At 4 p.m., Brazil's final tariff list was missing. The concentration share was unknowable.

Reuters reported on July 15 that three people familiar with the matter expected Washington to announce a new 25% tarifftariffA tariff is a tax charged on an imported product, usually collected from the importer when the goods enter the country. affecting more than 4,000 Brazilian products and about US$15 billion in annual trade. That was reporting about an expected decision, not a published decision. [Reuters](https://www.reuters.com/world/americas/brazil-braces-new-us-tariffs-washington-broadens-trade-push-sources-say-2026-07-15/)

The official record did establish that July 15 mattered. When USTRUSTRUSTR is the Office of the United States Trade Representative, the federal agency conducting the Brazil investigation. [USTR](https://ustr.gov/about/policy-offices/press-office/press-releases/2026/june/ustr-section-301-determination-brazils-unreasonable-acts-policies-and-practices) announced its actionability determination on June 1, it called July 15 the statutory deadline for taking responsive actionresponsive actionResponsive action is the measure USTR decides to take after an investigation, which can include additional tariffs or no action. [U.S. Code](https://uscode.house.gov/view.xhtml?req=%28title%3A19+section%3A2414+edition%3Aprelim%29). The underlying statute requires USTR to determine what action, if any, it should take and to publish that determination in the Federal RegisterFederal RegisterThe Federal Register is the U.S. government's official publication for agency rules, notices and other documents that must be made public. [National Archives](https://www.archives.gov/federal-register/public-inspection). [USTR](https://ustr.gov/about/policy-offices/press-office/press-releases/2026/june/ustr-section-301-determination-brazils-unreasonable-acts-policies-and-practices), [U.S. Code](https://uscode.house.gov/view.xhtml?req=%28title%3A19+section%3A2414+edition%3Aprelim%29)

At 4 p.m. Eastern Time, however, USTR's Brazil case page still ended with the July 6 and July 7 hearing transcripts. Its release index showed no July 15 Brazil action, and the date-specific Federal Register public-inspection page checked for this article showed no final tariff notice. [USTR case page](https://ustr.gov/trade-topics/enforcement/section-301-investigations/section-301-brazils-acts-policies-and-practices-related-digital-trade-and-electronic-payment), [USTR releases](https://www.ustr.gov/about-us/policy-offices/press-office/press-releases), [Federal Register](https://www.federalregister.gov/public-inspection/2026/07/15)

That means the narrow question has a narrow answer: the requested percentage was not calculable from the public record available at the stated time.

A percentage needs a numeratornumeratorThe numerator is the value above the line in a fraction, which in this analysis would be qualifying covered intermediate imports. and a denominatordenominatorThe denominator is the total below the line in a fraction, which in this analysis would be all covered Brazilian import value.. Here, the denominator is the 2025 customs valuecustoms valueCustoms value is generally the price paid for goods exported to the United States, excluding U.S. import duties and the freight, insurance and other costs of bringing them into the country. [U.S. Census Bureau](https://www.census.gov/foreign-trade/reference/guides/tradestatsinfo.html) of every Brazilian import covered by the final Brazil-specific action. Without the final product universe, there is no defensible total against which to divide the qualifying intermediate-goods value. [USITC DataWeb](https://www.usitc.gov/applications/dataweb/about), [U.S. Census Bureau](https://www.census.gov/foreign-trade/reference/guides/tradestatsinfo.html)

Think of it as calculating the share of a grocery bill spent on ingredients before seeing the receipt. The arithmetic is easy once the complete list exists. Until then, changing which purchases count changes both the total bill and the ingredient subtotal.

The June proposal makes that sensitivity clear. USTR proposed a 25% tariff on all goods of Brazil in principle, but excluded informational materials, donations, accompanied baggage, articles subject to Section 232 tariffs and products listed in a long annex. The proposal said its exclusions included certain raw materials, products whose taxation could cause economy-wide disruption and goods that could not be produced domestically or obtained elsewhere in sufficient quantities. [Federal Register proposal](https://public-inspection.federalregister.gov/2026-11158.pdf)

Some entries in the proposed annex carried an Ex limitation, meaning only the described portion of a tariff classification was excluded. A reliable calculation therefore cannot treat the legal document as a simple spreadsheet of whole product codes. It must also read the scope language attached to each partial exclusion. [Federal Register proposal](https://public-inspection.federalregister.gov/2026-11158.pdf)

USTR explicitly asked commenters whether products were necessary raw materials, available from alternative sources in sufficient quantities or likely to cause serious supply dislocations if taxed. Those criteria make supply availability part of the policy design itself. [Federal Register proposal](https://public-inspection.federalregister.gov/2026-11158.pdf)

That creates a selection effect. If the final action excludes products precisely because Brazil is difficult to replace, the remaining tariff basetariff baseThe tariff base is the customs value of the imports covered by the final legal action before the additional tariff is applied. [Federal Register proposal](https://public-inspection.federalregister.gov/2026-11158.pdf), [U.S. Census Bureau](https://www.census.gov/foreign-trade/reference/guides/tradestatsinfo.html) may look less concentrated than the broader U.S.-Brazil import relationship. This is an inference from USTR's stated exclusionexclusionAn exclusion removes a product from a tariff that would otherwise cover it, and an exclusion can apply to only part of a tariff classification. [Federal Register proposal](https://public-inspection.federalregister.gov/2026-11158.pdf) criteria, not evidence about what the unpublished final list contains. [Federal Register proposal](https://public-inspection.federalregister.gov/2026-11158.pdf)

The reverse is also possible if the final action restores products that the proposal excluded. Until the legal scope is public, neither direction should be assumed.

