Brazil’s 25% Section 301 Tariff: What Importers Must Know Before July 22

Executive Summary  

Beginning at 12:01 a.m. Eastern time on July 22, 2026, products of Brazil not covered by an exemption are subject to an additional 25% ad valorem duty under HTSUS 9903.05.01. A narrow in-transit exception applies only to qualifying vessel cargo loaded and in transit before the effective time and entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. Eastern time on July 29. Exemptions depend on exact HTS classifications and descriptions, not broad product categories.

Intro

At 12:01 a.m. Eastern on July 22, 2026, a flat 25% tariff lands on just about everything coming out of Brazil. It doesn’t ease in, and it won’t wait, so from that minute on, the date your freight clears customs is the difference between paying it and not. These Section 301 tariffs are hours away, and they’re final.

This didn’t come out of nowhere. The president told USTR to act, and USTR made it official in a Federal Register notice under Section 301 of the Trade Act of 1974. It caps off a yearlong investigation into six things Washington says Brazil does wrong, from digital trade barriers to illegal deforestation.

We’ve been following this since the first filing, and we’ll keep our trade and tariff coverage updated as it moves. This is the plain-English version of where things stand and what to do next.

Inside the New Section 301 Tariff on Brazilian Imports

It all comes down to one line on a customs entry: HTSUS 9903.05.01. The 25% kicks in the moment your Brazilian goods clear customs or leave a bonded warehouse on July 22 or later. There’s no phase-in, so you’re paying full price from your very first shipment.

It wasn’t a snap decision, either. USTR spent close to a year on it, with public hearings and 360-plus comments from companies like yours. Its announcement lists six complaints against Brazil: 

1. Digital trade rules
2. Weak IP protection
3. Preferential tariffs
4. Thin anti-corruption enforcement
5. Ethanol access
6. Illegal deforestation

One thing worth clearing up: This isn’t the China tariff wearing a new label. It’s its own action, separate from the 46-country Section 301 measure and the Section 122 fight from our China List 3 and 4A and Section 122 stay posts. The new importer-of-record rules are their own headache.

Which Brazilian Goods Face the 25% Duty and Which Are Exempt

Plenty of importers assume they’re fine because their product seems ordinary. Almost nothing from Brazil is exempt by default. The Federal Register notice lists what’s spared across a few annexes: 

• Beef
• Coffee
• Orange juice
• Aircraft and parts
• Pharmaceuticals
• Certain energy products
• Informational materials
• Section 232 goods.

That list isn’t set in stone, either. It shifted right up to the wire. USTR pulled dissolving pulp and non-pharmaceutical chemical uses after hearing testimony, then shut the door on apparel, footwear, steel, paper, electrical machinery, farm and mining equipment, and organic sugar.

So don’t go by your product category. It’s the exact HTS code that decides, line by line, and getting it right is the tedious work a licensed customs broker does for you. If you’re bringing in agricultural or textile goods or cosmetics and chemicals, check every code against the annexes before you file.

The In-Transit Grace Period: Why Your Loading Date Decides Your Duty

If your container’s already at sea, you catch a small break, but check the dates before you relax. Your goods dodge the 25% only if they were loaded and sailing before 12:01 a.m. ET on July 22, then cleared for entry before 12:01 a.m. ET on July 29. 

Miss either window and you pay.

This break only helps ocean shipments: anything arriving by air, truck, or rail pays the duty, no matter when it left Brazil.

Foreign-Trade Zones have their own rules. Goods going into an FTZ have to enter under privileged foreign status, which locks your rate the day they land. Once your freight’s on the water, the entry date is the one lever you’ve still got, so keep ocean freight and warehousing in sync and lean on our ocean delay guide for the timing.

Stacked Duties and Landed Cost: How the Tariff Hits Your Bottom Line

What stings is that this 25% doesn’t replace anything you already pay. It stacks on top. KPMG confirms it sits above your regular duties, fees, and any antidumping or countervailing order already on the product. If you’re under one of those, you’re now paying it plus 25%, and your margin takes the hit.

Don’t count on the usual escape hatches, either, because there aren’t any. No de minimis threshold, no phase-in, no exclusion process to apply for. Chapter 98 entries mostly stay clear, though a few assembly and repair provisions still owe duty on the value of the foreign work.

You’re not totally stuck, though. Section 301 duties usually qualify for drawback once you re-export, so good trade management and compliance work claws some of it back. Pair it with multimodal routing and the live cost view in myMALLORY, and you’re actually managing this instead of just watching it hit.

Your Pre-July 22 Action Plan for Brazilian Imports

Knowing the cost is only half the job. The rest is getting ahead of it before the 22nd, and there’s not much runway left. Troutman’s breakdown matches what we tell our own clients, so these are the five moves to make now.

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• Check Every HTS Code: Go line by line and match each product to the exemption annexes, since your product category won’t tell you whether you’re hit or exempt. That’s tedious work, and it’s exactly where we keep clients out of trouble.
• Run Your Real Landed Cost: Add the 25% to every affected product, not just your top sellers, so you can see your true exposure before the invoices land. Small-volume items add up faster than most teams expect.
• Find Out Who Pays: Read the price-adjustment, force-majeure, and pass-through clauses in your supply contracts to see whether you or your supplier absorbs the increase. That answer changes how hard you push on everything else.
• Line Up Alternatives and Fix Your FTZ Paperwork: Anything without an exemption needs quotes from other origins and a move into privileged foreign status now, before entries pile up. This is where industrial and manufacturing and high-tech and electronics supply chains feel the squeeze first.
• Recover What You Can, and Get Backup: Where you re-export, drawback can win back part of the duty. And a managed logistics team that watches USTR full-time means the next change won’t blindside you.

How Mallory Alexander Keeps Your Brazil Freight Moving

Strip away the policy talk, and it’s really just a customs job. It’s getting the code right, backing up the exemption, and timing the entry down to the day, and that’s what our service teams do all the time. We’re already digging into exemptions and cost exposure for the clients we work with.

All of this lines up with something we already do at Mallory Alexander. Classification and duty questions go to our trade and customs team. Freight already sailing gets its entry timed to the day, and when the ocean window closes, air freight can still save a date a delayed ship would wreck.

This isn’t our first rough stretch, either. We’ve been moving freight through a century of disruption, licensed and C-TPAT certified, and companies in retail and consumer goods and plenty of others lean on us when the rules change overnight. Your Brazil freight deserves people who’ve handled worse.

Reach out, and we’ll walk your Brazil freight through a tariff and classification review. And subscribe so the next Section 301 move reaches you while there’s still time to do something about it.