US tariff shock: what changes for Brazilian exporters now

On July 22, 2026 the United States implemented an additional 25% tariff on roughly 4,000 Brazilian products, affecting about US$11 billion in annual exports — equivalent to 26.2% of Brazil’s sales to the U.S., according to CNI(CNI). In parallel, a second measure created a 12.5% surcharge on another portion of exports, with the possibility of accumulating up to an additional 37.5% on top of the ordinary tariff(MDIC).

Even before the final announcement, CNI, Amcham Brasil and the U.S. Chamber sent a joint letter on July 9, 2026 to the Brazilian and U.S. governments requesting a short-term agreement to avoid the application of these additional Section 301 tariffs(Comex do Brasil). For exporters and importers this is not an abstract trade-policy debate: it changes final price, margin, route viability, contract design and even the decision to keep the U.S. as a priority market.

The tariff picture: numbers, dates and scope

In 2025 and 2026 the U.S. government opened investigations into Brazil based on Section 301 of the Trade Act of 1974, alleging "unfair practices" that restrict U.S. trade(Reuters/UOL). On June 2, 2026 the Trump administration proposed an additional 25% tariff on a broad basket of Brazilian products, excluding only items already covered by Section 232 (national security)(Reuters/UOL). On July 15, 2026 the government confirmed adoption of that 25% tariff after concluding the Section 301 investigation(Metrópoles).

According to an official CNI statement of July 17, 2026, the 25% tariff:

• applies to about 4,000 Brazilian products;
• even with 429 exceptions included in the final U.S. decision, affects roughly US$11 billion in exports, or 26.2% of Brazilian sales to the U.S.;
• became effective on July 22, 2026(CNI).

Subsequently, on July 23, 2026 the U.S. published a new measure under Section 301 creating an additional 12.5% surcharge on another share of Brazilian imports(MDIC). The MDIC note, based on the 2024 export basket (US$40.4 billion), details the current scenario:

• 52.7% of exports remain subject only to the Most-Favored-Nation (MFN) tariff, without Section 232 or 301 surcharges (US$21.3 billion);
• 1.9% (US$0.8bn) are subject only to the 25% surcharge (Section 301 specific to Brazil);
• 4.7% (US$1.9bn) are subject only to the 12.5% surcharge (the list of the 60 largest partners);
• 16.5% (US$6.6bn) now face both the 12.5% and 25% surcharges simultaneously, resulting in an additional 37.5%;
• 24.2% (US$9.8bn) were already under sectoral Section 232 tariffs (steel, aluminum, wood, vehicles, among others)(MDIC).

These Section 301 surcharges do not apply to products already covered by Section 232, which keep their own high rates. Section 232 tariffs on steel, aluminum and copper reached 50% and remain in force, with an expanded scope for some derivatives, even after the Section 301 tariff package(G1).

Overall, the MDIC estimates that more than 23% of Brazilian exports to the U.S. (base 2024) are now subject to new Section 301 surcharges, while 24.2% remain under Section 232. In other words, roughly 47–50% of the export basket is currently under some form of surcharge beyond the ordinary tariff(MDIC).

At the same time, CNI’s Industry Observatory identified 6,073 tariff codes of Brazilian products with some incidence of additional tariff (10%, 25% or 50%) after the tariff measures, combining actions under Sections 122, 232 and 301(Jornal do Comércio/CNI).

In bilateral trade, the MDIC reports that Brazil’s goods exports to the U.S. fell from US$40.4 billion in 2024 to US$37.7 billion in 2025 and continued declining in 2026, "in the wake of surcharges adopted by the U.S."(MDIC). Amcham Brasil estimates that more than US$11 billion in industrial and agribusiness exports could be affected by the 25% tariff as of July 22, 2026(Amcham/Felipe Tavares).

Important: products such as coffee, meat, orange juice, part of pulp and fuels remain outside the Section 232/301 surcharges and are still subject only to U.S. MFN tariffs, according to MDIC and the Brazil–U.S. Trade Monitor(MDIC).

It is within this scenario that the joint July 9 letter fits. CNI, Amcham Brasil and the U.S. Chamber ask for an agreement in two stages: in the short term, to avoid or suspend application of the new Section 301 tariffs; and in the medium and long term, to build a cooperation agenda on topics such as supply chains, digital economy, trade facilitation, innovation, decarbonization and agriculture(Comex do Brasil). The Industry News Agency and other outlets echoed this move, highlighting the request to preserve the bilateral relationship and avoid new costs for firms, workers and consumers in both countries(PIXTV).

Practical impact on operations: price, route, contract and documentation

From the perspective of trade operators, the new U.S. tariff framework creates five possible situations for the same HS code, according to the MDIC note(MDIC):

• only the ordinary tariff (MFN);
• ordinary tariff + 25% (Section 301 specific to Brazil);
• ordinary tariff + 12.5% (Section 301 list of the 60 largest partners);
• ordinary tariff + 37.5% (12.5% + 25% cumulative);
• ordinary tariff + Section 232 (10%, 25% or 50%, depending on the product), not cumulative with 301 when the item is already on the 232 list.

