Brazil’s Office of Foreign Trade Announces Proposed List of U.S. Goods to Face Higher Duties
Client Alert | 20 min read | 11.12.09
On November 9, 2009, Brazil's Office of Foreign Trade (CAMEX) published Resolution 74, initiating public consultation on a preliminary list of U.S. goods that may be subject to higher import duties. CAMEX has taken this action in light of a World Trade Organization (WTO) arbitrator's finding that Brazil is entitled to retaliate for failure of the United States to come into compliance with WTO rules pertaining to subsidies it gives to cotton growers. CAMEX proposes to impose import duties equal to as much as 100% of the value of the U.S. goods included on the attached list. Major product categories covered by the list include food, non-alcoholic beverages, medical products and medicines, beauty products, cotton, articles of clothing, vehicles, and household products. Interested parties are invited to provide comments to CAMEX by November 30, 2009.
Crowell & Moring lawyers, and Crowell & Moring International trade experts, have extensive experience working with companies and trade associations to obtain market access in foreign countries and to prevent the withdrawal of market access. Please contact us to discuss how we can help to make your views heard as CAMEX finalizes its list of products subject to retaliation.
ANNEX III
|
0303.51.00 |
Herring |
|
0303.71.00 |
Sardine |
|
0402.10.10 |
Powder milk and skin, concentrated or sugar or sweetener added, with arsenic, lead or copper levels inferior to 5ppm |
|
0404.10.00 |
Serum of milk, modified or not, even concentrated or sugar or sweetener added |
|
0504.00.13 |
Swine intestine, bladder and stomach; fresh, frozen, salted or brine, dry or smoked |
|
0802.21.00 |
Almonds, with skin |
|
0802.31.00 |
Walnuts, with skin |
|
0802.32.00 |
Walnuts, without skin |
|
0806.20.00 |
Raisins |
|
0808.20.10 |
Pears |
|
0809.20.00 |
Cherries |
|
0809.40.00 |
Plums and sloes |
|
1001.90.90 |
Other Wheat |
|
1105.20.00 |
Flakes, granules and pellets |
|
1302.12.00 |
Saps and extracts of licorice. |
|
1302.13.00 |
Saps and extracts of hops |
|
1302.19.99 |
Other vegetable saps and extracts |
|
1502.00.11 |
Fats of bovine animals, sheep or goats, other than those of heading of 15.03 |
|
1507.90.90 |
Other - Crude oil, whether or not degummed. |
|
1514.11.00 |
Low erucic acid rapeseed or colza oil, crude, but not chemically modified |
|
1514.19.10 |
Refined rapeseed oil. |
|
1516.20.00 |
Vegetable fats and oils and its fractions |
|
1702.19.00 |
Other - Lactose and lactose syrup containing by weight less than 99% lactose, calculated on the dry matter |
|
2005.20.00 |
Potatoes |
|
2009.90.00 |
Mixtures of juices |
|
2103.20.10 |
Tomato ketchup, in containers of less than 1 kilo |
|
2103.90.91 |
Other sauces and condiments, in containers of less than 1 kilo |
|
2106.10.00 |
Protein concentrates and textured protein substances. |
|
2106.90.10 |
Non-alcoholic preparations of a kind used in the manufacture of beverages |
|
2106.90.30 |
Food supplements |
|
2106.90.50 |
Chewing gum, without sugar |
|
2106.90.90 |
Other food preparations not elsewhere specified or included |
|
2202.90.00 |
Other waters |
|
2303.20.00 |
Beet-pulp, bagasse and other waste of sugar manufacture. |
|
2503.00.10 |
Crude and unrefined sulphur |
|
2815.12.00 |
Sodium hydroxide (Caustic soda), in aqueous solution (Soda lye or liquid soda) |
|
2905.11.00 |
Methanol (Methyl Alcohol) |
|
2905.13.00 |
n-1-ol (n-Butyl alcohol) |
|
2929.10.21 |
Mixed isomers |
|
3003.90.55 |
Paracetamol; bromopride |
|
3004.20.19 |
Other (medicaments containing chloramphenicol, its palmitate, succinate or hemisuccinate ) |
|
3004.20.79 |
Other medicaments containing tetracyclines or chloramphenicols or derivatives thereof |
|
3004.31.00 |
Medicaments containing insulin |
|
3004.39.39 |
Other medicaments containing hormones or other products of heading No. 29.37 but not containing antibiotics : |
|
3004.40.90 |
Other medicaments containing alkaloids or derivatives thereof but not containing hormones, other products of heading No. 29.37 or antibiotics |
