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.
Quick Answer
| Metric | Value |
|---|---|
| IEEPA tariff rate | +10% baseline (heading changed on Aug 7) |
| Collection window | Apr 5, 2025 -- Feb 24, 2026 |
| Major carveouts | Annex II products, Section 232 goods, in-transit |
| Aug 7 heading change | Moved from 9903.01.25 to 9903.02.09 (rate unchanged) |
| Current status | Section 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
| Date | What happened | Additional duty |
|---|---|---|
| Apr 5, 2025 | Reciprocal tariff baseline takes effect for Brazil-origin goods | +10% |
| Apr 10, 2025 | Suspension confirms 10% baseline for most countries including Brazil | +10% |
| Jun 16, 2025 | In-transit carveout window closes (goods loaded before Apr 5) | +10% for new entries |
| Aug 7, 2025 | Re-platforming to country-specific headings (Brazil: 9903.02.09) | +10% (unchanged) |
| Sep 8, 2025 | Annex II product exclusions updated | 0% for listed products |
| Feb 24, 2026 | IEEPA revoked following Supreme Court ruling | 0% (IEEPA layer ends) |
| Feb 24, 2026 | Section 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.
| Exception | Who qualifies | Effect |
|---|---|---|
| Annex II products | Goods on the enumerated HTS exclusion list | Exempt from reciprocal tariff |
| Section 232 goods | Steel, aluminum, vehicles, and other goods already covered by Section 232 | Exempt from reciprocal tariff |
| U.S. content rule | Products with 20% or more U.S.-origin content (requires line split) | Partial reduction |
| In-transit goods | Goods 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.
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 StartedChapter 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.
| Code | Description | Rate | Window |
|---|---|---|---|
9903.01.25 | Reciprocal baseline (pre-Aug 7) | +10% | Apr 5, 2025 -- Feb 24, 2026 |
9903.01.28 | In-transit carveout | 0% | Apr 5 -- Jun 16, 2025 |
9903.01.32 | Annex II product exclusion | 0% | Apr 5, 2025 -- Feb 24, 2026 |
9903.01.33 | Section 232 goods exclusion | 0% | Apr 5, 2025 -- Feb 24, 2026 |
9903.02.09 | Brazil reciprocal (re-platformed) | +10% | Aug 7, 2025 -- Feb 24, 2026 |
9903.03.01 | Section 122 default | +10% | Feb 24, 2026 -- Jul 24, 2026 |
Related
Sources & Verification
- CBP CSMS #64680374 -- Reciprocal tariff guidance: baseline + exceptions and April 9 country rate table (Apr 5, 2025)
- CBP CSMS #65829726 -- Aug 7 re-platforming and new 9903.02.* headings (Aug 7, 2025)
- White House Annex II (EO 14326) -- Brazil at 10% under 9903.02.09
- CBP CSMS #67834313 -- Ending collection of IEEPA duties (Feb 24, 2026)
- CBP CSMS #67844987 -- Section 122 duties (Feb 24, 2026)
Last verified: 2026-03-05
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 StartedInformational 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.