Brazil Resolução GECEX Nº 842/2025 — 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) is a standing tariff-engineering instrument: any auto part on the list that has no confirmed domestic manufacturer can be imported by a vehicle assembler at a preferential ~2% duty instead of Brazil's normal Mercosur Common External Tariff rate for auto parts (typically 14–18%). Firms petition to add or remove NCM lines as domestic manufacturing capacity for a given part emerges or disappears.

Resolução Gecex Nº 842 (23 December 2025, DOU 24 December 2025, in force 1 January 2026 — seven days after publication) is the year-end housekeeping update to that list:

• Annex I (removals, 5 lines): NCM 8409.99.99 (engine parts), 8511.40.00, 8536.50.90, 8536.90.40

(electrical connectors/switchgear) are struck from the exemption list, meaning imports of those parts revert to the standard duty — a signal that Gecex judged domestic production capacity now covers those lines.

• Annex II (additions, 17 lines, sunset 31 Dec 2027): hybrid/EV-specific components — high-voltage

lithium-ion battery packs (NMC and LFP chemistries) for PHEV/HEV platforms, oil coolers and oil collectors for hybrid drivetrains, brake pads and transmission parts — gain the preferential ~2% duty, temporarily, while domestic HEV/PHEV component supply chains mature.

• Annex III (additions, 21 lines, sunset 31 Dec 2027): mining and heavy-equipment parts (gears,

electrical switches, hydraulic systems, industrial displays) added to the same regime.

Downstream implications

• Net effect is input-cost relief for Brazil-based hybrid/EV assembly (batteries, drivetrain

components) and mining-equipment manufacturing, time-boxed to end-2027 — consistent with Brazil's broader push (Rota 2030 / Mover programme) to localise electrified-vehicle production. Beneficiaries are import-dependent EV/HEV assemblers operating in Brazil.

• The five-line removal is a mirror-image protective signal: domestic component makers for those

engine/electrical parts lose competition from duty-free imports as of 1 January 2026.

• Because the exemption is administered per-NCM-line via petition, it functions as a rolling,

low-visibility industrial-policy lever — the register should watch subsequent Gecex resolutions amending the same list (a pattern already visible with Resolução Gecex Nº 911, June 2026, which further revises Annex I/II lines set here).

Open questions

• Full company-level attribution of who petitioned for the Annex I removals vs. the EV/mining

additions was not disclosed in public summaries reviewed; the DOU text carries the complete technical annexes.

• Whether the Annex II/III 2027 sunset will be extended or made permanent once domestic component

supply is assessed, as has happened with prior tranches of this list.

• Precise standard (non-exempt) duty rate reverted to on the five Annex I NCM lines was not

independently confirmed beyond the general ~14–18% Mercosur CET auto-parts range.