Brazil Resolução GECEX Nº 826/2025 — December Amendment to the Non-Produced Auto Parts Tariff-Exemption List

Mechanism

Brazil's "Lista de Autopeças Não Produzidas" (Resolução Gecex Nº 284, 21 December 2021) lets vehicle assemblers import auto parts that have no confirmed domestic manufacturer at a preferential ~2% duty instead of the standard Mercosur Common External Tariff rate for auto parts (typically 14-18%). The list is amended periodically as domestic component-manufacturing capacity emerges or disappears, and firms petition Gecex to add or remove specific NCM lines.

Resolução Gecex Nº 826 (4 December 2025, DOU 5 December 2025, in force 12 December 2025) is one such periodic update, tracked by Global Trade Alert as two linked interventions under the same state act:

• Removals (17 products / 15 NCM lines): these parts are struck from the exemption list and

revert to the standard duty — a signal that Gecex judged domestic production capacity now covers those lines. GTA classifies this intervention as "certainly harmful" (an import-tariff increase).

• Additions (24 products / 17 NCM lines): these parts gain the preferential ~2% duty,

time-boxed with a sunset of 30 November 2027. GTA classifies this intervention as "liberalising" (a tax/duty-relief measure).

Both product-and-NCM-code-level details sit behind Global Trade Alert's paywall; the underlying legal text (DOU/MDIC primary sources above) carries the full annexes.

This is the same standing instrument later amended again by Resolução Gecex Nº 842 (23 December 2025, filed separately as 2025-12-23-brazil-gecex-842-auto-parts-list-amendment), which removed a further 5 lines and added 38 new ones (17 EV/hybrid, 21 mining/heavy-equipment) — confirming this list is revised on a near-monthly cadence rather than as one-off events.

Downstream implications

• Net effect is the same rolling industrial-policy lever documented in the 842 filing: input-cost

relief for assemblers on the newly-added lines, offset by the loss of duty-free access for domestic component makers competing on the 17 removed lines.

• Because product-level NCM detail is paywalled at the GTA source, and the DOU text was not

parseable via automated fetch during filing, the specific components affected are not independently confirmed beyond GTA's category descriptions (motor vehicles/trailers/transport equipment; plastics products; electric motors/generators; insulated wire and cable).

• The register should keep tracking this list's cadence — three amendments (826, 842, and the

911/June-2026 amendment referenced in the 842 filing) in roughly six months indicates an active, fast-moving tariff-engineering channel rather than a static exemption regime.

Open questions

• Exact NCM codes and the specific ~2%-vs-standard duty spread for the 17 removed and 24 added

lines were not independently confirmed; GTA gates this detail behind a login wall and the DOU full text could not be automatically retrieved during filing.

• Whether the 30 November 2027 sunset on the additions differs materially from the 31 December

2027 sunset set on the EV/mining additions in the later Resolução 842 (both could reflect the same programme window, or drift as further amendments are made).