Response to US trade policy · 2026
Status
Under investigation
Authority
CAMEX
no list published
Decree date
July 14, 2025
Tariffs
None
No tariffs enacted
Brazil occupies a distinct middle ground in the retaliation landscape. It has not settled its dispute with the United States the way Korea and Japan did, nor has it merely floated a proposal the way India did at the World Trade Organization. Instead, Brazil has built the full legal machinery to retaliate — a reciprocity statute, an implementing presidential decree, and an authorised inter-ministerial body — and then stopped short of publishing the actual list of US products and rates it would target. As of June 2026 there is no Brazilian retaliatory tariff in force on any US export, but the authority to impose one is loaded and ready, which is why this page classes Brazil’s status as under investigation rather than resolved.
The dispute grew out of the United States’ “Fair and Reciprocal Plan” tariff programme, the emergency-powers regime under which Washington applied a baseline ten percent charge on Brazilian imports and, for Brazil specifically, an additional forty percent duty layered on top. That combination was unusually steep for a major Western Hemisphere partner and landed on a politically sensitive set of Brazilian exports. Where Asian partners leaned toward negotiation, the Brazilian government chose to arm itself legally first — passing a framework that would let it answer in kind if diplomacy failed — while keeping the question of which US goods to hit deliberately open.
The response came in three distinct steps. First, the Brazilian Congress passed the Economic Reciprocity Act in April 2025, creating the statutory basis for trade countermeasures. Second, President Lula signed the decree that operationalised the law: Decree 12,551 of July 14, 2025, which set the criteria and procedures for retaliation, as reported by Agência Brasil and analysed by Brazilian trade counsel. Third, the Chamber of Foreign Trade — the inter-ministerial body known as CAMEX — was authorised to draw up the measures and opened a technical review window in August 2025. That review was the point at which a concrete list of targeted US products and rates would normally emerge. It never did: no CAMEX product-rate schedule had been published in any authoritative source as of the June 2026 review for this page.
Brazil also pursued the multilateral route at the same time. On August 6, 2025 it requested consultations at the World Trade Organization over the US tariff measures, opening the dispute recorded as case DS640. A consultations request is the first formal stage of a WTO dispute and signals that Brazil reserved its rights under the global trade rules while its domestic retaliation machinery was still being assembled. The WTO track and the CAMEX track run in parallel: the former is a legal challenge to the US measures, the latter the vehicle for any Brazilian counter-tariff, and neither has produced a collected Brazilian duty on US goods.
Part of the reason the dispute has not boiled over is a US move that eased pressure on the most exposed Brazilian sector. On November 20, 2025 the White House issued an action modifying the scope of the tariffs on Brazil, exempting more than two hundred and thirty agricultural tariff lines from the additional forty percent duty. By relieving Brazilian farm exporters — the constituency with the loudest stake in the fight — the exemption reduced the domestic political urgency for CAMEX to finalise a retaliation list, and it helps explain why the authorised measures have stayed on the shelf.
Because no Brazilian rates exist yet, a US exporter to Brazil has nothing concrete to price in today — but the exposure is real and forward-looking rather than zero. Trade counsel watching the file, notably a Covington & Burling analysis, identified pharmaceuticals, the taxation of dividends, and digital services as the categories Brazilian officials cited as likely targets if CAMEX acts. Those are cited risk categories, not a finalised list, and they should be treated as a watch-list rather than a schedule of charges. US agricultural exporters, by contrast, are comparatively insulated after the November 2025 exemptions. The asymmetry is worth stressing: the most likely future Brazilian targets are services and high-value manufactured goods, not the farm products that dominate the headlines.
The November 2025 exemption deserves a closer look because it reshaped who is actually exposed in this dispute. By lifting the additional forty percent charge from more than two hundred and thirty agricultural tariff lines, the United States removed the pressure from the Brazilian sector with the most political weight and the loudest voice in Brasília — farm exporters. That carve-out did two things at once: it lowered the cost to American importers buying those Brazilian agricultural goods, and it quieted the domestic constituency that would otherwise have pushed CAMEX hardest to publish a retaliation list. The result is a dispute that looks calmer on the surface than its underlying legal posture would suggest, because the loudest claimants have been partially satisfied while the retaliation authority remains fully intact. For US exporters, the lesson is to read the quiet carefully: the agricultural front has cooled, but the services and high-value categories Brazilian officials flagged were never the subject of the exemption and remain the live area of risk.
