On November 20, 2025, President Donald Trump issued an Executive Order modifying the scope of certain ad valorem tariffs on Brazil implemented on July 30, 2005, pursuant to the International Emergency Economic Powers Act (IEEPA). These earlier tariffs placed a 40% duty rate on certain articles of Brazil, including numerous agricultural products, coffee and beef.
Accordingly, an updated version of Annex I to the July 30, 2025 Executive Order has been issued and is attached to the November 20, 2025 Executive Order. These modifications are retroactive to November 13, 2025, as to goods entered for consumption, or withdrawn from warehouse for consumption.
The November 20, 2025 Executive Order states that, to the extent required, a refund of duties collected “shall be processed pursuant to applicable law and the standard procedures of U.S. Customs and Border Protection [CBP] for such refunds.” A new subheading 9903.01.90 has been created by CBP to cover these exempted goods (see CSMS message).
For additional background information on the July 30, 2025 Executive Order, see Thompson Hine Update of August 1, 2025.