 July must be admitted under privileged foreign status under 19 CFR 146.41 unless they qualify for domestic status, and Chapter 98 provisions do not all behave the same way, with repair, alteration, and assembly programmes under certain subheadings remaining partially subject to the duty. The entry-line sequence also matters: CBP has reminded filers to report the Section 301 Chapter 99 heading in the correct order relative to other Chapter 98 and 99 provisions. These are the details that separate a clean entry from a rejected one.
The 25% is being collected now, and the exemption turns on your exact subheading and a clean entry. The difference between an advisor and an operator is that we do not just tell you the rule, we file the entry, defend the origin, and model the alternative. Carra Globe acts as your importer of record in 175+ countries, which means we can also answer the question the tariff really raises: if Brazil no longer works, where next.
Check your Brazil exposure, and your alternatives →
The Real Decision: Absorb the 25%, or Move
This is the section most coverage of this tariff leaves out, and it is the one that actually costs or saves money. Once you know a product is exposed, you face a commercial choice, not just a compliance task. There are broadly three responses, and the right one depends on your margin and your volume.
If moving is the answer, the practical question is where, and who clears the goods for you there. The realistic alternative origins depend on the product. For machinery and industrial goods, other Latin American producers and parts of Southeast Asia are common substitutes. For footwear and apparel, which Brazil largely lost its exemption on, Vietnam, Indonesia, and India are the established alternatives. For agricultural and food products, the answer is category-specific and sometimes there is no clean substitute, which is itself useful to know before you waste time looking.
The catch every importer hits is that entering a new sourcing market means having an importer of record there, someone legally able to bring the goods in, hold the compliance, and pay the duty.
That is precisely the gap Carra Globe fills. We act as importer of record across 175+ countries, so the alternative origin you identify on paper is one we can actually operate, rather than a market you then have to go and solve from scratch. A law firm can tell you Brazil is expensive. A tariff calculator can tell you the rate. Neither can be your declarant in Vietnam next month. That is the difference between advice and a route out.
Who Is Exposed: Sector by Sector
Aerospace and aircraft parts
Brazil is a significant player in the global aerospace supply chain, and civil aircraft, jet engines, and aircraft parts are among the exemptions USTR retained. That is a meaningful carve-out, but it is not blanket. Map every Brazilian-origin part against its specific HTS subheading and confirm it falls within the civil aircraft exemption lines. A part that qualifies is protected; a closely related part outside the named subheadings may face the full 25%. The classification is the deciding factor.
Industrial machinery and electrical equipment
This is one of the most exposed areas, and CBP guidance confirms electrical machinery was specifically kept in scope. General industrial machinery, motors, and electrical equipment from Brazil are largely covered by the 25% duty, with machinery exempt mainly for civil aircraft use. A company importing Brazilian capital equipment or industrial components needs to verify each product’s classification individually, because the exemption is narrow and end-use dependent. For importers of industrial and electrical goods, this is where the real cost exposure sits, and where the “absorb or move” decision above bites hardest.
Steel, aluminium, copper, and heavy equipment
Goods already covered by Section 232, including steel, aluminium, copper and certain derivatives, autos and auto parts, and semiconductors, are excluded from the Brazil Section 301 duty. These importers continue to manage their existing Section 232 exposure, and the 25% does not add to it. The verification step is confirming a product genuinely falls under Section 232 rather than sitting in a gap. For the detail of the current Section 232 regime, see our guide to Section 232 full customs value 2026.
Apparel, footwear, and consumer goods
Apparel and footwear are squarely in scope: USTR declined to exempt them, so Brazilian-origin clothing and shoes now carry the full 25%. These are also among the most movable supply chains, which makes them the clearest candidates for the “move the source” response, with Vietnam, Indonesia, and India as established alternatives. Consumer goods more broadly are a mixed picture at the subheading level, so each line still has to be checked, but for exposed, price-sensitive apparel and footwear the sourcing question is usually the real one.
Agriculture, ethanol, and food
Agricultural and food categories fared relatively well. Beef, oranges and orange juice, coffee, and a range of other food products are carved out, and hundreds of additional agricultural lines were removed after industry comment. But the picture is mixed: sugar, notably, remains exposed, and each food category carries a distinct classification that must be checked individually. Where a food input has no clean alternative source, absorbing the duty may be the only option, which is exactly why knowing the classification and the substitute landscape early is worth the effort.
Why an IOR and Origin Verification Are Decisive Here: Operators, Not Just Advisors
A country-specific 25% tariff turns two routine parts of compliant importing into high-value determinations: accurate country-of-origin determination and accurate HTS classification. Both sit at the heart of the Importer of Record’s responsibility, and both now carry 25 percentage points of duty on the outcome. This is where the distinction between a firm that explains the tariff and a firm that clears the shipment stops being marketing and starts being money.
Country of origin is the first pressure point. A 25% duty on goods of Brazil makes origin commercially critical. Goods finished in Brazil from components sourced elsewhere, or routed through Brazil, raise substantial transformation questions that were once a routine documentation step and are now a high-value determination, because the difference between Brazilian origin and another origin is 25 percentage points.
From the operator’s side of the desk, this is the moment CBP scrutiny actually lands: an origin claim on a Brazilian entry now needs to be backed by bill-of-materials and manufacturing evidence that will survive a request for information, not just a supplier’s assertion on a commercial invoice. The IOR named on the entry owns that declaration and its defence.
