EU-Mercosur Sector
Chemicals & Pharmaceuticals
Full tariff elimination within 10 years for most chemical products. Immediate 0% for organic chemicals and vaccines. ANVISA registration still required.
Tariff reduction schedule
| HS | Product | MFN | Year 0 | Year 4 | Year 10 | Cat. |
|---|---|---|---|---|---|---|
| 2811–2819 | Inorganic chemicals (acids, oxides) | 10–14% | 7% | 3.5% | 0% | A10 |
| 2901–2942 | Organic chemicals | 10–14% | 0% | 0% | 0% | E0 |
| 3002 | Vaccines, blood products | 8% | 0% | 0% | 0% | E0 |
| 3003–3004 | Pharmaceuticals (dosage forms) | 8–10% | 6% | 3% | 0% | A10 |
| 3208–3210 | Paints, varnishes, lacquers | 14–18% | 14% | 10.5% | 0% | B10 |
| 3301–3307 | Essential oils, perfumery, cosmetics | 18% | 14.4% | 9% | 0% | A10 |
| 3401–3402 | Soaps, detergents, surfactants | 14–18% | 14% | 10.5% | 0% | B10 |
| 3808 | Insecticides, herbicides, fungicides | 14% | 11.2% | 7% | 0% | A10 |
| 3901–3914 | Plastics in primary forms | 14% | 11.2% | 7% | 0% | A10 |
| 3917–3926 | Plastics articles | 16–18% | 16% | 12% | 0% | B10 |
Tariff ≠ market access
Pharmaceuticals, cosmetics, and agrochemicals require regulatory approval (ANVISA, IBAMA, MAPA) regardless of the tariff rate. Zero duty doesn't mean zero barriers — ANVISA registration can take 6–24 months and requires a Brazilian company as holder. Plan regulatory approval in parallel with tariff benefit planning.
Regulatory overlay
Chemical and pharmaceutical imports face dual requirements: tariff (customs) AND regulatory (agency approval). The EU-Mercosur agreement reduces tariffs but does not change regulatory requirements:
Pharmaceuticals (HS 30)
ANVISA registration mandatory. Each drug must be registered individually. Timeline: 6–24 months. GMP inspection of foreign manufacturing site required. The agreement includes mutual recognition of GMP inspections — this can reduce ANVISA inspection delays.
Cosmetics (HS 33)
ANVISA notification/registration. Grade 1 (15 days), Grade 2 (30–180 days). INCI nomenclature now aligned with EU standard. EU-Mercosur includes cosmetics harmonization provisions.
Agrochemicals (HS 3808)
Triple approval: IBAMA + MAPA + ANVISA. The most complex regulatory path in Brazilian imports. EU-Mercosur includes SPS cooperation provisions but doesn't eliminate the triple-approval requirement.
Industrial chemicals (HS 28–29)
IBAMA CTF registration for controlled substances. Rotterdam Convention compliance. SDS (Safety Data Sheet) required in Portuguese.
Rules of Origin for chemicals
- Chapters 28–29 (inorganic/organic chemicals): CTSH (change of tariff subheading) or MaxNOM 50%. Chemical reaction rule: products obtained by chemical reaction in the EU qualify regardless of input origin.
- Chapter 30 (pharmaceuticals): CTH or MaxNOM 50%. Active ingredient must be manufactured in the EU (synthesis or extraction).
- Chapters 32–38 (formulated products): CTH or MaxNOM 50%. Formulation (mixing, blending) in the EU generally qualifies as sufficient transformation.
- Chapter 39 (plastics): CTH or MaxNOM 50%. Polymerization in the EU qualifies. Extrusion/molding of non-originating pellets may not be sufficient alone.
Key EU exporter countries
- Germany — BASF, Bayer, Merck. Largest EU chemical exporter to Brazil. Pharmaceuticals and specialty chemicals.
- France — Sanofi, L'Oréal, Air Liquide. Pharmaceuticals, cosmetics, industrial gases.
- Netherlands — DSM, AkzoNobel. Specialty chemicals and coatings.
- Belgium — Solvay, UCB. Polymers and pharmaceuticals.
- Ireland — pharmaceutical manufacturing hub for EU (Pfizer, MSD).