Exporting to Brazil under EU-Mercosur: what actually changed

This page sets out what is in force, what it is worth, and what it leaves untouched. Every figure carries a source and the date it was checked.

What is in force, and what is not

Two separate legal instruments came out of the same negotiation. The Interim Trade Agreement, which carries the tariff schedule, is being applied provisionally. The wider EU-Mercosur Partnership Agreement is not ratified and is not in force.

Date	Step
6 December 2024	Negotiations concluded politically
9 January 2026	Council of the EU approves signature. France, Poland, Austria, Hungary and Ireland vote against; Belgium abstains
17 January 2026	Signature in Asunción
21 January 2026	European Parliament asks the Court of Justice for an opinion, by 334 votes to 324 with 11 abstentions
28 April 2026	Brazil publishes Decreto nº 12.953/2026
1 May 2026	Provisional application of the trade part begins

So the tariff schedule is live and enforceable at the Brazilian border. The rest of the agreement is waiting on a court opinion and on ratification across the member states. Neither has a published deadline.

We keep a dated record of every step and what remains outstanding on the status and timeline page.

What the tariff cut is worth once it reaches your landed cost

The figure in circulation is that duties are eliminated on 91% of EU exports to Mercosur. It comes from the European Commission and it describes the end state of the schedule, not the position in 2026.

Two adjustments turn it into something usable.

The first is that the reduction schedule runs off base rates recorded in the tariff annex, while the duty Brazil charges today is tracked separately. On several verified lines the applied rate is 10% below the annex base, which matches Brazil's horizontal tariff cut of 2022 and 2023, though the annex does not give that as the reason. Where the applied rate sits below the base, the early annual steps do not close the gap. For lip make-up under NCM 3304.10.00 the preferential rate this year is 16.87% against an applied duty of 16.20%. Claiming the preference would cost more than not claiming it. From 1 January 2027 that reverses.

The second is that a duty cut does not pass through to landed cost at full value. PIS/COFINS-Importação is charged on the customs value and AFRMM on the freight, neither of which depends on the duty. Across four modelled categories, duty cuts of 12.6 to 18 percentage points produced landed cost reductions of 10.0% to 13.9%, around 77% of the headline.

The full calculation, the formula behind it and four worked product examples are on the page covering what the tariff cut is really worth.

Which sectors gain, and when

The schedule sorts every tariff line into one of three regimes: immediate elimination, a staged reduction over 4, 8, 10 or 15 years, or a quota.

Across the 10,029 lines of the Mercosur offer, 10.7% go to zero immediately, 8.9% are excluded permanently, and the remaining 80% follow a schedule or a quota. The largest single group, 35.1% of lines, is the ten year category.

Sector	Position under the agreement
Machinery	Duties of 14% to 20% to zero over 10 years, covering 93% of lines
Pharmaceuticals	Duties up to 14% to zero over 10 years, covering 90% of lines
Textiles	35% to zero over 8 years
Cars, electric and hybrid	35% to 25% immediately, per the European Commission. The annex handles this category under its own mechanism, described on the tariff schedule page
Cars, internal combustion	35% to 17.5% immediately
Chemicals	Duties up to 18%, with an estimated EUR 4.8 billion gain in EU exports

Sector averages hide a great deal. Within one pump subheading, 8413.70, two tariff lines sit in the fifteen year category and a third is excluded from preferences altogether. The line matters, not the sector.

Figures for chemicals cover the chapter as a whole. The European Commission does not publish a separate line for cosmetics or perfumery, and the only verified cosmetics data point is lip make-up at an 18% base rate in the fifteen year category.

The category by category schedule, the annual reduction table and the sector detail are on the tariff schedule page.

What the agreement does not touch

The agreement changes one thing at the Brazilian border: the import duty. Everything else that governs whether your product can be sold in Brazil is unchanged.

IPI, PIS/COFINS, ICMS and its gross up calculation, AFRMM and the Siscomex fee all stay as they are. So does ANVISA registration or notification for cosmetics, health products and food. So does establishment registration with MAPA for wine and products of animal origin. So does compulsory INMETRO certification, which attaches to the NCM code rather than to the country of origin. Labelling in Portuguese remains mandatory. The Brazilian importer still needs RADAR accreditation, and import licensing still applies where an agency has to give consent.

