G/LIC/Q/BRA/19  
 
7 November 2014  
(14-6509)  Page: 1/3  
Committee on Import Licensing  Original: English  
 
 QUESTIONS FROM THE EUROPEAN UNION TO BRAZIL REGARDING  
THE IMPORTATION OF  NITROCELLULOSE 
REPLIES FROM BRAZIL TO QUESTIONS FROM THE EUROPEAN UNION 
 
The following communication, dated 20 October 2014, is being circulated at the request of the delegation of Brazil. 
 
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1
. Could Brazil provide the statistics both  on the number of import licenses for 
nitrocellulose requested and on the number of  import licenses for nitrocellulose granted 
over the last 5 years? Could Brazil provide th e statistics on the distribution of such 
licences among supplying countries and related import statistics (value and/or volume), 
and the nitrogen content below and above 12.5%? 
 
Import Statistics  
2009 
Country Quantity (kg) 
Switzerland 315,520  
France 125,800  
China 19,480  
South Africa 8,325  
Total   469,125  
 
2010 
Country Quantity (kg) 
Switzerland 454,720  
Total 454,720  
 
2011 
Country Quantity (kg) 
Switzerland 352,640  
Netherlands 27,840  
Germany 1 
Subtotal 380,481  
 
2012 
Country Quantity (kg) 
Switzerland 408,320  
France 9,160  
Czech Republic 1,080  
Subtotal 418.056  
 G/LIC/Q/BRA/19 
 
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  2013 
Country Quantity (kg) 
Switzerland 259,120  
France 63,880  
China 9,280  
United States 9,280  
Subtotal 342,280  
 
2014 (January to September) 
Country Quantity (kg) 
Switzerland 315,520  
China 27,878  
Subtotal 343.418  
Source: AliceWeb Database, MDIC, Brazilian Government. 
 
Import Licenses 
 IL granted IL denied Total IL requested 
2009 21 0 21 
2010 12 0 12 
2011 15 0 15 
2012 17 2 19 
2013 17 0 17 
2014 15 1 16 
Source: Diretoria de Fiscalização de Produtos Controlados, Brazilian Army. 
 
Since 2009, no import licenses were denied, except for 2 licenses in 2012 and 1 license in 2014. 
Imports from Switzerland, France, South Africa and the USA are for military use (nitrogen content 
above 12.5%).  
2. Could Brazil provide import statistics over the last 5 years of ni trocellulose products 
of below and above 12.5% nitrogen content?  Could Brazil explain why it is importing 
nitrocellulose with a content of more than  12.5% of nitrogen? These nitrocellulose 
products cost about twice as much as nitroc ellulose and are products used mainly for 
military purposes.  See answer to question 1, above. Imports of  nitrocellulose in Brazil depend on market 
requirements. 
 3. Could Brazil provide statistics over the la st 5 years regarding the Brazilian production 
of nitrocellulose with reference to the nitr ogen content below and above 12.5% and also 
name the producers of nitrocellulose products?  
Brazilian Production: 
 
2009 2010 2011 2012 2013 
38.195,1 36.110,0 34.782,0 32.333,4 34.500* 
Source: ABIQUIM Yearbook, 2013.  
* Estimate subject to final revision for 2014 Yearbook. 
 
Brazilian Producers: 
 
Producers Capacity (t/year)  
Nitro Química 38,000  
IMBEL 1,500  
Source: ABIQUIM Yearbook, 2013. 
 G/LIC/Q/BRA/19 
 
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  4. Could Brazil submit sound and detailed ar guments for explaining why import licenses 
for industrial nitrocellulose are denied?  As explained above (see question 1) since 2009 no import licenses were denied, except for three 
cases. It is important to recall that international trade of nitrocellulose is controlled all over the 
world because nitrocellulose is a hazardous material and poses risks at any nitrogen concentration.   
Regardless of its nitrogen concentration and declared use (industrial or military) nitrocellulose can 
be ignited by flame, heat, friction, spark or static electricity. Metal containers containing nitrocellulose may explode when heated. In this sense, there is no difference between nitrocellulose solutions with different percentages of nitration, except for the concentration of 
nitrogen itself, which is never completely absent in the product. Therefore, the control of imports 
is legitimate for security and safety reasons.  
5. Could Brazil clarify which are the procedures to be followed by importers of industrial 
nitrocellulose? In particular, could Brazil cl arify if a non-automatic license has to be 
asked to the Ministry of Defence? Could Brazil  explain in detail which is the role of the 
Ministry of Defence for issuing such licenses? 
 The procedures to be followed for the importat ion of Nitrocellulose are similar to any other 
measures in place for products under special control due to safety and security reasons. Operators 
interested in importing such products must request an authorization ("habilitação") to Brazilian 
Army's Diretoria de Fiscalização de Produtos Controlados (roughly, "Board of Controlled Products"). The control of imports by the Brazilian Army is envisaged for safety and security 
reasons, in view of the characteristics of the product.   
 Once the authorization is granted, the importer receives a registration. For each commercial 
operation, the importer will get a prior authorization named International Import Certificate. This 
documentation allows the importer to register the operation on Brazil's Integrated Foreign Trade System and proceed to import licensing. Each impo rt operation will then be authorized by the 
Board of Controlled Products. 
 
As a concluding remark, Brazil would like to underline that it does not share the European Union´s view that "industrial and military nitrocellulose are substantially and chemically different products", 
except for the nitrogen concentration. Regardless of its use, the product poses risks. In this sense, 
the non-automatic licensing regime is a legitimate instrument to regulate the trade and use in Brazil of nitrocellulose in view of the characterist ics of the product, in order to prevent the use of 
such hazardous substances in ways incompatible with security standards. 
  
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