11/21/2025
U.S. Eases Tariffs on Select Brazilian Agricultural Imports Following Progress in Bilateral Talks
Check out this week's Customs Corner to read about tariffs on Brazilian imports, a trade agreement framework with Switzerland and Liechtenstein, and more.
Trade and Customs Updates
1) U.S. Eases Tariffs on Select Brazilian Agricultural Imports Following Progress in Bilateral Talks
The United States government has announced a revision of tariffs on specific agricultural imports from Brazil, citing initial progress in ongoing negotiations between the two countries.
The decision follows an October 6, 2025, call between President Donald Trump and Brazilian President Luiz Inácio Lula da Silva, during which both leaders agreed to initiate talks aimed at addressing issues outlined in Executive Order 14323. This order, initially enacted in response to a declared national emergency, imposed additional 40% duties on certain Brazilian goods.
U.S. officials, who have been closely monitoring the situation as directed by President Trump, recommended reconsidering the additional tariffs in light of recent diplomatic developments. According to their assessment, select agricultural products from Brazil have shown sufficient progress in the negotiation process to warrant removal from the list of goods subject to increased tariffs.
After reviewing these recommendations and evaluating the status of discussions with Brazil, President Trump determined that adjusting the scope of the affected products is both necessary and appropriate. As a result, certain Brazilian agricultural imports will no longer face the extra 40% duties previously mandated under Executive Order 14323.
The updated list of exempt products is detailed in the revised Annex I to the order, with changes taking effect for goods entered for consumption, or withdrawn from warehouses for consumption, starting at 12:01 a.m. EST on November 13, 2025. The Harmonized Tariff Schedule of the United States has also been amended accordingly, as outlined in Annex II of the order.
The Secretary of State will continue to monitor developments related to the national emergency specified in Executive Order 14323 and will provide regular updates and recommendations to the President, ensuring that U.S. policy responds appropriately to any changes in circumstances.
Negotiations with Brazil remain ongoing as both nations work toward a resolution of the outstanding issues.
References:
- Modifying the Scope of Tariffs on the Government of Brazil – The White House
- 2025NovemberBrazilTariff.ANNEXES.pdf
- CSMS # 66871909 - UPDATE: Agricultural Products Exempted from Brazil Tariffs
2) President Trump Announces Trade Deal Framework with Switzerland and Liechtenstein
President Trump has unveiled a framework for a trade agreement with Switzerland and Liechtenstein, promising access for U.S. exporters and new investments across America. The “Agreement on Reciprocal, Fair, and Balanced Trade” aims to eliminate trade barriers, open Swiss and Liechtenstein markets to a wide range of American products, and drive job creation in sectors from pharmaceuticals and manufacturing to agriculture and energy.
Key Highlights of the Trade Framework:
- Market Access: The agreement will grant U.S. manufacturers, farmers, ranchers, and other producers access to Swiss and Liechtenstein markets.
- Major Investments: Swiss and Liechtenstein companies have pledged to invest at least $200 billion in the United States, with $67 billion targeted for 2026. Major Swiss firms such as Roche, Novartis, ABB, and Stadler are expected to announce new projects.
- Tariff Reductions: Both countries plan to remove a range of tariffs on U.S. agricultural and industrial goods, including nuts, seafood, fruits, chemicals, and spirits. Tariff rate quotas will be established for American poultry, beef, and bison.
- Addressing Non-Tariff Barriers: The agreement will tackle decades-old restrictions, streamline customs procedures, open markets for U.S. medical devices, and enhance protection for intellectual property rights.
- Labor and Environmental Commitments: Swiss and Liechtenstein enterprises will invest in American workers through apprenticeships and training, while both nations commit to high environmental standards and cooperation on labor issues.
- Digital Trade and Supply Chain Security: The deal includes digital trade principles, a commitment to avoid harmful digital services taxes, and measures to strengthen supply chain resilience.
- Government Procurement Reforms: Switzerland and Liechtenstein will close loopholes in procurement markets, ensuring greater access for U.S. products and services.
- National Security Cooperation: The framework expands joint efforts on export controls, sanctions, and investment screening.
Negotiations are expected to conclude in early 2026, aiming to eliminate the U.S. goods trade deficit with Switzerland and Liechtenstein—$38.5 billion in 2024—by 2028.
Reference:
3) U.S. and South Korea Affirm Tariff Changes Under Strategic Trade and Investment Deal
Key Tariff Updates:
- Reciprocal Tariff Application: The United States will apply the higher of either the U.S.-Korea Free Trade Agreement (KORUS FTA) or Most Favored Nation (MFN) tariff rate, or a flat 15% tariff—whichever is greater—on qualifying South Korean goods, in line with Executive Order 14257.
- Section 232 Tariff Reductions: The U.S. will lower its Section 232 tariffs on South Korean automobiles, auto parts, timber, lumber, and wood products to 15%. For these items, if the KORUS FTA or MFN tariff rate is already 15% or higher, no additional Section 232 tariff will apply; if it is lower, the combined tariffs will total 15%.
- Pharmaceuticals and Semiconductors: Section 232 tariffs on South Korean pharmaceuticals will be capped at 15%. For semiconductors and related equipment, South Korea will receive terms at least as favorable as any future agreements covering comparable trade volumes.
