Brazil's New 25% Section 301 Tariff: What Importers Need to Know

Brazil had been one of the few major US trading partners where most goods entered at MFN rates with no additional duty layer on top. That ended July 22, 2026.

At 12:01 a.m. ET that morning, a 25% additional ad valorem duty took effect on most goods of Brazilian origin, under a new Section 301 action initiated twelve months earlier. The rate stacks on top of the applicable column 1 general rate. For goods that previously entered Brazil at MFN rates of 0–5%, the cost impact is immediate and material. For importers who hadn't been watching the proceeding closely, this is a hard surprise.

The exclusions matter. USTR carved out a substantial set of product categories: over 1,600 HTSUS subheadings. Getting them right determines whether your specific entries are affected at all.

What Triggered the Investigation

USTR initiated the Section 301 investigation on July 15, 2025 under the Trade Act of 1974 (19 USC § 2411), covering six categories of Brazilian trade practices it determined were unreasonable and burdened US commerce:

Digital trade and electronic payment services. The most publicly prominent trigger. Brazil's Pix instant payment system, operated by the Banco Central do Brasil, is free to all users by regulatory mandate and achieved near-universal adoption. US financial networks argued this mandated zero-cost interoperability effectively displaced their services from the Brazilian market. USTR agreed it constituted an unreasonable trade practice.

Unfair or preferential tariffs. Brazil's tariff structure favors certain trading partners in ways USTR found discriminatory toward US exporters.

Anti-corruption enforcement. Concerns about interference with prosecutorial mechanisms that affect US companies operating in Brazil.

Intellectual property protection. Inadequate enforcement of patent and copyright protections for US rightsholders.

Ethanol market access. Brazilian pricing policies and import barriers on US corn-based ethanol.

Illegal deforestation. Trade advantages embedded in Brazilian land-use policies linked to unlawful clearing in the Amazon and Cerrado regions.

The preliminary determination was published in the Federal Register on June 4, 2026 (document 2026-11158). The final action notice was published July 20, 2026 (document 2026-14542), with a two-day window before the effective date.

What's Covered and What's Not

The exclusion list is substantial, and several of Brazil's most significant US export categories are on it.

Excluded from the 25% duty:

Beef — both fresh/chilled and frozen, covering one of Brazil's largest agricultural exports to the US
Orange juice — including FCOJ and NFC, where Brazil supplies the dominant share of US imports
Coffee — including unflavored instant coffee; other coffee products are largely exempt
Organic honey — added in response to public comment
Certain seafood products
Civil aircraft and parts — approximately 430 HTSUS subheadings covering commercial airframes, jet engines, and aerospace components; this protects Embraer deliveries, which represent a large slice of Brazilian aerospace exports
Pharmaceutical products — finished dosage forms and active pharmaceutical ingredients (APIs)
Energy products — crude petroleum, refined petroleum products, LNG, and related categories
Pig iron, iron and steel scrap — added after the public comment period specifically because these materials aren't available in adequate volumes domestically or from alternative sources
Goods already subject to Section 232 measures — steel (25%), aluminum (10%), copper, and heavy equipment categories covered by Section 232 are excluded to prevent double-stacking with those existing duties
Humanitarian donations, informational materials, personal baggage

The practical effect: the major Brazilian export categories that dominate US import flows from Brazil (aerospace, metals under Section 232, beef, citrus, coffee, petroleum) are largely protected. Brazil's agricultural and energy export base faces minimal disruption.

What is covered is everything outside those carve-outs. Footwear, apparel, paper and paperboard, furniture, tobacco products, vehicles (other than those covered by Section 232 heavy equipment provisions), chemical products outside the pharmaceutical exclusion, and machinery not under Section 232. These categories were previously paying only column 1 MFN rates.

The cost shift is concrete. Brazilian footwear carrying a 9% MFN rate now faces 34% combined. Paper products entering at 0–3% MFN now face 25–28%. Chemical intermediates at 5.5% move to 30.5%. For supply chains built around Brazilian sourcing in these categories, the landed cost math changed as of July 22.

