Countries·5 min read

Brazil IEEPA Tariffs: What Importers Need to Know

How IEEPA reciprocal tariffs affected imports from Brazil, who qualifies for a refund, and what to do next. Covers rates, heading changes, exceptions, timelines, and the path to recovery.

By Paige W.··Updated March 16, 2026

Quick Answer

MetricValue
IEEPA tariff rate+10% baseline (heading changed on Aug 7)
Collection windowApr 5, 2025 -- Feb 24, 2026
Major carveoutsAnnex II products, Section 232 goods, in-transit
Aug 7 heading changeMoved from 9903.01.25 to 9903.02.09 (rate unchanged)
Current statusSection 122 (+10%) replaced IEEPA

Overview

Brazil is a significant U.S. trading partner, with major import categories including industrial inputs, energy products, aerospace components, agricultural commodities, and manufactured goods. Under the IEEPA reciprocal tariff program, Brazil-origin imports were subject to an additional 10% duty beginning April 5, 2025.

Unlike some trading partners that faced higher country-specific rates, Brazil remained at the 10% baseline throughout the entire IEEPA period. For most Brazil importers, the practical question was not the rate itself but whether an exception applied. The Annex II product exclusion list, Section 232 goods, the 20% U.S. content rule, and in-transit carveouts could all reduce or eliminate the reciprocal add-on entirely.

On August 7, 2025, CBP re-platformed the reciprocal tariff headings from the 9903.01.* series to country-specific 9903.02.* codes. For Brazil, this meant the heading changed from 9903.01.25 to 9903.02.09, but the rate stayed the same at +10%.

The IEEPA reciprocal tariff ended on February 24, 2026, following the Supreme Court's ruling in Learning Resources v. Trump. On the same day, a new Section 122 surcharge of 10% took effect. For importers who paid the IEEPA duty on non-exempt goods, those payments may be recoverable.

Informational only — not legal advice.

What Changed: Rate Timeline

DateWhat happenedAdditional duty
Apr 5, 2025Reciprocal tariff baseline takes effect for Brazil-origin goods+10%
Apr 10, 2025Suspension confirms 10% baseline for most countries including Brazil+10%
Jun 16, 2025In-transit carveout window closes (goods loaded before Apr 5)+10% for new entries
Aug 7, 2025Re-platforming to country-specific headings (Brazil: 9903.02.09)+10% (unchanged)
Sep 8, 2025Annex II product exclusions updated0% for listed products
Feb 24, 2026IEEPA revoked following Supreme Court ruling0% (IEEPA layer ends)
Feb 24, 2026Section 122 surcharge begins+10%

Exceptions and Carveouts

Not every Brazil-origin import was subject to the full 10% IEEPA reciprocal rate. The following exceptions applied during the IEEPA collection window.

ExceptionWho qualifiesEffect
Annex II productsGoods on the enumerated HTS exclusion listExempt from reciprocal tariff
Section 232 goodsSteel, aluminum, vehicles, and other goods already covered by Section 232Exempt from reciprocal tariff
U.S. content ruleProducts with 20% or more U.S.-origin content (requires line split)Partial reduction
In-transit goodsGoods loaded or in-transit before Apr 5, 2025 (extended to Jun 16)Exempt from reciprocal tariff

If your goods qualified under one of these exceptions, the IEEPA reciprocal surcharge either did not apply or applied at a lower rate.

What This Means for Your Refund

If you imported non-exempt goods from Brazil between April 5, 2025 and February 24, 2026, you may have paid an additional 10% in IEEPA reciprocal duties on top of your normal tariff rate. Following the Supreme Court's ruling in Learning Resources v. Trump, those duties may be refundable.

The type of filing depends on your entry's liquidation status:

  • Unliquidated entries may be corrected through a Post-Summary Correction (PSC)
  • Liquidated entries typically require a Form 19 protest, which must be filed within 180 days of liquidation

IEEPA reciprocal duties are separate from Section 232 duties and Section 301 duties. Those programs are not affected by the Supreme Court ruling.

If you are unsure whether your entries qualify, check the full Chapter 99 line, not just the ordinary HTS. Brazil entries can involve both 9903.01.* and later 9903.02.* headings.

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Chapter 99 Code Reference

This section is for customs brokers, trade compliance teams, and anyone reviewing entry summaries at the line-item level. Each Chapter 99 code corresponds to a specific IEEPA or Section 122 treatment.

CodeDescriptionRateWindow
9903.01.25Reciprocal baseline (pre-Aug 7)+10%Apr 5, 2025 -- Feb 24, 2026
9903.01.28In-transit carveout0%Apr 5 -- Jun 16, 2025
9903.01.32Annex II product exclusion0%Apr 5, 2025 -- Feb 24, 2026
9903.01.33Section 232 goods exclusion0%Apr 5, 2025 -- Feb 24, 2026
9903.02.09Brazil reciprocal (re-platformed)+10%Aug 7, 2025 -- Feb 24, 2026
9903.03.01Section 122 default+10%Feb 24, 2026 -- Jul 24, 2026

Need help getting your documents?

Most importers don't have their customs records on hand. We'll guide you through requesting them from your carrier or broker.

Get Started

Informational only — not legal advice. RefundArrow is not a law firm, and this resource does not create an attorney‑client relationship with Himmelstein & Adkins, LLC. Tariff/refund outcomes depend on your facts, entry records, and evolving CBP/court guidance; consult qualified customs counsel for advice on your situation.

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