Brazil – Proposed Section 301 Tariffs
If you are importing goods from Brazil, U.S. Customs and Border Protection (CBP) announced in the Federal Register on July 15, 2026, a proposed Section 301 tariff on imports from Brazil. The proposed additional duty rate is 25% and would apply to most imported products, subject to certain exceptions.
Products proposed for exemption include:
- Civil aircraft and related articles
- Certain pharmaceutical products
- Steel, aluminum, and copper articles already subject to Section 232 duties (existing Section 232 duties would continue to apply)
- Certain passenger and heavy-duty vehicles
- Certain wood products
- Certain semiconductor articles
The complete list of proposed exemptions is available in the Federal Register notice.
Copper and Copper Articles – New Country of Smelt and Cast Reporting Requirements
Effective July 30, 2026, importers of copper articles will be required to report the primary country of smelt and cast for the copper used in imported products, similar to the current reporting requirements for aluminum.
Suppliers must be able to identify where the copper was smelted and cast, as this information must be reported to CBP at the time of importation.
For products classified under the following HTSUS numbers:
- 8544.42.10
- 8544.42.20
- 8544.42.90
- 8544.49.10
The secondary country of smelt and cast may also be required. If either country is unknown, it must be reported as “OTH” (Other).
Strengthening Customs Enforcement – Executive Order 14411
President Trump issued Executive Order 14411, directing the Secretary of Homeland Security to implement measures over the next six months to strengthen customs enforcement and increase oversight of importers. While these initiatives have been announced, implementation details and regulatory guidance have not yet been released.
Key provisions outlined in the Executive Order include:
- Requiring Importers of Record (IORs) to maintain a minimum level of domestic assets, bonding, or both, while increasing minimum bond requirements (specific thresholds have not yet been announced).
- Requiring IORs to provide additional information to CBP, including anticipated import volumes, year of organization, ownership and beneficial ownership information, business affiliations, domestic asset disclosures, and any other information CBP determines necessary.
- Prohibiting foreign IORs from filing informal entries through future regulatory changes.
- Requiring foreign IORs filing formal entries under 19 U.S.C. § 1484 to:
- Obtain single-entry bonds unless CBP authorizes the use of a continuous bond after determining that revenue is fully protected and compliance can be assured.
- Participate in the Customs Trade Partnership Against Terrorism (CTPAT), if eligible, or utilize a CTPAT-validated and licensed customs broker to file entries.
- Requiring all IORs to maintain “good standing” with CBP. Good standing generally includes compliance with U.S. customs laws and regulations, payment of all customs liabilities, and the absence of violations involving illegal or illicit imports. Importers that are not in good standing could be prohibited from importing goods or conducting activities related to importation, including appointing a customs broker.
- Establishing enhanced vetting procedures for all entities seeking to import goods into the United States.
- Expanding importer disclosure and certification requirements, including reporting certain foreign tax information, global business identifiers, and detailed supply chain and production information. Failure to comply may result in civil penalties or criminal enforcement actions.
- Requiring submission of documentation or information that foreign exporters were required to provide to their own customs authorities before exporting goods to the United States.
- Revising penalty mitigation standards, including establishing a minimum mitigation floor of no less than 50% of the assessed penalty and limiting mitigation for repeat offenders.
At this time, these provisions represent policy directives that will require further regulatory action before many of the changes become effective. Additional guidance from CBP is expected as implementation progresses.
To review the full Executive Order, visit Strengthening Customs Enforcement – The White House
John Boomhover
Director of Compliance & Customs Services