The In-Transit Window

There's limited relief for goods already moving at the effective date. Two conditions must both be met to qualify:

The goods were loaded on the final vessel before 12:01 a.m. ET on July 22, 2026.
The goods were entered for consumption (or withdrawn from warehouse) before 12:01 a.m. ET on July 29, 2026.

Both are required. Goods sitting at a transshipment port awaiting loading as of July 22 don't qualify regardless of how early they left Brazil. And July 29 is a hard close: entries after that date pay 25% even if the shipment predates the effective date.

Importers with Brazilian-origin entries currently in transit should check bill of lading dates against these conditions and alert their brokers to prioritize timely entry.

The Duty Stack

Brazil has no free trade agreement with the United States. Until July 22, most Brazilian goods entered at MFN rates with no additional layers. The IEEPA "Liberation Day" tariffs that briefly applied to Brazilian goods were vacated after the Supreme Court's ruling in Learning Resources, Inc. v. Trump, No. 24-1287 (2026), which found IEEPA doesn't authorize tariff imposition. Brazil was not subject to any prior Section 301 action.

So the calculation for covered Brazilian-origin goods is straightforward:

Column 1 MFN rate + 25% = combined duty rate

No IEEPA layering. No separate Section 301 China exposure. No AD/CVD unless a specific order covers the product and the goods meet the scope. The 25% is the only additional layer, but it's applied on top of what were, for many categories, near-zero duties.

What to Do Now

Map your HTS codes against the exclusion list. The Federal Register notice (document 2026-14542) contains the complete list of covered and excluded HTSUS subheadings. If you haven't already done this for every Brazilian-origin entry in your pipeline, it's the immediate priority. Your broker may have already flagged the impacted lines, but verify.

Confirm country of origin on all affected entries. The duty applies to goods "of Brazil," meaning goods with Brazilian origin under the substantial transformation standard. Goods manufactured in a third country and shipped through Brazil without substantial transformation aren't Brazilian-origin. But goods manufactured in Brazil and shipped through third countries still are.

Include the Chapter 99 subheading. Like all Section 301 tariffs, the Brazil duty flows through a Chapter 99 HTSUS subheading. Entries for Brazilian-origin goods must include the applicable Chapter 99 number alongside the regular 10-digit HTS code. Missing it typically results in CBP rejection or a request for information.

Reassess sourcing alternatives in non-excluded categories. For footwear, furniture, paper, or similar categories where Brazil was a primary source, the 25-percentage-point addition likely triggers a sourcing review. Our Brazil trade and tariff overview covers the broader context of US-Brazil trade flows. Other supply alternatives — Vietnam, India, Indonesia — now carry their own additional duties under the Section 301 forced labor tariffs that took effect July 24, but at 10–12.5% rather than 25%.

Look up the exact base rate and full duty stack for any HTS code using the HTS lookup tool before making sourcing decisions. For all country-of-origin comparisons, TariffClassify shows the full overlay including all applicable Section 301 duties.

Key Takeaways

A 25% additional ad valorem duty applies to most goods of Brazilian origin entered on or after July 22, 2026, 12:01 a.m. ET.
Over 1,600 HTSUS subheadings are excluded: beef, orange juice, coffee, pig iron, ferrous scrap, energy products, civil aircraft (430+ lines), pharmaceutical products, and all goods already subject to Section 232 measures.
The in-transit window requires (1) loading on the final vessel before July 22 AND (2) entry before July 29. Both conditions must be satisfied.
Brazil has no FTA with the US. With IEEPA tariffs vacated, the duty stack for covered goods is simply column 1 MFN rate plus 25%.
The legal authority is the Trade Act of 1974. USTR found six categories of unreasonable Brazilian practices, including Pix payment system policies, IP enforcement failures, and illegal deforestation.
Customs entries for Brazilian-origin goods must include the applicable Chapter 99 HTSUS subheading. Coordinate with your broker to ensure classification is updated.

The full duty stack for Brazilian-origin goods — base rate, Section 301, AD/CVD — is visible in TariffClassify for any product. Try your first classification free.