In practice, this requires reviewing each tariff position:

• Pricing: simulate FOB + MFN tariff + any 232/301 surcharge + freight + insurance for each HS. In many cases, the addition of 25–37.5–50% can make the final U.S. price unviable.
• Contracts: renegotiate "tariff pass-through" clauses or automatic price review triggers for unilateral tariff changes at destination. An exporter without such clauses may have to absorb part of the tariff until the next negotiation cycle.
• Incoterms: reconsider whether it makes sense to continue selling CIF/DDP to the U.S. in sensitive segments. In some cases, moving to FOB/FCA and transferring tariff payment to the U.S. importer may be a condition to continue the relationship.
• Route and destination: with nearly half the export basket under surcharges, companies with geographic flexibility tend to test other markets for the most pressured product lines, while focusing U.S. shipments on products still free of 301/232 measures.
• Documentation and classification: operational risk of HS errors increases. A misclassification can put a product on a list with a 25–50% tariff or, conversely, cause the importer to lose the right to an exception.
• Special regimes: for those importing inputs from the U.S. and re-exporting, the use of drawback and other regimes becomes even more relevant in global cost strategy.

On the U.S. buyer side, Amcham Brasil highlights that bilateral trade was already down 13% in 2026 and that the new tariffs tend to raise costs for U.S. firms and consumers and increase dependence on Asian suppliers(Amcham/Felipe Tavares). This opens room to renegotiate lead times, sharing of tariff costs and even U.S.-based inventory models (consignment, bonded warehouse) to cushion the importer’s cash impact.

Another important point is exceptions. CNI cites 429 new products included in the exemption list in the U.S. final decision, such as pig iron, aluminum hydroxide and instant coffee(CNI). For operators in these segments, the work is now technical: check code by code, prove the classification and keep a robust documentary file for potential U.S. customs audits.

TMLOG's take

Interest behind the tariff shock: official data indicate that the move is not merely a one-off against Brazil. There is a reconfiguration of U.S. trade policy that combines the "unfair practices" argument (Section 301) with "national security" (Section 232) to protect strategic industrial sectors and strengthen political bargaining power. The fact that the package hits metals, chemicals, industrial goods and part of agribusiness — not just specific niches — shows use of tariffs as a domestic policy tool, not only as a correction of market distortions.

Where the press exaggerates: some coverage treats the tariff shock as if all Brazilian exports to the U.S. became unviable overnight. MDIC numbers show that 52.7% of the basket remains subject only to MFN tariff, without Section 232 or 301 surcharges(MDIC). In addition, relevant products such as coffee, meat, orange juice, part of pulp and fuels remain outside the surcharges(MDIC). For these sectors, the immediate impact is much smaller.

What really changes for the exporter: for industry and parts of agribusiness, almost everything changes. With roughly 47–50% of the basket under some form of surcharge beyond the ordinary tariff(MDIC), exporting to the U.S. becomes an exercise in per-product and per-contract margin engineering, no longer a "natural market" with reasonable predictability.

In practice, we see four inevitable moves for companies we assist daily:

• aggressive repricing of lines destined for the U.S., including suspending shipments until a new price is agreed;
• mix revision: concentrate sales on items that remained outside the surcharges or on newly granted exceptions;
• test new destinations for products most hit by the 25–37.5–50% measures;
• greater contractual sophistication (tariff clauses, currency hedging aligned with the new cost and, in some cases, Incoterm review).

What to do in the coming weeks:

• run an HS-by-HS diagnostic of the export/import basket with U.S. destination/origin, cross-checking official 232/301 lists;
• meet with the U.S. client (or supplier) and put exact percentages affecting each product on the table, using MDIC, CNI and Amcham communications as technical basis;
• review existing contracts, prioritizing insertion of price-review triggers linked to unilateral tariff changes;
• assess logistical routes and timings: with tighter margins, delays, storage and demurrage weigh more; planning the shipping window becomes a strategic topic;
• map opportunities in products excluded from surcharges or added to the exception list — these tend to gain relative competitiveness versus competitors from more penalized countries.

Government-to-government negotiations can alleviate part of the problem in the medium term, as CNI, Amcham and the U.S. Chamber hope(Comex do Brasil). But Brazilian exporters and importers cannot wait for that to adjust their operations. Room for maneuver today lies in fine management of price, contract and logistics.

Sources

• Trump administration proposes 25% tariff to punish Brazil for trade practices — Reuters/UOL
• The second CNI letter trying to block Trump’s tariff shock — Metrópoles
• Scope of U.S. Tariff Measures on Brazilian Exports — MDIC
• Trump’s tariff shock: timeline and how the new tariffs affect Brazil — G1
• Amcham, CNI and US Chamber of Commerce urge the governments of Brazil and the U.S. to seek an agreement to avoid new tariffs — Comex do Brasil
• New U.S. tariff keeps industry under pressure and demands progress in negotiations — CNI
• CNI calls for negotiation to avoid U.S. tariffs — PIXTV
• Amcham Brasil note on the application of 25% U.S. tariffs in relation to Brazil — LinkedIn/Felipe Tavares
• Special issue of the Industry Observatory — Jornal do Comércio/CNI
• Tariff shock: steel, aluminum and copper remain surcharged — Folha de S.Paulo
• Colombia facing new U.S. tariffs: selective risks and product-level opportunities — AmCham Colombia