USTR Imposes 25% Section 301 Tariffs on Most Brazilian Imports Effective July 22
U.S. importers of Brazilian-origin goods must immediately assess tariff exposure and compliance obligations to avoid unexpected costs, customs penalties, and supply chain disruptions.
On July 15, the USTR finalized a 25% Section 301 tariff on most Brazilian-origin imports, effective July 22, addressing actionable concerns including digital trade barriers, unfair ethanol market access, illegal deforestation, and inadequate intellectual property protection. The rule includes HTSUS-specific product exclusions for categories such as pharmaceuticals, medical devices, certain agricultural goods, and select industrial inputs, but eligibility requires careful review of Federal Register annexes to avoid incorrect claims. Importers face heightened CBP scrutiny for classification, country-of-origin, and transshipment compliance, plus increased duty costs, potential customs bond insufficiency, and supply chain disruption risks for goods with limited alternative sourcing. In-house counsel should prioritize product-level tariff exposure assessments, review of supply and intercompany contracts for duty allocation terms, and updates to customs compliance protocols.