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Tariffs of up to 37.5%: what separates exporters losing margin from those gaining ground in the U.S.

Since July, 23.1% of Brazil's exports to the United States face new surcharges of up to 37.5%. Our specialists show who was hit, what has already changed in shipments and why companies that reposition now, including with a U.S. presence, stand to come out ahead.

Data through September 20268-minute readPublished October 23, 2026

By the Marroffino & Partners team of specialists

23.1%

of Brazil's exports to the U.S. face the new Section 301 tariffs

MDIC, Jul 2026

37.5%

maximum combined surcharge (25% + 12.5%), applied to 16.5% of exports

USTR; MDIC

52.7%

of exports carry no additional tariff, including coffee, meats and aircraft

MDIC, Jul 2026

−6.5%

exports to the U.S., January–September 2026 vs the same period of 2025

Secex/MDIC, Oct 2026

Executive summary

Exposure is concentrated, not across the board. More than half of exports to the U.S. (52.7%) carry no additional tariff. The real impact falls on manufactured goods, from machinery and footwear to furniture, apparel, wood and oils, which make up 16.5% of sales and now pay up to 37.5%.
The surcharges stack. The 25% Section 301 tariff on Brazil, in force since July 22, adds to the 12.5% forced-labor tariff in force since July 24, which replaced the 10% global tariff. Goods under Section 232, such as steel and aluminum, follow a separate regime.
The effect is already visible in shipments. Exports to the U.S. fell 6.5% from January to September; for surcharged goods the decline was 8.1%. September's 31.9% rise came mostly from prices (+28%), not volume (+3.1%).
Margins drive the strategy. For a product with a 3% normal U.S. duty, the 37.5% surcharge raises the landed cost in the U.S. by about 34%. Classification and contract reviews are immediate; diversification and local production require more capital and time.

What changed in 2026

In less than six months the legal basis for U.S. tariffs on Brazil changed twice. The tariffs struck down by the Supreme Court in February gave way to a temporary global rate and then, in July, to two Section 301 actions that stack on the same products.

Exhibit 1

How the additional U.S. tariff on Brazilian goods evolved in 2026

Feb 2410%
Temporary global tariff (Section 122), for up to 150 days, after the Supreme Court struck down the IEEPA tariffs.
Jul 2225%
Section 301 action on Brazil, with exemptions for energy, civil aircraft, beef, coffee, orange juice, fertilizers and other goods.
Jul 2412.5%
Section 301 forced-labor tariff replaces the 10% for Brazil and 40 other economies; 471 products are excluded.
Todayup to 37.5%
The two Section 301 surcharges stack. Section 232 goods (steel, aluminum, autos) stay under their own regime.

Sources: Federal Register; USTR; EY; Alston & Bird; Thomson Reuters.

Who is exposed

The headline rate overstates the average impact. Exposure depends on the tariff bucket of each product. Scroll to see each bucket.

Exhibit 2

Brazil's exports to the U.S. by additional-tariff bucket (% of value)

Source: MDIC note of July 24, 2026. Shares of exports to the U.S.

52.7% · No additional tariff

More than half passes without a surcharge

Coffee, meats, pig iron, aircraft, orange juice, fruit, chemicals and most pulp pay only the normal U.S. duty.

24.2% · Section 232

Steel, aluminum and other sectoral goods

Goods already under the Section 232 national-security tariffs are outside the 25% action on Brazil. They pay the sectoral rate that applies to every country.

16.5% · 37.5%

The core of the impact: manufactured goods

Machinery and equipment, wood, fats and oils, footwear, furniture and apparel carry both surcharges, about US$6.6 billion in annual sales.

4.7% · 12.5%

Forced-labor tariff only

Stone and plaster articles, ores, essential oils, perfumery and fish.

1.9% · 25%

The Brazil surcharge only

The main item is sugar.

Reading

23.1% under the new tariffs

Together, the three Section 301 buckets cover 23.1% of exports to the U.S. Using a different method, CNI estimates 4,060 products and US$12.4 billion affected.

