Brazil Resolução Gecex nº 823/2025 — Ex-Tarifário Capital-Goods Duty-Relief Rebalancing (2,414 products)

Mechanism

Brazil operates a standing "ex-tarifário" regime: temporary (typically 2-year) reductions of the import duty — often to 0% — on capital-goods (BK) and IT/telecom-goods (BIT) tariff lines for which no equivalent domestic production exists. The regime is administered through periodic GECEX resolutions that add newly-approved exemptions and retire expired or successfully-domesticated ones. Resolução nº 823/2025 is one such periodic rebalancing cycle:

• Article 1 — removes a batch of ex-tarifário codes from Annex I of the

base Resolução nº 322/2022, meaning those specific NCM/ex-number combinations lose their temporary duty relief and revert to Brazil's standard Mercosur Common External Tariff (TEC) rate.

• Article 2 — adds a new batch of ex-tarifário codes to the Annex Único

of Resolução nº 780/2025 (the current "active exemptions" register), granting duty relief to a different set of products through 2027.

• Articles 3-4 — correct/refine the technical descriptions of eleven

specific line items without changing their duty treatment.

GTA's count of 2,414 products / 317 six-digit NCM headings spans both the exclusion and inclusion sides of this rebalancing — it is not a uniform tariff hike, but a routine net reshuffle of which capital-goods imports qualify for relief at any given time. A same-day rectification (published alongside the resolution) moved a handful of entries between Articles 3 and 4 and dropped one duplicated line, without altering rates or scope.

Downstream implications

• Products dropped from the exemption annex face an immediate step-up to

the standard TEC rate on their next import shipment — a real cost increase for importers who had built sourcing plans around the ex-tarifário relief, even though the mechanism itself is administrative housekeeping rather than a new protectionist initiative.

• The offsetting Article 2 inclusions extend duty relief on a different set

of capital-goods lines through 2027, continuing Brazil's policy of not taxing imported machinery that lacks a domestic substitute — relevant context alongside Brazil's broader Nova Indústria Brasil (NIB) and MOVER industrial-policy programmes, which aim to grow that domestic-substitute base over time.

• Because this is a recurring GECEX administrative cycle (similar batches

are published roughly monthly), it is a useful proxy indicator: shrinking exemption-inclusion counts over successive resolutions would signal Brazil judging more capital-goods categories "domestically served," while growing counts would signal continued reliance on imported machinery.

Open questions

• Full unredacted list of which of the 2,414 NCM/ex-number combinations were

excluded (duty relief lost) versus included (duty relief newly granted) — the aggregate GTA count does not net these apart; the full annexes are DOU attachments requiring page-level retrieval.

• Whether the excluded ex-tarifário items were retired because equivalent

domestic Brazilian production has scaled up (the regime's intended trigger) or for other administrative reasons (sunset expiry, applicant non-renewal).