On 14 October, Brazil’s foreign minister announced that Brazilian exports to the European Union rose by 30% between May and September 2026 compared with the same period of 2025. The EU–Mercosur agreement has applied provisionally since 1 May. More volume is good news. It also means more goods exposed to European controls, and those controls have not been relaxed. Here are the four points I check first with Brazilian exporters and their European importers.
An agreement that opens the market, not the border
A reduced duty has to be claimed; it is never applied automatically. The product must be originating within the meaning of the agreement, the proof of origin must be issued in the prescribed form, and the invoice, the tariff classification and the declaration must tell the same story. When one of the three diverges, the outcome is familiar: full duties, a corrective entry, sometimes a post-clearance audit of earlier shipments. I described this mechanism in May; it still applies in full.
Check 1 — preferential origin
Before the first shipment under the agreement, I ask the exporter for three things: the tariff classification of its products, the detail of the non-originating materials used, and the list rule applicable to each heading. This takes a few days; it avoids months of disputes. On the importer’s side, I make sure the customs representative holds the proof of origin before arrival, not after.
Check 2 — steel, metals and CBAM
Since 1 October 2026, all steel imported into the EU must be accompanied by evidence of the country where it was melted and poured. An incomplete mill certificate is enough to hold a container. For goods covered by the Carbon Border Adjustment Mechanism (steel, aluminium, cement, fertilisers, hydrogen, electricity), the definitive regime has applied since 1 January 2026: the European importer must be an authorised CBAM declarant, and the Brazilian exporter must be able to supply usable emissions data. Without that data, the importer is charged on default values, which are generally unfavourable.
Check 3 — coffee, soy, beef, wood, leather: the EUDR
The EU Deforestation Regulation applies to larger companies from 30 December 2026 and to smaller ones from 30 June 2027. The date stands: simplifications are still being discussed in Brussels, but no majority is emerging for another postponement. In practice, every batch must be linked to the geolocation coordinates of the plots and to a due diligence statement lodged before the goods are placed on the market. For Brazil’s coffee, soy, beef, wood and leather supply chains, this is the project of the autumn.
Check 4 — the entry file
The first three checks concern the product. The fourth concerns the file: a valid EORI number for the importer, a confirmed tariff classification, a documented customs value, a customs representative appointed and briefed, and complete ICS2 safety data before loading. It is the least spectacular of the four, and the one that immobilises the most containers.
What I prepare, and what I do not do
CTB Group prepares the ready-to-lodge file: a product-by-product origin matrix, the list of expected documents with an owner and a deadline for each, CBAM and EUDR data collected from suppliers, then coordination of the customs representative and freight forwarder chosen by the company. We do not lodge the declaration and we do not replace the customs representative: it is still lodged by your declarant, on a file that holds no surprises for them.
If you export from Brazil to Europe, or import from Mercosur, the right time to check these four points is before the next order, not when the vessel arrives. The first conversation is free of charge.
Further reading
- EU–Brazil corridor: Brazilian exporters
- CBAM Pack
- Wood and EUDR
- EU–Mercosur agreement: why your reduced duties are not guaranteed