Please be advised the Brazilian Chamber of Foreign Trade (CAMEX) recently released a list of over 200 U.S. products that may be subject to retaliatory tariff increases of up to 100% starting January 2010. The list includes agricultural and textile, motor vehicle, electronics, cosmetics, medical equipment and pharmaceutical products.

This action stems from the WTO August ruling giving Brazil authority to impose duties as a result of the U.S. failure to comply with previous WTO ruling against U.S. cotton industry subsidies. This ruling gives Brazil the right for an initial retaliation of up to $800 million in U.S. goods and services.

U.S. goods on the published list are valued at $2.7 billion. The list is being made available for Brazilian importers to provide comment and input until November 30 before a final list is developed and presented to the WTO for approval. The final list is expected to include $450 million worth of U.S. goods. Retaliation against U.S. intellectual property rights and services is also under consideration in the amount of $450 million.

Click here to view the original resolution (Resolution 11.6.2009 - Portuguese) issued on November 6, 2009 by CAMEX along with the list of goods subject to increased duty rates. A comment submission form is included in the original resolution on pages 8-10. We have provided a translated version of this comment submission form for your convenience.

Submission of comments is currently only open to Brazilian importers. If you have customers or operations in Brazil that import U.S. products provided for on the list of goods, we encourage you to contact them immediately so they may voice their concerns.

We hope that you give careful consideration to this notice as it could have a significant impact on your business. As always, please contact us with any questions you may have.

***UPDATE***

The Brazilian Chamber of Foreign Trade (CAMEX) has delayed issuance of the final list of U.S. exports subject to retaliatory duties until February 2010. Officials say an announcement of sanctions that will take effect and the specific value of U.S. goods covered will be released with the final list of goods.

The Brazilian government will consider all public comments on the proposed list of goods when developing the final list. Over 400 comments have reportedly been received - 95% call for the removal of specific products.