The effect on trade

The United States lost weight in Brazil's export mix: from 12.0% in 2024 to 9.4% in the first half of 2026. In the first half, the 13% fall was led by crude oil (−30.4%) and semi-finished iron and steel (−21.7%), where international prices and sectoral tariffs weigh more than the new surcharges.

September brought a 31.9% year-on-year rise (US$3.52 billion against US$2.67 billion), but Amcham attributes it mainly to higher average prices (+28%); volume grew 3.1%. The comparison base is also depressed: in September 2025 the 2025 tariffs of up to 50% were in force.

Exhibit 4

Change in exports to the U.S., January–September 2026 vs 2025 (%)

Source: Secex/MDIC, release of October 6, 2026, as reported by the press; Amcham Brasil.

What the tariff costs on your product

In a typical product of the 37.5% bucket, landed cost in the U.S. rises by about a third. Whether that is absorbed, shared or avoided depends on decisions few companies have made yet.

Exclusive diagnostic

How much does the tariff cost on your product, and which route protects your margin?

Our specialists calculate the U.S. landed cost of each item in your export basket, compare the possible routes and deliver an objective recommendation for your leadership.

Landed cost in the U.S. by product, under the tariffs in force
Exporting, assembling or producing in the U.S., compared side by side
A recommendation and action plan for your leadership

+34% increase in landed cost for a typical product in the 37.5% bucket Request the diagnostic

The routes companies are weighing

Six routes are on the table. Which one makes sense depends on the margin, volume and timing of each operation, and that is exactly what we assess with our clients.

Classification and exemptions

Check each item's HTS classification against the exemption annexes. A large part of the export basket is exempt, and misclassification is costly either way.

Pricing and contracts

Renegotiate price, Incoterms and adjustment or force-majeure clauses, and share the surcharge along the chain.

Market diversification

Redirect volume to Asia, Europe and Latin America, a shift analysts such as FTI Consulting have already observed.

Foreign-Trade Zones

Since July 22, Brazilian goods enter FTZs under privileged foreign status: no inverted-tariff gain, but duty deferral and duty-free re-export remain possible.

Assembly or production in the U.S.

Goods made in the U.S. pay no import duty, though imported components do. Origin depends on substantial transformation, and the project needs capital, permits and a local team.

Production in a third country

Works only with real substantial transformation in the intermediate country. Simple transshipment is illegal and penalized.

Overview for orientation only. It does not replace customs, legal or tax advice.

In the press and among analysts

Bloomberg · Jan 6, 2026Brazil posted record exports in 2025 despite U.S. tariffsNew destinations offset part of the loss in the U.S. market.AP · Jul 16, 2026U.S. imposes a 25% tariff on some Brazilian imports from July 22Washington cited Brazil's high import tariffs and weak anti-corruption enforcement.EY Tax News · Jul 2026What the USTR notice means for importersExemptions, no stacking with Section 232 and the end of the inverted-tariff benefit in FTZs.FTI Consulting · 2026Tariffs accelerated Brazil's export diversificationVolumes were redirected to China and other Asian markets.

What to do now

Measure the real exposure of your export basket under the rules in force since July.
Recalculate landed cost and margin in the U.S. before the next price negotiation.
Decide, with numbers, whether to defend the current model or build a presence in the U.S.

We assess your company's exposure and options, with numbers.

Speak with a partner

About this article

Prepared by the Marroffino & Partners team of specialists in strategy and U.S. market entry.

To discuss these findings for your company, write to us or book a conversation with a partner.

contact@marroffino.com

Methodology and sources

Figures come from official notices and from MDIC/Secex data as reported by the press, checked on October 23, 2026. Where sources diverge (MDIC and CNI estimate the affected share differently), both are shown.

This article is for information only and reflects public data available on October 23, 2026. It is not legal, customs or tax advice, nor an investment recommendation. Trade measures can change at any time; confirm the current rules before deciding.