G/LIC/Q/BRA/20  
 
22 November  2016 
(16-6403) Page: 1/2 
Committee on Import Licensing  Original: English  
 
 QUESTIONS FROM THE E UROPEAN UNION TO BRA ZIL  
 
The following communication, dated 16 November 2016 , is being circulated at the request of the 
delegation of the European Union.  
 
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Following Brazil's request, the EU would like to submit in wri ting the questions raised during the 
last meeting of the Import Licensing Committee.  
 
1. Reference is done to the notifications submitted by Brazil and circulated as document 
G/LIC/N/1/BRA/7+  G/LIC/N/1/BRA/7 /corr.1 (in accordance to Art. 1.4 and 8.2 of the  ILA) and as 
document G/LIC/N/2/BRA/7 (in accordance to Art. 5 of the ILA).  
 
In the EU's understanding, the  notifications  submitted by Brazil do not refer to a specific product  
or to any specific changes in the import licensing procedures of one or more pr oducts. The 
notifications r ather refer to the general import procedures system in place.  Therefore:  
 
o Could Brazil clarify how to read those notifications?  
o Could Brazil clarify what are the new import licensing schemes and/or the 
amendments to existing imp ort licensing procedures that have been notified?   
2. Reference is done to the annual notification submitted by Brazil in accordance with Art. 7.3 of 
the ILA and circulated as document  G/LIC/N/3/BRA/11 . 
 
In the EU's view, this notification does not compl y with the requirements set in the questionnaire 
and contained in document G/LIC/3 (annex).  
 
According to the current notification's rules, the  annual notification should give a brief presentation 
of each system  as a whole and, with respect to each import  procedure system , Members should 
reply to the questions as relevant.  
 
Brazil has limited itself to refer to its SISCOMEX without presenting a detailed description of the 
import procedures for each product.  Furthermore, it seems that the SISCOMEX online p rocedures 
are not yet fully operational (see reply to point 6.d).  
 
Therefore, the EU would like to receive the following clarifications:  
 
o Could Brazil provide a complete description of the procedures in place, for each 
single product subject to import lice nsing requirements ? 
o Could Brazil provide the list of tariff lines clearly indicating whether an automatic 
or a non -automatic  import license procedure is applicable ?  
o According to the information available, it seems that an import licence would be 
necessary  for the importation of the products corresponding to more than 5,000 
tariff lines. In this respect:  
 Could Brazil clarify whether this information is correct?  G/LIC/Q/BRA/20  
 
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   Could Brazil clarify the reasons for such extensive use of import licenses?  
 Could Brazil explain  how this could be justified taking also into account 
that in its annual notification Brazil declares that, as a rule , the Brazilian 
import regime does not require licensing?  
o Could Brazil  clarify when the new SISCOMEX single window will be fully operation al 
as regards import licenses?  
Additionally, a s the products are not clearly defined, the EU would reiterate its concerns on the 
procedures in place for the importation of nitrocellulose  and would like to ask Brazil further 
clarifications.  
 
In particular, the EU notes that Brazil's notification includes the reference to the ministry of 
industry where a table is provided for import procedures  (http://ww w.mdic.gov.br/comercio -
exterior/importacao/tratamento -administrativo -de-importacao ). According to that table, it seems 
that the importation of nitrocellulose is subject to an automatic import licence.  
 
o Could Brazil c larify whether the import ation of prod ucts under NCM 3912.20 
(nitratos de cellulose/ nitrocellulose) are subject to automatic import licences, as 
stated in the notification, or to non -automatic import licenses, as declared during 
the meeting?  
o In case non -automatic import licenses are required,  does Brazil envisage amending 
its notification? Could Brazil submit detailed information on the procedures for the 
importation of these products?  
 
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