|
3004.50.50 |
D calcium pantotenate; vitamin D3 (colecalciferol) |
|
3004.90.19 |
Other medication containing enzymes |
|
3004.90.49 |
Paracetamol and bromopride, containing products of the headings 2924 to 2926, but not containing products of items 3004.90.1 to 3004.90.3 |
|
3005.10.90 |
Other dressings with closure devices |
|
3006.10.90 |
Other surgical suture materials |
|
3006.40.12 |
Other dental fillings |
|
3003.00.20 |
Colognes |
|
3304.10.00 |
Make up products for the lips |
|
3304.99.10 |
Beauty creams and nutritional creams; tonic lotions |
|
3304.99.00 |
Other preparations for skin care |
|
3305.10.00 |
Shampoos |
|
3305.90.00 |
Other hair care products |
|
3306.10.00 |
Toothpaste |
|
3306.90.00 |
Other products for teeth care |
|
3307.10.00 |
Preparations for shaving |
|
3307.20.90 |
Other personal deodorants and antiperspirants |
|
3307.90.00 |
Other toilet preparations |
|
3401.19.00 |
Soap and organic surface-active products and preparations,in the form of bars, moulded pieces or shapes, and paper,wadding, felt and nonwovens, impregnated, coated or covered with soap or detergent, not for toilet use |
|
3402.90.39 |
Other cleaning preparations |
|
3707.90.21 |
Based on carbon black or dye and thermoplastic resins, for electrostatic document reproduction |
|
3901.20.29 |
Other Polyethylene having a specific gravity of 0.94 or more |
|
3901.90.90 |
Polymers of ethylene, nesoi, in primary forms, other than elastomeric |
|
3902.10.20 |
Polyprolylene, without charge, primary form |
|
3904.10.10 |
Polyvinyl chloride homopolymer, suspension type |
|
3917.40.90 |
Other fittings for tubes, pipes and hoses, of plastics |
|
3923.10.90 |
Other boxes, cases, crates and similar articles: |
|
3923.29.90 |
Other Aseptic bags, incorporating a sealed gland, of a width of 315 mm or more and a length of 410 mm or more |
|
3923.30.00 |
Carboys, bottles, flasks and similar articles for the conveyance or packing of goods, of plastics. |
|
3923.50.00 |
Stoppers, lids, caps and other closures, of plastics |
|
3926.90.90 |
Other products of plastic |
|
4011.10.00 |
Rubber-based products of a kind used on motor cars (including station wagons and racing cars). |
|
4011.20.90 |
Other new pneumatic tires |
|
4011.63.90 |
Other (of a kind used on construction or industrial handling vehicles and machines having a rim size exceeding 61 cm) |
|
4011.94.90 |
Other: New pneumatic tires, of rubber-based, of a kind used on handling equipment, having a rim size exceeding 61 cm |
|
4016.93.00 |
Gaskets, washers and other seals |
|
4016.95.90 |
Other inflatable articles of vulcanized rubber other than hard rubber. |
|
4703.21.00 |
Chemical wood pulp, soda or sulfate, other than dissolving grades, of semi-bleached or bleached coniferous wood |
|
4811.41.10 |
Self-adhesive paper & paperboard, in strips/rolls of 15 cm wide or rectangular sheets w/1 side of 36 cm & other side of 15 cm in unfolded |
|
4813.20.00 |
Cigarette paper in rolls of a width not exceeding 5 cm |
|
4908.90.00 |
Other transfers (decalcomanias) |
|
5201.00.20 |
Cotton not carded or combed, ginned but not further processed. |
|
5201.00.90 |
Other cotton |
|
5203.00.00 |
Cotton, carded or combed |
|
5204.11.31 |
Two-ply |
|
5205.11.00 |
Cotton yarn (other than sewing thread), containing 85% or more by weight of cotton, not put up for retail sale – single yarn, of uncombed fires measuring 714.29 decitex or more (not exceeding 14 metric number) |
|
5208.21.00 |
Other fabrics, bleached: plain weave, weighing not more than 100 g/m² |
|
5208.31.00 |
Other fabrics, dyed: plain weave, weighing not more than 100 g/m² |
|
5208.32.00 |
Other fabrics, dyed: plain weave, weighing more than 100 g/m² |
|
5208.33.00 |
3- thread or 4- thread twill, including cross twill |
|
5208.42.00 |
Other fabrics, of yarns of different colors: plain weave, weighing more than 100 g/m² |
|
5208.49.00 |
Woven fabrics of cotton, 85%, not more than 200 g/m² |
|
5208.52.00 |
Other fabrics, printed plain weave, weighing more than 100 g/m² |
|
5208.59.00 |
