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Executive Order of September 5, 2025 Expands Exclusions from the Tariff Hike and Creates an Annex with “Potential Adjustments” to Tariffs for Countries That Enter into Agreements with the U.S. Changes Start to Take Effect on September 8, Focusing on Critical Minerals, Aerospace, and Pharmaceuticals.
The White House Published on September 5 an executive order that modifies the scope of the so-called “reciprocal tariffs” and establishes procedures for implementing reductions or exemptions when there are trade and security agreements with aligned countries. The measure will take effect starting September 8, 2025.
According to the official statement, there was an update to the Annex II of the previous order, which lists goods that will not be subject to the ad valorem rates of the tariff hike. This includes an expansion of exclusions for strategic items and, at the same time, the removal of some products that will again pay the reciprocal tariff.
The central logic is to condition zero tariff or reduction on signing agreements with the United States and the “degree of commitment” of the partner to mitigate imbalances and address trade and security concerns. That is, it is not an automatic exemption, and each agreement may have a specific list.
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The government wants to create a new tax in Brazil, and this time the target is minerals that leave the country without any processing, while other countries profit billions transforming Brazilian raw material.
PTAAP: The New List of “Potential Adjustments” for Aligned Partners
The order creates an annex named Potential Tariff Adjustments for Aligned Partners (PTAAP), which serves as a menu of items that “may” have the tariff reduced to 0% if the country enters into an agreement with the U.S. Among the categories are aircraft and parts, pharmaceutical articles and inputs (with emphasis on generics), and natural resources not cultivated or produced in sufficient scale in the American market.
According to reports and sector analyses, the government has opened the door for over 45 eligible categories for the 0% rate through agreements, making the PTAAP a tool to calibrate the “tariff hike” without dismantling it entirely.
In practice, the PTAAP helps reduce uncertainty in critical supply chains, signaling that items such as inputs for generics and aerospace components may be exempted when there is formal alignment.
Updated Annex II: What Has Already Been Excluded from the Tariff Hike
In addition to the PTAAP, the update of the Annex II itself brought immediate exclusions. Official communications and compliance summaries highlight that certain critical minerals and industrial inputs received different treatment, while other materials were removed from exclusions and will again pay tariffs.
Among the changes, the White House mentioned the removal of aluminum hydroxide, resins, and silicones from the exempt list, a move that reinforces the strategic nature of the package. Importers using exemption codes will need to revise their classification to avoid discrepancies.
Companies have been advised to check the correct HTSUS classification and monitor updates in the Federal Register, as eligibility depends on the code and declared origin. Complying with classification is crucial to take advantage of exclusions without the risk of penalties.
Who May Benefit: Aligned Partners, EU and Japan in Focus
The measure has been designed to be activated through agreements with aligned partners, such as the European Union and Japan, paving the way for zero tariffs on items in the PTAAP as soon as those agreements are concluded and enacted. The government describes this mechanism as part of a broader strategy to reduce the deficit and reorder sensitive supply chains.
International coverage reinforces that nickel, gold, graphite, and pharmaceutical compounds are among the items most likely to be exempted in agreement scenarios, especially when there is insufficient domestic production. This directly interests commodity exporters and manufacturers integrated into global supply chains.
Market analyses indicate that, although the risk of new sectors entering the scope of the tariff hike remains, the newly created flexibility for conditional exclusions may mitigate impacts in segments such as aerospace, pharmaceuticals, and electronics.
Impact on Brazil: Nickel, Gold, Graphite, and Agro in Demand Focus
For Brazil, the creation of the PTAAP opens a window of opportunity in critical minerals demanded by the U.S., such as nickel (batteries), gold (refining and finance), and graphite (anodes and industrial applications). With an agreement that meets U.S. requirements, these items could theoretically achieve zero tariff.
There are also potential gains for aerospace and generic pharmaceuticals and inputs, where the country participates as a supplier of parts, ingredients, and services. The message from the White House is clear: regulatory alignment and reciprocal commitments matter a lot in the final decision.
It is worth noting: without an agreement, the reciprocal tariff prevails. With an agreement, the exemption may be partial and calibrated by product, according to American national interests and the capacity to mitigate risks.
And you, do you believe that the list of exemptions for aligned partners will unlock Brazilian exports, or will it tend to turn into more bureaucracy and uncertainty for companies? Share your opinion in the comments.
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