Selling to the EU from Brazil

Yes, provisionally. After more than twenty-five years of negotiation the EU–Mercosur agreement has been provisionally applied since 1 May 2026, covering Argentina, Brazil, Paraguay and Uruguay. It enters into force formally once the European Parliament has given its consent. Provisional application means the tariff preferences are usable now, on the usual condition that you meet the origin rule and hold the proof.

Hard. Coffee, soy, cocoa, cattle, rubber, palm oil and wood from Brazil all fall under the EUDR: geolocation of the plots, proof of no deforestation after 31 December 2020, and a due diligence statement before customs. Delayed to 30 December 2026 for large operators; use the delay to build the plot-level data collection now.

No. It changes duty, and only duty; what that means for a shipment today is in the trade-agreement answer at the top of this page. Product law is a separate system that no trade agreement reaches: the EUDR due diligence statement, REACH restrictions, the GPSR Responsible Person and the labelling duties apply to Brazilian goods exactly as they apply to goods from a country with no agreement at all. A preference lowers the rate you pay at the border; it does not remove a single document you have to produce to get there.

Yes: any consumer product sold in the EU needs a Responsible Person established inside the Union, whether it comes from Brazil, China or anywhere else. A Brazilian company cannot take the role itself.

Three: EUDR (deforestation-free with plot geolocation), the EU Timber Regulation (until EUDR fully replaces it; legality of harvest), and GPSR for the consumer product itself. Forest-product exporters from Brazil carry one of the heaviest compliance loads in the entire system.

The obligation sits with the authorised CBAM declarant, not with you, but the data has to come from you. That declarant is the importer established in a member state; where the importer is established outside the EU it is his indirect customs representative. The definitive regime applies from 1 January 2026.

Threshold. He is exempt for as long as the net mass he imports in a calendar year, added up over iron and steel, aluminium, cement and fertilisers, does not pass 50 tonnes (Article 2a, with the figure in Annex VII, point 1). Once he passes it in a calendar year, the obligations apply to the embedded emissions of that whole year. The threshold counts per importer, not per shipment and not per supplier. It does not apply to hydrogen or to electricity (Article 2a(4)): for those he is in scope from the first consignment, however small.

Authorisation. The goods may only be released for free circulation by an authorised CBAM declarant, or by his indirect customs representative (Article 4; application under Article 5). Transitional rule: where the application is submitted by 31 March 2026, he may keep importing during 2026 for as long as the competent authority has not decided. If it is refused afterwards, a penalty follows on the emissions imported in the meantime.

Certificates. There are no CBAM certificates on sale in 2026. Sales start on 1 February 2027 (Article 20(1)). For import year 2026 the CBAM declaration is filed and the certificates are surrendered by 30 September 2027 (Article 22). The cost counts in his margin from 2026, but the cash leaves in 2027.

What he will ask you for. Which goods are in scope is decided by the CN code in Annex I: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. For those he chooses how the embedded emissions are determined: from the actual emissions of the installation, or from default values (Article 7(2)). He is not required to ask you first, and not required to show that actual data cannot be obtained. It is a cost calculation, not a penalty. Default values are set at the average emission intensity of the exporting country, raised by a mark-up fixed in implementing acts; where reliable data for the exporting country is missing, the average emission intensity of the ten exporting countries with the highest emission intensity is used instead. Against that, only actual emissions have to be checked by an accredited verifier (Article 8(1)), so working from default values saves him that verification. Your figures are worth buying when your installation is cleaner than the country average plus mark-up by more than the verification costs; for an installation dirtier than that average, the default value can be the better deal for him.

The provider list covers EUDR specialists and Responsible Person services. Or ask for three introductions.