- Tariff Removals: The United States will eliminate additional tariffs imposed under Executive Order 14257 on certain products, including generic pharmaceuticals, their ingredients and precursors, specific natural resources unavailable domestically, and certain aircraft and aircraft parts from South Korea.
These measures are designed to further strengthen economic ties between the two nations, providing clarity for importers and exporters and promoting investment and job growth on both sides of the Pacific.
An effective date is yet to be established.
References:
4) CBP Detains Mauritius Garments Over Forced Labor Concerns in Action Against Firemount Group Ltd.
U.S. Customs and Border Protection (CBP) has issued a Withhold Release Order (WRO) against Firemount Group Ltd., a Mauritius-based manufacturer of garments, apparel, and textiles, effectively detaining all such imports at U.S. ports due to evidence indicating the use of forced labor. This marks the fourth WRO issued in 2025 and the first of Fiscal Year 2026, as CBP continues to enforce 19 U.S.C. §1307, which prohibits the importation of goods produced with forced labor.
The decision follows a CBP investigation that analyzed a range of evidence, including interviews, audio recordings, transcripts, NGO reports, news articles, and academic research. Findings revealed that workers at Firemount were subjected to four International Labour Organization indicators of forced labor: abuse of vulnerability, debt bondage, deception, and intimidation or threats. According to CBP, these indicators provided reasonable suspicion that forced labor was used in the production process.
“CBP issues WROs on companies that use forced labor to the detriment of law-abiding businesses. CBP’s action protects and promotes American economic prosperity,” stated CBP Commissioner Rodney S. Scott. Acting Executive Assistant Commissioner Susan S. Thomas added, “Not only is forced labor inhumane, but it also creates unfair competition that harms American businesses and consumers. CBP stands ready to enforce our laws and ensure a level playing field.”
Importers whose shipments are detained may choose to export or destroy the goods or provide proof that the merchandise was not produced with forced labor. With the Firemount WRO, CBP now oversees and enforces 54 active WROs and nine Findings under Section 1307.
Reference:
CBP issues Withhold Release Order on Firemount Group Ltd. | U.S. Customs and Border Protection
5) FDA Supplemental Guide Version 2.6: Upcoming System Deployments and Key Changes for Trade
The U.S. Food and Drug Administration (FDA) has announced two upcoming system deployments related to the Supplemental Guide (SG) version 2.6, as detailed in Customs and Border Protection (CBP) message CSMS 66347264. These changes will impact how trade participants submit certain data elements and validations for FDA-regulated products.
Production Deployment – November 20, 2025 (Warnings Severity):
- PG01 & PG02 Records: New validation will require the PIC code in the Product Code to be ‘A’ for consumer use products if the Processing Code is ‘CSU’.
- PG01 & PG06 Records: Enhanced validation for U.S. goods returned; IUC 920.000 must include Source Type Code ‘39’ and Country Code ‘US’ or ‘PR’.
- PG23 Record: Updated syntax for the Tobacco Submission Tracking (TST) Number Affirmation of Compliance qualifier.
CBP Certification Environment Deployment – November 21, 2025 (Reject Severity):
- PG01 & PG02 Records: Same consumer use product validation as above.
- PG01 & PG06 Records: Same enhanced U.S. goods returned validation as above.
- PG23 Record: Updated TST Number Affirmation of Compliance qualifier syntax.
- PG01: Intended Use Code (IUC) requirements will be enforced for all processing codes.
- PG07: Trade Name is only required for Processing Code CSU (Consumer Use).
- PG23: The following Affirmation of Compliance Codes will no longer be accepted: ‘SE’ (Substantially Equivalent), ‘EXE’ (Exemption from Substantial Equivalence), and ‘PMT’ (Premarket Tobacco Application).
- PG23: New Affirmation of Compliance Codes will be accepted with qualifier: ‘FLV’ (flavor), ‘NIC’ (nicotine concentration), and ‘PID’ (product identification number).
The draft of FDA Supplemental Guide version 2.6 can be found in the Draft Chapters: Future Capabilities section of the CATAIR.
Reference:
6) CBP to End Use of Document Image System for Outbound Cargo Declarations Effective December 1, 2025
U.S. Customs and Border Protection (CBP) has announced that, effective December 1, 2025, the Document Image System (DIS) will no longer be accepted for submitting outbound cargo declarations, including CBP Form 1302A, supplemental form CBP 168, and related outbound cargo manifest documents.
Starting December 1, carriers and vessel agents must submit these documents either as hard copies directly to the port of departure or electronically through the Electronic Export Manifest (EEM) system using Electronic Data Interchange (EDI) via the Automated Commercial Environment (ACE) EEM application. The option to submit outbound cargo declarations via port email inboxes will be discontinued, though CBP officers may still request additional documents by email when needed.
For more information on the EEM process or to join the pilot program, visit the CBP ACE EEM webpage. Those not participating in EEM must ensure all outbound cargo declarations are submitted on paper at the port.
Reference:
CSMS # 66811171 - CBP Set to Disable Submission of Export Manifest via DIS on December 1
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