The National Confederation of Industry (CNI) has released new data on the reach of US surcharges on Brazilian products. The diagnosis is compelling: 77,8% of Brazil's exports to the US are subject to additional tariffs. Given the importance of the US as one of the main destinations for Brazilian industry, understanding the depth of these impacts—and how to react—is urgent for exporters, logistics operators, market analysts , and public policy makers.

Introduction: The current tariff scenario

• 77,8 % of the Brazilian export agenda to the USA is subject to surcharges.
• The US remains among the country's largest trading partners, especially for manufactured goods.
• Sectoral tariffs These are import taxes applied by product/segment, with rates that vary by NCM (HS Code), industrial policy objectives and specific legal instruments.
• Among these instruments is the 232 section (Section 232 of the Trade Expansion Act of 1962), which allows the U.S. government to impose tariffs for reasons of National security, notably about steel, aluminum and related matters.

General impact of surcharges

The aggregate numbers show amplitude and intensity:

• 45,8 % of Brazilian products face tariffs of 40% or 50%.
• A maximum tariff (50%) reaches 41,4 % of the agenda — equivalent to $17,5 billion (2024).
• 69,9 % da transformation industry is affected, adding US $ 12,3 billion.

Executive interpretation: this is a large-scale cost shock, with the potential for margin compression , repricing , loss of market share , and redirection of trade flows.

Most affected sectors

Participation of affected sectors in the CNI cut:

• Clothing and accessories: 14,6 %
• Machinery and equipment: 11,2 %
• Textile products: 10,4 %
• Foods: 9,0 %
• Chemicals: 8,7 %
• Leather and footwear: 5,7 %
• Steel, aluminum and copper (Section 232): 9,3 % of the agenda

Cost transfer — where it hurts the most:

• Fashion (clothing/accessories, textiles, footwear): high price competition and substitutability increase the difficulty of transfer.
• Foods: partial transfer possible, but with risk of exchange for an alternative source.
• Chemicals and machines: greater probability of value pricing when technical differentiation, certifications and services (installation, after-sales).
• Metals (Section 232): broad tariffs and cost/lead time sensitivity require commercial engineering more sophisticated.

Partially exempt products and sectors

There are areas of mitigation/exemption that deserve attention:

• 22,2 % of exports are surcharge-free, with emphasis on the extractive industry (oil, fuels, light and heavy oil).
• Civil aviation: items with 6,9 % of the agenda can pay only 10%, upon proof of aeronautical use.

Potential for expansion: technical claims, proof of end-use, correct tariff classifications, and bilateral negotiation can broaden the scope of temporary exemptions or reductions.

Institutional and diplomatic reaction

The CNI, through its president Ricardo Alban , emphasizes the urgency of bilateral negotiations to mitigate the effects of surcharges and preserve industrial competitiveness. Coordination between the government and the private sector is crucial for:

• Prioritize strategic sectors in the elections.
• Articulate technical evidence with American authorities.
• Assess developments in multilateral forums (WTO) is at Commercial agreements with facilitation clauses.

Key message: Predictability and legal certainty are essential for investment decisions and maintaining supply chains.

Strategies for Brazilian exporters

1) Cost mitigation and operational efficiency

• HS classification & ruling: Technical reviews of NCM/HS with legal support and binding rulings in the US; avoid undue classifications that increase tax rates.
• Logistics optimization: cargo consolidation, INCOTERMS appropriate contracts with shipowners/forwarders and use of alternative ports to reduce cost base.
• Drawback/REINTEGRA/Ex-tariff (inputs): Brazilian mechanisms to alleviate the indirect tax burden on exported inputs.
• Exchange rate insurance and dynamic pricing: protect margin and adjust price lists by rate scenario.

2) Differentiation and added value

• Certificates (UL, FDA when applicable, ASTM, FAA for aero): add value and justify premium.
• Servitization: technical package (installation, maintenance, SLA, training) to reduce price comparability.
• Design and R&D: products with their own IP suffer less substitution.

3) Alternative markets and destination portfolio

• Geographical diversification: expand presence in Mexico, Canada, EU, Middle East, Africa and ASEAN, where the tariff-logistics combination may be more favorable.
• Regional integration/Mercosur: take advantage of existing agreements and ongoing negotiations to tariff preferences.
• Alternative B2B/B2C channels: specialized marketplaces, local distributors with capillarity and exclusivity contracts that support margin.

4) Trade strategy for the USA (full compliance)

• Rules of origin: any chain reconfiguration (e.g. partial assembly in third countries) must strictly comply with the rules of origin to avoid legal risks.
• Deletion/Waiver Requests: when applicable, plead temporary exclusions (case of critical inputs without adequate domestic supply in the US).
• Industrial partnerships: joint ventures/partial local production may reduce tariffs in specific segments (case by case).

What are Sector Tariffs and Section 232 (Objective Explanation)

• Sectoral tariffs: differentiated import rates by product/segment, motivated by industrial policy objectives, trade defense (anti-dumping/anti-subsidy) or safeguards.
• Section 232: instrument of American legislation that allows tariffs for reasons of national security. In 2018, it was the basis for surcharges on steel and aluminum, with impacts on flat steel, long steel, primary aluminum and semi-manufactured products, Among others.

Economic and diplomatic effects: they increase the cost of imports, alter supply chains , create trade diversions , and raise the need for diplomatic coordination to mitigate impacts and restore predictability.

What to expect from now on?

Surcharges represent a structural challenge for the Brazilian export industry, but also a trigger for modernization, innovation, and active economic diplomacy . The combination of:

1. Eficiência de custos,
2. Differentiation by value,
3. Market diversification, and
4. Coordinated action between companies, sector entities and government
   will be decisive for sustain volumes and margins in the American market.

Call to action: companies and trade associations must intensify their participation in the debate , refine their technical demands, and advance medium-term commercial strategies — while the diplomatic channel works towards tariff relief and legal certainty in relations with the US.