Other fabrics |
|
5209.22.00 |
Bleached 3- or 4-thread twill fabrics of cotton, including cross twill, 85 percent or more cotton by weight, weighing more than 200 g/m2 |
|
5209.29.00 |
Bleached woven fabrics of cotton, nesoi, containing 85% or more cotton by weight, weighing more than 200g/m2 |
|
5209.32.00 |
Dyed 3- or 4-thread twill fabrics of cotton, including cross twill, containing 85% or more cotton by weight, weighing more than 200 g/m2 |
|
5209.39.00 |
Dyed woven fabrics of cotton, nesoi, containing 85% or more cotton by weight, weighing more than 200 g/m2 |
|
5209.41.00 |
Woven fabrics of cotton, plain weave, containing 85% or more by weight of cotton, weighing more than 200 g/square meter, of yarns of different colors, plain weave |
|
5209.42.10 |
Woven fabrics of cotton, containing 85 percent or more by weight of cotton, weighing more than 200 g/m2; Bleached; Blue Denim |
|
5209.49.00 |
Other woven fabrics of cotton, containing 85% or more by weight of cotton, weighing more than 200 g/square meter, of yarns of different colors |
|
5209.51.00 |
Plain weave, woven fabrics of cotton, plain weave, containing 85% or more by weight of cotton, weighing more than 200 g/square meter, printed |
|
5209.59.00 |
Other woven fabrics of cotton, containing 85% or more by weight of cotton, weighing more than 200 g/square meter, printed |
|
5210.21.00 |
Woven fabrics of cotton, plain weave, containing less than 85% by weight of cotton, mixed mainly or solely with man-made fibers, weighing not more than 200 g/square meter, bleached |
|
5210.41.00 |
Woven fabrics of cotton, plain weave, containing less than 85% by weight of cotton, mixed mainly or solely with man-made fibers, weighing not more than 200 g/square meter of yarns of different colors |
|
5210.51.00 |
Woven fabrics of cotton, plain weave, containing less than 85% by weight of cotton, mixed mainly or solely with man-made fibers, weighing not more than 200 g/square meter, dyed |
|
5211.39.00 |
Other woven fabrics of cotton, containing less than 85% by weight of cotton, mixed mainly or solely with man-made fibers, weighing more than 200 g/square meter, dyed |
|
5211.43.00 |
Woven fabrics of cotton, 3-thread or 4-thread twill, containing less than 85% by weigh of cotton, mixed mainly or solely with man-made fibers, weighing more than 200 g/m2, of yarns of different colors |
|
5211.49.00 |
Other woven fabrics of cotton, containing less than 85% by weight of cotton, mixed mainly or solely with man-made fibers, weighing more than 200g/square meter, of yarns of different colors |
|
5211.59.00 |
Other woven fabrics of cotton, containing less than 85% by weight of cotton, mixed mainly or solely with man-made fibers, weighing more than 200g/square meter, printed |
|
5212.13.00 |
Other woven fabrics of cotton, dyed, weighing not more than 200 g/square meter |
|
5212.15.00 |
Other woven fabrics of cotton, printed, weighing not more than 200 g/square meter |
|
5212.24.00 |
Other woven fabrics of cotton, of yarn of different colors, weighing more than 200 g/square meter |
|
5407.42.00 |
Woven fabrics, containing 85 percent or more by weight of filaments of nylon or other polyamides, dyed |
|
5601.21.90 |
Other articles of wadding |
|
5603.12.10 |
Non wovens, of man-made filaments, weighing >25 but not >70 g/square m, whether or not impregnated, coated, covered or laminated, of high density polyethylene |
|
5603.12.90 |
Other non wovens, of man-made filaments, weighing >25 but not >70 g/square m, whether or not impregnated, coated, covered or laminated |
|
5603.13.90 |
Other non wovens, of man-made filaments, weighing >70 but not >150 g/square m, whether or not impregnated, coated, covered or laminated |
|
5603.14.90 |
Non wovens (except laminated), of man-made filaments, weighing >150 g/square m, whether or not impregnated, coated, or covered |
|
5608.90.00 |
Knotted netting of twine, cordage or rope, of other materials; made up fishing nets and other made up nets, of other textile materials |
|
5703.20.00 |
Carpets and other floor coverings, tufted, whether or not made up, of nylon or other polyamides. |
