USTR is imposing an additional 25% Section 301 duty on most products of Brazil entered for consumption, or withdrawn from warehouse for consumption, at or after 12:01 a.m. Eastern time on July 22, 2026. A narrow vessel-in-transit exception runs through July 28. Section 232 goods and products listed in the final notice’s annexes are exempt. Importers should verify the exact HTS and Chapter 99 line before assuming coverage or exclusion.
This is a final action, not a proposal. USTR published the action on July 15 after reviewing more than 360 submissions and testimony from 77 witnesses. For a covered product, the new duty can materially change landed cost on entries filed from July 22 onward—even if the purchase order, invoice, or vessel departure occurred earlier.
The controlling questions are: Is the merchandise a product of Brazil? What HTS subheading will be declared? Is that exact line exempt? When will the merchandise be entered for consumption or withdrawn from warehouse? Arrival date alone does not answer the duty question.
What changed
| Rule | Importer impact |
|---|---|
| Additional duty | 25% on covered Brazilian-origin goods, in addition to the ordinary duty and other applicable charges. |
| Effective time | 12:01 a.m. ET on July 22, 2026, based on entry for consumption or withdrawal from warehouse for consumption. |
| Vessel transition | Brazil-origin goods loaded onto a vessel and in transit before the effective time can use heading 9903.05.02 if entered or withdrawn before 12:01 a.m. ET on July 29, 2026. |
| General scope | Most products of Brazil, subject to statutory and Annex-listed exemptions. |
| Section 232 treatment | Articles and parts already subject to Section 232 tariffs are exempt from this Section 301 action. |
| Foreign-trade zones | Covered goods admitted after the effective date generally require privileged foreign status unless eligible for domestic status. |
Which products are exempt?
The action does not apply uniformly to every shipment from Brazil. It exempts informational materials, donations, accompanied baggage, articles and parts subject to Section 232 duties, and products listed in Annexes I and II of the final notice.
USTR’s public summary identifies broad excluded areas including beef, orange juice, aircraft and aircraft parts, and energy products. The final notice also describes expanded exemptions for specific categories such as certain pharmaceuticals and ingredients, wood products, seafood, iron and steel scrap, pig iron, unflavored instant coffee, organic honey, used clothing, antiques and art, and certain hides and leather.
An industry label such as “wood,” “coffee,” or “pharmaceuticals” is not enough. Coverage turns on the exact tariff subheading and any product-use limitation in the annex. Some chemical exemptions, for example, are limited to pharmaceutical applications.
How to decide whether your shipment is covered
- Confirm Brazilian origin. The seller’s country, invoice address, and shipping point do not necessarily establish country of origin. Review where the substantial transformation occurred.
- Confirm the HTS classification. Match the declared subheading to the final notice’s Annex I and Annex II tables and notes.
- Check for Section 232 treatment. A product or part subject to Section 232 is exempt from this separate Section 301 action, but the Section 232 duty can still apply.
- Map the entry date. Determine when the goods will be entered for consumption or withdrawn from warehouse—not merely when they sail or arrive.
- Recalculate landed cost. Add the 25% layer to the ordinary duty and any other applicable charges that are not excluded.
Entry timing: July 22 is the operative line
The final notice ties the duty to entries for consumption and warehouse withdrawals at or after 12:01 a.m. Eastern time on July 22. It also provides a narrow transition under heading 9903.05.02: goods must be loaded onto a vessel at the port of loading and in transit before the effective time, then entered for consumption or withdrawn from warehouse before 12:01 a.m. Eastern time on July 29. The text says vessel; importers should not assume the same transition applies to air cargo without CBP guidance.
An importer with goods already on the water should review the bill of lading, loading time, planned entry type, and expected entry date now. Rushing an entry, changing warehouse strategy, or altering declarations without a defensible operational basis can create separate compliance risk.
Foreign-trade-zone treatment
Covered Brazilian goods admitted into a U.S. foreign-trade zone on or after the effective date generally may be admitted only in privileged foreign status under 19 C.F.R. § 146.41, unless the merchandise qualifies for domestic status under 19 C.F.R. § 146.43. This is a timing and status rule, not a tariff-avoidance route: the privileged status follows the merchandise when it is later entered for consumption. Coordinate the status before admission, not after the fact.
