G/LIC/Q/BRA/22  
 
5 April 2018 
(18-2075) Page: 1/2 
Committee on Import Licensing  Original: English  
 
IMPORT LICENSING SYS TEM OF BRAZIL  
FOLLOW -UP QUESTIONS FROM TH E EUROPEAN UNION TO BRAZIL  
 
The following communication, dated 27 March 2018 , is being circulated at the request of the 
delegation of the European Union.  
 
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The EU thanks Brazil for the replies to its previous questions. However, as already raised at the 
last meeting of this Committee, the EU still needs further clarifications.  
 
Furthermore, the EU understands that Brazil is currently carrying on a revision o f its import 
procedures and, in particular, of the ones applicable to the importation of Nitrocellulose  for 
industrial use. Then, the EU understands that the recently established inter -ministerial Technical 
Group on Import Licences will meet in the coming weeks and will discuss the import requirements 
for nitrocellulose . 
 
EU question No 1 : Could Brazil submit additional information on the tasks of the inter -ministerial 
Technical Group on Import Licenses, notably about the participants and its scope? Could a lso Brazil 
clarify the expected timeline of the review? What sectors will the review cover?  
 
EU question No 2 : