Executive summary

For businesses in Brazil considering the implications of the United States Trade Representative's 15 July 2026 Notice of Action on Section 301 tariffs, noting which goods are affected, and which will not, will be important.

(For background, see EY Global Tax Alerts: USTR issues Notice of Action imposing 25% Section 301 tariffs on imports from Brazil, effective 22 July 2026, dated 16 July 2026; and Brazilian exporters consider how to navigate ongoing tariff instability in light of new US tariffs, dated 24 June 2026.)

New 25% tariffs

The latest United States (US) 25% tariffs on Brazil-origin goods, imposed under Section 301 of the US Trade Act of 1974, apply to products entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on 22 July 2026. The additional 25% duty applies to all products of Brazil that are not identified in Annexes I and II to the Notice of Action. Products already subject to tariffs imposed under Section 232 of the US Trade Expansion Act of 1962 are exempt from the Section 301 duty imposed by the Notice of Action, preventing the stacking of Section 301 duties with Section 232 measures. Other tariff measures, including other Section 301 tariffs, will stack with the additional 25% duty under this action. Informational materials, donations and accompanied baggage are excluded.

Some products initially listed as those that could be subject to additional duty have been excluded, including soluble coffee, orange juice, chemicals and bovine meat. Sectors related to shoes, textiles, machinery and equipment remained on the sanction list, indicating that a new 25% tariff will apply in addition to the current duties.

The US government is also investigating several countries for failing to restrict imports of products allegedly manufactured using forced labor, with the possibility of imposing additional tariffs of 10% or 12.5%. If this investigation were extended to imports from Brazil, the effect known as tariff "stacking" could arise, meaning the accumulation of tariffs (e.g., 25% + 12.5%, resulting in 37.5%).

Implications

Businesses in Brazil should consult with knowledgeable tax professionals to review affected product classifications, assess possible exposure to tariff stacking and consider modeling the commercial effect of the additional duties.