Brazil's July 15 Section 301 deadline arrives before tariff timing is fixed
Treat July 15 as a decision deadline, not a duty start date. Keep Brazil entry scenarios separate until USTR publishes an effective date. In AD/CVD matters involving affirmative critical-circumstances findings, map unliquidated entries against the statutory window and track how many commissioners participate in the eventual USITC vote.
Brazil's July 15 deadline closes USTR's Section 301 decision clock, not the customs collection clock. USTR still must publish the selected action, final scope, and effective date. Separately, a six-member USITC would reopen tie-vote questions in certain AD/CVD proceedings, including disputed critical-circumstances treatment that can reach some unliquidated entries made up to 90 days before provisional measures began.
July 15 closes USTR's Section 301 decision clock for Brazil. It does not itself start duty collection. USTR still must publish the selected action, final product scope, and effective date. Keep no-action, delayed-implementation, and collection-on-an-announced-date scenarios separate until that notice appears.
Read the full analysis: Brazil's Section 301 Deadline Leaves Tariff Timing Open.
Five pending nominees could restore a six-member USITC, making 3-3 votes possible. In a narrow AD/CVD critical-circumstances setting, an evenly divided Commission may support duty treatment reaching some unliquidated entries made up to 90 days before provisional measures began. Parties should map entries to the statutory window and track which commissioners participate in the eventual vote.
Read the full analysis: A Full USITC Can Turn a 3-3 Vote Into Retroactive Duties.