Tariffs · BR → EU
The US tariff on Brazil is now signed, not proposed — and the exemption list moved
Jul 21, 2026 · 6 min read
In short
On 15 July 2026 the USTR published its final notice under Section 301, confirming a 25% tariff on Brazilian goods, effective 00:01 ET on 22 July 2026. The final exemption list broadly follows the June draft — goods already covered by Section 232 (steel, aluminium, copper, autos, wood, semiconductors), civil aircraft and parts, pharmaceutical-use articles, humanitarian donations — plus named carve-outs for beef, coffee, rare-earth materials and energy products. Two specifics moved between draft and final rule: high-purity dissolving pulp lost its exemption, while pig iron, explicitly excluded from relief in the June proposal, was added to the final exemption list. Separately, a broader US Section 301 investigation into forced labour, covering roughly 60 economies, is expected to conclude around 24 July and could add a further 10-12.5% for Brazil on top of the 25%, pushing exposed goods toward a 37.5% ceiling. None of this changes the underlying logic set out in our earlier note: EU-Mercosur's day-one tariff cuts are live now, independent of what Washington decides.
On 15 July 2026 the Office of the US Trade Representative published its final notice of action under Section 301, confirming the 25% tariff on Brazilian goods first proposed in June. The measure takes effect at 00:01 ET on 22 July 2026. That resolves the uncertainty we flagged in our earlier brief on the proposal stage: this is no longer a draft open for comment, it is a signed rule with a fixed start date.
The final exemption list broadly tracks the June draft. Goods already carrying Section 232 duties are excluded to avoid double-counting — steel, aluminium, copper and their derivatives, passenger and heavy-duty vehicles, wood products and semiconductors — alongside civil aircraft and parts, pharmaceutical-use articles, humanitarian donations and informational materials. USTR also named specific carve-outs: beef, coffee, rare-earth materials and a range of energy and oil-and-gas products are spared, despite beef and deforestation-linked commodities having featured directly in the underlying investigation.
Two changes between the June draft and the final text are worth flagging on their own, because they show that the specifics moved and an exporter's June reading of the annex may no longer hold. High-purity dissolving pulp, exempted in the proposal, lost that exemption in the final rule. Pig iron ran the other way: explicitly left off the exemption lists in June, it was added to the final list. The practical step is to re-check your own HTS codes against the final Federal Register notice, not the draft you may have reviewed a month ago.
A second, separate track adds a further layer of uncertainty. USTR's broader Section 301 investigation into forced labour in import supply chains, covering roughly 60 economies, proposed tariffs of 10-12.5% for the countries involved and is expected to conclude around 24 July 2026 — tied to the expiry of a Section 122 stopgap tariff. Brazil sits inside that investigation too, and a finding against it would stack on top of the 25% already in force, pushing the ceiling on affected goods toward 37.5%. As with the main measure, this would layer on top of any existing anti-dumping or countervailing duties rather than replace them.
None of this changes the arithmetic we set out when the tariff was still a proposal: the EU-Mercosur trade pillar has applied provisionally since 1 May 2026, so its day-one duty cuts are live and available now, entirely independent of what Washington decides on forced labour or anything else. What has changed is that the US side of the comparison is no longer a forecast. An exporter can now model a real US landed cost against a real EU landed cost, for actual HTS and CN codes, rather than a proposed one against a provisional one.
The useful work this week is comparative and current: confirm which of your product lines sit inside the final exemption list, watch for the forced-labour determination due within days, and re-run the EU-versus-US landed-cost comparison now that the US number is fixed rather than pending. A short Opportunity Scan can map your goods against the EU regime, flag the certification it requires, and size the difference while the US picture is still settling.
Business intelligence, not legal or tax advice.