Does the 25% stack with other duties?
For covered products, the Section 301 duty is additional to the ordinary Chapter 1–97 duty and other applicable Chapter 99 duties, taxes, fees, anti-dumping duties, and countervailing duties. The final action exempts products actually provided for in the listed Section 232 headings; it does not create a blanket exemption for every downstream metal, vehicle, wood, or semiconductor-related product.
Most properly claimed Chapter 98 entries are carved out, but headings 9802.00.40, 9802.00.50, 9802.00.60, and 9802.00.80 use partial-value rules described in the notice. Ordinary drawback may remain available when the statutory requirements are met, but importers should not promise recovery until CBP confirms the entry coding and claim treatment.
Use the entry line, not a product-level average. Two products from the same supplier can have different results if one HTS line is excluded and the other is covered.
Importer checklist before July 22
- Export the last 12 months of Brazilian-origin entry lines by HTS code, value, supplier, and port.
- Match each HTS line against Annex I and Annex II of USTR’s final notice.
- Separate products subject to Section 232 from products potentially covered by the new Section 301 duty.
- Review country-of-origin support for goods processed in more than one country.
- Identify entries and warehouse withdrawals expected on or after July 22, and separately document any shipment claiming the vessel-in-transit transition through July 28.
- Confirm FTZ admission status for covered goods.
- Reprice exposed purchase orders and customer commitments using the entry-line duty stack.
Know your Brazil exposure before July 22.
Send us your Brazilian supplier list, HTS codes, and upcoming entry dates. We will separate covered lines from exemptions and map the landed-cost impact before the first affected entry.
- HTS and Annex exemption review
- Origin and entry-timing check
- Section 232 overlap review
- Entry-line landed-cost model
Frequently asked importer questions
When does the 25% Brazil Section 301 tariff start?
The additional duty applies to covered Brazilian-origin goods entered for consumption, or withdrawn from warehouse for consumption, at or after 12:01 a.m. Eastern time on July 22, 2026. Importers should review the entry date and status, not only the vessel arrival date.
Is there an in-transit exception for shipments already moving?
Yes, but it is narrow. Brazil-origin goods must have been loaded onto a vessel and in transit before 12:01 a.m. Eastern time on July 22, 2026, and must be entered for consumption or withdrawn from warehouse before 12:01 a.m. Eastern time on July 29. Do not assume the vessel wording covers air cargo.
Does the 25% tariff apply to every product from Brazil?
No. The action covers most Brazilian-origin goods, but it exempts products subject to Section 232 tariffs, informational materials, donations, accompanied baggage, and the products listed in Annexes I and II of USTR’s final notice. Exemption must be confirmed against the exact HTS line and applicable notes.
Which Brazilian products are exempt from the new tariff?
USTR’s exclusions include many Annex-listed products. Broad examples identified by USTR include beef, orange juice, aircraft and parts, and energy products, plus additional categories such as certain pharmaceuticals, wood products, seafood, pig iron, unflavored instant coffee, organic honey, used clothing, and other specifically listed goods. The exact HTS subheading controls.
Are Section 232 goods from Brazil also charged the new 25% Section 301 tariff?
No. The final action exempts articles and parts already subject to Section 232 tariffs. Importers still need to confirm that the precise product and entry line qualify for the Section 232 exemption.
How are covered Brazilian goods treated in a U.S. foreign-trade zone?
Covered Brazilian goods admitted to a U.S. foreign-trade zone on or after the effective date generally must enter in privileged foreign status under 19 C.F.R. 146.41, unless eligible for domestic status. Importers should coordinate FTZ status before admission.
The bottom line
Most Brazilian-origin goods face an additional 25% duty beginning July 22, but the exemption list is broad and technical. The winning move is not to assume every Brazil shipment is covered—or exempt. It is to match origin, HTS classification, entry timing, and the final annex before the entry is filed.
Primary sources: USTR, “USTR Takes Section 301 Action on Brazil’s Unreasonable Acts, Policies, and Practices”, July 15, 2026; USTR, “Notice of Action: Brazil’s Acts, Policies, and Practices…”, July 15, 2026, including Annexes I and II. This operational guide is current as of July 18, 2026 and is not legal advice. Confirm the final notice and exact HTS line before filing.