|
5806.31.00 |
Carpets and other floor coverings, tufted, whether or not made up, of nylon or other polyamides. |
|
5903.90.00 |
Other textile fabrics impregnated, coated, covered or laminated with plastics, other than those of heading No. 59.02 |
|
5907.00.00 |
Textile fabrics otherwise impregnated, coated or covered; painted canvas being theatrical scenery, studio back-cloths or the like |
|
6006.21.00 |
Circular knit, wholly of cotton yarns exceeding 100 metric number per single yarn, unbleached or bleached |
|
6006.22.00 |
Circular knit, wholly of cotton yarns exceeding 100 metric number per single yarn, dyed |
|
6006.23.00 |
Circular knit, wholly of cotton yarns exceeding 100 metric number per single yarn, of fabrics of different colors |
|
6101.20.00 |
Men's or boys' overcoats, car-coats, capes, cloaks, anoraks (including ski-jackets), wind-cheaters, wind-jackets and similar articles (other than those of subgroup 843.2), of cotton |
|
6102.20.00 |
Women's or girls' overcoats, car-coats, capes, cloaks, anoraks (including ski-jackets), wind-cheaters, wind-jackets and similar articles, knitted or crocheted, other than those of heading No. 61.04, of cotton |
|
6104.32.00 |
Women's or girls' jackets and blazers, knitted or crocheted, of cotton |
|
6104.42.00 |
Women's or girls' dresses, knitted or crocheted, of cotton |
|
6104.62.00 |
Women's or girls' trousers, bib and brace overalls, breeches and shorts (other than swimwear), knitted or crocheted, of cotton |
|
6106.10.00 |
Women's or girls' blouses and shirts, knitted or crocheted, of cotton |
|
6109.10.00 |
T-shirts, singlets, tank tops and similar garments, knitted or crocheted, of cotton |
|
6110.20.00 |
Sweaters, pullovers and similar articles, knitted or crocheted, of cotton, containing 36 percent or more of flax fibers |
|
6111.20.00 |
Babies' blouses and shirts, except those imported as parts of sets, knitted or crocheted, of cotton |
|
6115.95.00 |
Stockings, socks and other hosiery, knitted or crocheted, of cotton |
|
6116.10.00 |
Gloves impregnated, coated or covered with plastics or rubber |
|
6116.92.00 |
Other gloves, mittens and mitts, knitted or crocheted, of cotton |
|
6203.42.00 |
Trousers, bib and brace overalls, breeches and shorts of cotton |
|
6204.42.00 |
Dresses, of cotton |
|
6204.62.00 |
Women/girls trousers and shorts, of cotton, not knitted |
|
6205.20.00 |
Men's or boys' shirts, of cotton |
|
6206.30.00 |
Women's or girls' blouses, shirts and shirt-blouses, of cotton |
|
6207.91.00 |
Other clothing, of cotton |
|
6213.20.00 |
Handkerchiefs of cotton |
|
6302.21.00 |
Other bed linen, printed of cotton |
|
6302.31.00 |
Other bed linen of cotton |
|
6303.92.00 |
Other curtains (including drapes) and interior blinds; curtain or bed valances, knitted or crocheted of synthetic fibers |
|
6307.90.10 |
Other made up articles, including dress patterns, of nonwovens |
|
6307.90.90 |
Other made up articles, including dress patterns |
|
7019.39.00 |
Nonwoven glass wool insulation products |
|
7019.59.00 |
Other woven fabrics |
|
7113.19.00 |
Articles of jewelry and parts thereof, of precious metal or of metal clad with precious metal, of other precious metal, whether or not plated or clad with precious metal |
|
7208.39.90 |
Other iron/nonalloy steel |
|
8212.10.20 |
Razors |
|
8212.20.10 |
Razor blades |
|
8407.21.90 |
Other outboard motors |
|
8415.90.00 |
Parts of air conditioning machines |
|
8418.40.00 |
Freezers of the upright type, not exceeding 900 liters capacity, electric or other |
|
8418.50.10 |
Refrigerating or freezing display counters, cabinets, showcases and similar refrigerating or freezing furniture |
|
8433.11.00 |
Mowers for lawns, parks or sports grounds, powered, with the cutting device rotating in a horizontal plane |
|
8471.90.12 |
Bar code readers |
|
8506.10.10 |
Alkaline batteries |
|
8506.80.90 |
Other primary batteries |
|
8516.60.00 |
Other ovens; cookers, cooking plates, boiling rings, grillers and roasters |
|
8517.12.31 |
Portable phones |
|
8517.78.10 |
Intercoms |
