Alert

USTR Announces Final Section 301 Tariff Action on Brazil

July 16, 2026

On July 15, 2026, the Office of the U.S. Trade Representative (USTR) announced a final tariff action of 25% on certain goods from Brazil. This action is the result of USTR’s Section 301 investigation on Brazil’s acts, policies, and practices related to unfair digital trade and electronic payment services; unfair, preferential tariffs; insufficient anticorruption enforcement; insufficient intellectual property protections; failure to provide reciprocal ethanol market access; and illegal deforestation.

The new tariffs will go into effect on July 22, 2026. At that time, it will be in addition to the 10% tariff imposed on Brazil and other countries under Section 122 of the Trade Act of the Trade Act of 1974, which are set to expire on July 24, 2026. This action will exclude any products subject to tariffs imposed under Section 232 of the Trade Expansion Act.

USTR had issued a proposed tariff action with respect to the investigation on June 1, 2026, and after taking public comments and holding a hearing on the action, adjusted the products covered by the 25% tariff. USTR removed high-purity dissolving pulp from the exemption list and limited the availability of exemptions for certain chemicals to pharmaceutical applications. USTR also added certain products to the list of those exempt from the 301 tariff action, including: aluminum hydroxide; antiques, collectibles, and art; ash containing precious metals or precious metal compounds; certain animal hides, furskins, and leather; certain seafood products; certain additional pharmaceuticals and pharmaceutical ingredients; certain additional wood products; iron and steel waste and scrap; organic honey; pig iron; unflavored instant coffee; and used clothing. 

The remaining coverage and structure of the tariff action is consistent with the proposal. This includes exemptions for products covered by Section 232 tariff actions and products that USTR had identified as:

  1. Raw materials that if subject to these tariffs could lead to the unavailability of domestic supply;
  2. Products that could cause economy-wide disruptions if subject to these tariffs;
  3. Products that cannot be grown or produced in sufficient quantities or at reasonable prices in the United States or obtained from other sources; or
  4. Articles for which these tariffs may not contribute substantially to the elimination of the acts, policies, and practices of Brazil found to be actionable in the investigation.

Wiley’s International Trade practice has deep experience advising clients on the rapidly evolving tariff landscape. Should you have any questions, please contact one of the listed attorneys on this alert.

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