HTS classification is the second. With exemptions defined at the subheading level, the precise classification of each product determines whether the duty applies at all. A classification that places a product in an exempt subheading avoids the duty; an error that places it in a covered one 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, and it is the tedious, line-by-line work that a licensed operator does as routine and an advisor simply flags. For the broader enforcement environment that makes this non-negotiable, see our guide to the CBP customs audit landscape in 2026.
What Importers of Brazilian Goods Must Do Now
The Bigger Signal: No Single Alternative Origin Is Permanently Safe
The Brazil action does not stand alone, and importers now have several moving parts to track at once. It landed in the same window as the expiry of the Section 122 surcharge and the separate multi-country Section 301 forced-labour action at 10% or 12.5%. It is worth repeating that these are distinct: the Brazil 25% comes from Brazil’s own dedicated investigation and stands entirely apart from the multi-country forced-labour measure, which we cover in our guide to Section 301 tariffs 2026. Confusing them produces the wrong duty calculation.
But the strategic point is bigger than Brazil. This is the first major country-specific Section 301 tariff of the post-IEEPA era, arriving after the Supreme Court removed IEEPA as a tariff tool, which suggests the administration is leaning harder on Sections 301 and 232 to pursue objectives IEEPA can no longer serve.
For importers who spent the last few years diversifying away from China, the Brazil determination carries an uncomfortable lesson: no single alternative origin is permanently safe, and Brazil may be a template for future actions against other non-China sourcing markets as the same scrutiny applied to China extends to the countries that absorbed its redirected trade.
That is the real case for building on a compliant, flexible import structure rather than a single-country bet. The discipline that manages Brazil exposure today, defensible origin, accurate classification, and an importer of record that can operate wherever you source, is the same discipline that protects against the next country-specific action, wherever it lands. A business set up to move is a business that treats a tariff like this as a manageable decision. A business locked into one origin is exposed every time the map is redrawn.
Frequently Asked Questions: Brazil Section 301 Tariff 2026
Is the 25% Brazil tariff in effect now?
Yes. USTR finalised the action on 15 July 2026 and the 25% duty took effect at 12:01 a.m. ET on 22 July 2026, under HTSUS 9903.05.01. It is being collected now.
This is a change from the June 2026 position, when the tariff was still a proposal open for comment. That comment window has closed and the duty is live, so the priority now is confirming each product’s exemption status and deciding whether to absorb or move.
Which Brazilian goods are exempt from the 25% tariff?
Two categories: goods already covered by Section 232, and the products in Annex I, which include beef, orange juice, coffee, civil aircraft and parts, energy, and pharmaceutical-use articles. Exemptions turn on exact HTS subheading.
Apparel, footwear, electrical machinery, farm and mining equipment, paper, and organic sugar were specifically kept in scope. Coverage is at the subheading level, so each product’s classification must be checked against the annex to determine its status.
Does the Brazil tariff stack on other duties?
It stacks additively on standard Column 1 duty, antidumping and countervailing duties, and Section 122, but it does not stack on Section 232. Goods already subject to Section 232 are exempt from the Brazil action.
It may also stack with future Section 301 measures, including the separate forced-labour and overcapacity actions, so an exposed product could later face this duty plus another Section 301 tariff. Landed cost models should add the 25% to the existing stack.
How does the in-transit relief work?
It applies only to ocean freight, under heading 9903.05.02. Goods must have been loaded and in transit before 22 July, and entered for consumption before 12:01 a.m. ET on 29 July 2026. Both conditions apply.
A booking confirmation is not enough: CBP looks for the bill of lading and loading records proving the vessel was in transit before the cut-off. Air freight does not qualify, so any eligible ocean cargo at sea should be entered before the 29 July window closes.
Is the Brazil tariff the same as the 46-country Section 301 tariff?
No. The Brazil 25% duty comes from Brazil’s own dedicated Section 301 investigation into digital trade, tariffs, IP, ethanol, and deforestation. The multi-country 10% or 12.5% action is a separate forced-labour Section 301 measure.
The two are unrelated actions on different legal footings and should not be confused. Brazil’s rate is specific to Brazil, and a Brazilian product could in principle be affected by both if it also fell within the scope of the forced-labour action.
My Brazilian product is not exempt. Should I absorb the tariff or change source?
It depends on margin, volume, and whether a clean substitute exists. Confirm the classification, model the landed cost with the 25% added, then weigh absorbing it against sourcing elsewhere. For movable goods, moving often wins.
The practical barrier to moving is having an importer of record in the new market. Carra Globe acts as IOR across 175+ countries, so an alternative origin can be operated rather than just identified. Where goods are re-exported, drawback may also recover part of the duty.
For companies importing Brazilian-origin aerospace parts, industrial equipment, electrical components, apparel, or other goods, the 25% Section 301 tariff makes classification, origin, and sourcing strategy an immediate priority. Carra Globe’s Importer of Record services include HTS classification verification, country-of-origin analysis, landed cost modelling, and IOR cover across 175+ countries, so we can both defend your Brazilian entries and operate the alternative if you decide to move. To understand the full IOR role first, see our explainer on what an Importer of Record is and does.
This guide is for informational purposes only and does not constitute legal or customs advice. The Brazil Section 301 tariff, its exemption annex, and the in-transit provisions are subject to change as USTR and CBP issue further guidance. Always consult a licensed US customs broker or trade attorney before making classification, sourcing, or entry decisions.