|
8518.10.90 |
Other piezoelectric |
|
8518.21.00 |
Single loudspeakers, mounted in their enclosures |
|
8518.22.00 |
Multiple loudspeakers, mounted in the same enclosure |
|
8518.30.00 |
Headphones and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or more loudspeakers |
|
8518.40.00 |
Audio-frequency electric amplifiers |
|
8518.50.00 |
Electric sound amplifier sets |
|
8521.90.90 |
Other combined recording and reproducing apparatus |
|
8525.80.19 |
Other television cameras |
|
8525.80.29 |
Other digital still image video cameras |
|
8527.21.90 |
Other radio-broadcast receivers, including apparatus capable of receiving also radio-telephony or radio- telegraphy |
|
8528.49.29 |
Other screens |
|
8703.21.00 |
Vehicles of a cylinder capacity not exceeding 1 000 cc |
|
8703.23.10 |
Vehicles with a seating capacity of not more than 6, including the driver, w/cyl. cap. o/1500 cc n/o 3000 cc |
|
8703.24.10 |
Vehicles with a seating capacity of not more than 6, including the driver, w/cyl. cap. o/ 3000 cc |
|
8703.24.90 |
Other vehicles with compression ignition internal combustion piston engine (diesel or semidiesel) |
|
8703.33.10 |
Vehicles with a seating capacity of not more than 6, including the driver, of a cylinder capacity exceeding 2,500 cc |
|
8711.50.00 |
Motorcycles, cycles, with reciprocating internal combustion piston engine of a cylinder capacity exceeding 800 cc |
|
8903.92.00 |
Vessels, motorboats (o/than outboard motorboats), for pleasure or sports |
|
8903.99.00 |
Other boats |
|
9001.30.00 |
Contact lenses |
|
9004.10.00 |
Sunglasses |
|
9008.30.00 |
Other image projectors |
|
9018.19.10 |
Endoscopy apparatus |
|
9018.19.80 |
Other electro-diagnostic apparatus |
|
9018.19.90 |
Parts of electro-diagnostic apparatus |
|
9018.32.19 |
Other chromium-nickel alloy needles |
|
9018.39.10 |
Needles |
|
9018.39.24 |
Peripheral intravenous catheters, of polyurethane or of ethylene tetrafluoroethylene copolymers (ETFE) |
|
9018.39.29 |
Other peripheral intravenous catheters |
|
9018.90.24 |
Endoscopy apparatus |
|
9019.20.10 |
Oxygen therapy apparatus |
|
9019.20.19 |
Other artificial respiration apparatus |
|
9021.10.20 |
Splints and other fracture appliances |
|
9021.31.10 |
Femoral appliances |
|
9021.31.90 |
Other orthopedic appliances |
|
9021.39.19 |
Other valves |
|
9021.39.80 |
Other artificial parts of the body |
|
9021.90.89 |
Other stents |
|
9021.90.99 |
Other skin substitutes |
|
9022.14.90 |
Other apparatus based on the use of X-rays |
|
9022.30.00 |
X-ray tubes |
|
9022.90.80 |
Other X-ray apparatus |
|
9022.90.90 |
Parts and accessories of X-ray apparatus |
|
9102.11.10 |
Parts and accessories (not specified or included elsewhere in this Chapter) for machines, appliances, instruments or apparatus of Chapter 90, with case of base metal |
|
9401.20.00 |
Locks of a kind used for motor vehicles |
|
9401.30.90 |
Other seats |
|
9403.70.00 |
Furniture of plastics |
|
9506.91.00 |
Articles and equipment for general physical exercise, gymnastics or athletics |
|
9603.21.00 |
Tooth brushes, including dental-plate brushes |
|
9701.10.00 |
Paintings, drawings and pastels |
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On April 15, 2024, the Acting Assistant Attorney General for the Criminal Division of the Department of Justice (“DOJ”) Nicole Argentieri announced a new Pilot Program on Voluntary Self-Disclosure for Individuals (“Pilot Program” or “Program”). The Pilot Program offers a clear path for voluntary self-disclosure by certain corporate executives and other individuals who are themselves involved in misconduct by corporations, in exchange for a Non-Prosecution Agreement (“NPA”). The Pilot Program specifically targets individuals who disclose to the Criminal Division at DOJ in Washington, D.C. information about certain corporate criminal conduct. By carving out a clear path to non-prosecution for those who qualify, DOJ has created another tool to uncover complex crimes that might not otherwise be reported to the Department.
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