This is not an inference from silence. The technical barriers chapter of the agreement contains exactly one product annex, covering automotive products. There is no annex for cosmetics, no mutual recognition of good manufacturing practice, and the Commission's own question and answer material describes regulatory cooperation as taking place on a voluntary basis.

For most companies this is the part that sets the launch date. A duty change is a line in a spreadsheet. A product registration is a calendar.

The full list, with the legal basis for each item, is on the page covering what does not change.

How to claim the preferential rate

Preferential origin under this agreement is proved by a statement on origin made out by the exporter, following the model wording in Annex 3-C and the conditions in Article 3.17. Movement certificates of the EUR.1 type are not used.

EU exporters need to be registered in the REX system. Without registration, a statement can only cover consignments up to EUR 6,000. The statement is valid for twelve months under Article 3.18, and supporting records have to be kept for three years under Article 3.22.

Cumulation is bilateral only, under Article 3.3. Inputs from countries outside the EU and Mercosur do not count toward origin, which affects any supply chain that routes components through a third country.

One practical point from testing: Brazil's customs tax simulator, queried on 7 September 2026 with a German origin, applied the ordinary duty on every code we checked. The preference did not appear automatically. It is something the importer claims and supports, not something the system grants.

The procedure, the wording and the errors that void a claim are on the rules of origin page.

Where quotas apply

A handful of lines are managed by quota rather than by a straight schedule. On the European export side the case most exporters will meet is chocolate.

Filled chocolate under subheading 1806.31 has an annual quota of 1,890 tonnes in year 0, rising each year, shared across the entire European Union and allocated first come first served. Inside the quota the rate in year 0 is 18.70%. Above it, 20%. Brazil applies 18.00% today, so this year the ordinary route is cheaper in both cases. The quota reaches zero duty from year 14.

Quota and conditional categories together account for 45 of the 10,029 lines. Details and the year by year table are on the tariff quotas page.

Public procurement, partly open

Brazilian public procurement opens to EU suppliers at federal level and, unevenly, at state level. Municipalities and state owned enterprises are not covered.

Federal thresholds are SDR 216,000 for goods and services until the end of year 7 and SDR 130,000 after that, with SDR 8,000,000 for works falling to SDR 5,000,000. State thresholds are SDR 216,000 and SDR 8,000,000. Paraguay opens access after three years.

The carve outs are substantial: the SUS public health system, food security programmes, a set aside of up to 25% for small and medium enterprises, offsets, and a list of specific product codes.

What could still change

The Court of Justice has been asked for an opinion on the agreement, and that process has no published timetable. Ratification by the member states of the full partnership agreement is unfinished. The Council vote in January recorded five countries against and one abstention, so the political opposition is on the record rather than hypothetical.

None of that affects the tariff schedule now being applied, which rests on the interim agreement and on Brazil's implementing decree. What it affects is the parts of the wider agreement that have not entered into force.

Where this leaves you

If you export to Brazil, the useful next step is narrow: take your own NCM code, find its staging category in the annex, compare the resulting preferential rate against the duty currently applied, and decide whether claiming the preference helps you this year or in 2027. For a meaningful share of codes the honest answer is that it does neither, because the line is excluded.

Then look at the part the agreement did not change, because that is usually what determines whether you can sell at all and how long it takes.

We work on both sides of that question from Rio de Janeiro, covering classification, the registrations and the import structure. If you want a view on a specific product, send us the code and the destination state and we will tell you where it stands.

Sources

• Council Decision (EU) 2026/183 on the Interim Trade Agreement, CELEX 32026D0183, agreement text CELEX 22026A00184; Council Decision (EU) 2026/185 on the Partnership Agreement, CELEX 32026D0185, text CELEX 22026A00186. Both 9 January 2026.
• Decreto nº 12.953/2026 of 28 April 2026, Brazil.
• Annex 2-A and Appendix 2-A-2 to the Interim Trade Agreement, Mercosur tariff schedule, for staging categories, base rates and the annual reduction table.
• Applied duties and Brazilian federal taxes by NCM code: Portal Único Siscomex, Classif module, tax treatment simulator, query date 7 September 2026.
• Sector figures and the 91% tariff elimination figure: European Commission, DG TRADE.
• Rules of origin: Articles 3.3, 3.17, 3.18 and 3.22 of the Interim Trade Agreement, with Annexes 3-A, 3-B and 3-C.

Rates, categories and status on this page were verified on 7 September 2026. Brazilian tariff and tax rates change several times a year, and the status of the agreement is still moving. Check the date before relying on a figure.