Understanding why Brazil can move quickly — and why it has not yet — requires looking at how the framework is built. The Economic Reciprocity Act gives the executive branch standing authority to respond to foreign trade measures Brazil considers unjustified, and Decree 12,551 translated that statute into operating procedure by routing the decision through the Chamber of Foreign Trade. CAMEX is an inter-ministerial body, not a single agency, which means a retaliation decision draws in the ministries responsible for trade, finance, and foreign affairs at once. Notably, the Brazilian counsel who analysed the decree highlighted that the criteria reach beyond conventional tariffs to instruments such as the suspension of intellectual-property protections, a far broader toolkit than a simple import surcharge. That breadth is part of why the cited risk categories for US exporters — pharmaceuticals, the taxation of dividends, and digital services — sit outside the usual goods-tariff conversation. The machinery is deliberately flexible and fast once CAMEX resolves to act, which is exactly why a US exporter in an exposed sector should treat the current quiet as a function of political restraint rather than legal incapacity. The authority is complete; only the published schedule is missing, and that gap could close on short notice if the bilateral relationship deteriorates.
Brazil is the country on this site most likely to move from a null rate to a real one, so monitoring is the practical advice. The two signals that would matter most are a CAMEX resolution publishing specific product lines and rates, and any escalation in the DS640 dispute. Until a CAMEX schedule appears, the accurate statement is that Brazil has authorised retaliation but not imposed it. For verification, the WTO DS640 record tracks the multilateral dispute, Agência Brasil and Brazilian trade-law commentary cover Decree 12,551 and CAMEX activity, and the White House action of November 20, 2025 documents the current US tariff scope. Because this is the most fluid file of the four zero-rate countries, confirm any duty-sensitive decision against these live sources and a licensed customs broker before relying on it.
| Target product | Rate | Effective date | Authority | Source |
|---|---|---|---|---|
| Pharmaceutical Ingredients (API) | Rate not yet finalized | July 14, 2025 | Brazil Economic Reciprocity Act (Lei de Reciprocidade) + Lula presidential decree July 14 2025 — CAMEX authorized to impose countermeasures; specific product list and rates under investigation as of June 2026 | ITA |
Target product
Pharmaceutical Ingredients (API)
Effective July 14, 2025
Source: ITANo. As of June 2026 there is no Brazilian retaliatory tariff in force on any US export. Brazil has built the full legal machinery to retaliate — the Economic Reciprocity Act, implementing Decree 12,551, and an authorised inter-ministerial body, CAMEX — but it has not published a specific list of targeted US products and rates. That is why Brazil’s status is "under investigation" rather than resolved.
Decree 12,551, signed by President Lula on July 14, 2025, is the presidential decree that operationalised Brazil’s Economic Reciprocity Act. It set the criteria and procedures for trade countermeasures and authorised the Chamber of Foreign Trade (CAMEX) to prepare them. It did not itself impose any tariff on US goods; it created the authority to do so, as reported by Agência Brasil and analysed by Brazilian trade counsel.
CAMEX opened a technical review in August 2025 but never published a product-rate list. A major reason is a US action on November 20, 2025 that exempted more than two hundred and thirty agricultural tariff lines from the additional forty percent duty, easing pressure on Brazil’s most exposed exporters and reducing the political urgency to finalise a retaliation list.
A Covington & Burling analysis identified pharmaceuticals, the taxation of dividends, and digital services as the categories Brazilian officials cited as likely targets. These are cited risk categories, not a finalised list — they should be treated as a watch-list. US agricultural exporters are comparatively insulated after the November 2025 exemptions.
On August 6, 2025 Brazil requested consultations at the World Trade Organization over the US tariff measures, opening the dispute recorded as case DS640. A consultations request is the first formal stage of a WTO dispute. The WTO track is a legal challenge to the US measures and runs in parallel to the domestic CAMEX track; neither has produced a collected Brazilian duty on US goods.
Brazil is the country most likely to move from a null rate to a real one, so monitoring is the practical advice. Watch for a CAMEX resolution publishing specific product lines and rates, and any escalation in DS640. Verify against the WTO DS640 record, Agência Brasil and Brazilian trade-law commentary on Decree 12,551, and the White House action of November 20, 2025 — and confirm any duty-sensitive decision with a licensed customs broker.
Tariff rates from Tax Foundation, USITC, and Penn Wharton Budget Model; retaliatory and industry data from the ITA Foreign Retaliations Database and U.S. Census Bureau (NAICS). Last verified .