Brazil's National Confederation of Industry, known as CNI, reported on July 6 that 4,187 products representing US$14.9 billion in exports could be affected if two proposed U.S. actions were adopted. One was the Brazil-specific 25% proposal. The other was a separate forced-labor proposal under which USTR had proposed a 12.5% additional dutyadditional dutyAn additional duty is a tariff charged on top of duties that may already apply to an imported product. [Federal Register proposal](https://public-inspection.federalregister.gov/2026-11158.pdf) for Brazil and other listed economies. [CNI](https://imprensa.portaldaindustria.com.br/releases/cni-mais-de-4-mil-produtos-brasileiros-exportados-aos-eua-podem-ter-tarifa-elevada-para-375/), [USTR](https://www.ustr.gov/about/policy-offices/press-office/press-releases/2026/june/ustr-makes-findings-and-proposes-action-60-section-301-investigations-relating-failures-take-action)

CNI said 62% of those goods were intermediate goods. But its public release does not say whether 62% is the share of product categories, the share of export value or another measure. It also does not apply the requested top-three-supplier test. [CNI](https://imprensa.portaldaindustria.com.br/releases/cni-mais-de-4-mil-produtos-brasileiros-exportados-aos-eua-podem-ter-tarifa-elevada-para-375/)

Those omissions are decisive. A count-based percentage gives a tiny product line the same weight as a large one. A value-weighted percentage asks how much trade is exposed. Both can be legitimate, but they answer different questions.

The first step after publication is legal, not statistical: archive the final notice and annexannexAn annex is an attached legal list that can identify covered or excluded products and any limits on those entries. [Federal Register proposal](https://public-inspection.federalregister.gov/2026-11158.pdf), record the effective date, identify every excluded classification and preserve the wording of any partial-code limitation. The June proposal demonstrates why the scope text must be retained alongside the product codes. [Federal Register proposal](https://public-inspection.federalregister.gov/2026-11158.pdf)

The second step is to retrieve full-year 2025 U.S. imports for consumptionimports for consumptionImports for consumption are goods that have cleared U.S. Customs for domestic use, either immediately or after leaving a bonded warehouse or foreign-trade zone. [U.S. Census Bureau](https://www.census.gov/foreign-trade/reference/guides/tradestatsinfo.html) by product and country from USITC DataWeb. DataWeb provides official Commerce Department trade statistics and permits queries down to ten-digit HTS classifications. The value measure will be customs value, which excludes the tariff itself and the freight, insurance and other costs of bringing the merchandise into the United States. [USITC DataWeb](https://www.usitc.gov/applications/dataweb/about), [U.S. Census Bureau](https://www.census.gov/foreign-trade/reference/guides/tradestatsinfo.html)

The third step is economic classification. Each covered product will be matched to the United Nations BECBECBEC is the United Nations Classification by Broad Economic Categories, which groups products by economic use and distinguishes intermediate products from other uses. [UN BEC](https://unstats.un.org/unsd/trade/classifications/bec.asp) system, which separates economic use from product type and includes a specific intermediate-goods dimension. Any product that cannot be assigned unambiguously will be flagged rather than silently forced into a category. [UN BEC](https://unstats.un.org/unsd/trade/classifications/bec.asp)

The fourth step is supplier ranking. For every covered product, countries will be ordered by their 2025 customs value in the U.S. market. A product enters the numerator only if it is classified as intermediate and Brazil ranks first, second or third. The denominator remains the value of all covered Brazilian imports, including products that fail either test. [USITC DataWeb](https://www.usitc.gov/applications/dataweb/about)

The finished percentage will describe supply concentrationsupply concentrationSupply concentration describes how heavily an import market depends on one country or a small group of countries. inside the final tariff base. It will show how much covered Brazilian import value consists of production inputs for which Brazil is already among the three largest foreign suppliers.

It will not prove that U.S. importers cannot switch. A country can rank highly because it is efficient, nearby or historically established even when other suppliers have spare capacity. Conversely, a lower-ranked supplier may be unable to expand quickly because of production limits, product specifications, certification requirements or transport constraints.

The measure also will not estimate tariff revenue, consumer-price changes, company profits, output or employment. Those outcomes require evidence about import volumes after the policy change, contractual pricing, substitution and whether importers pass costs to customers. This article reports neither a market reaction nor an economic effect.

For now, withholding the percentage is the substantive finding. The available trade databases can answer the question, but only after the government publishes the legal universe the calculation is supposed to describe.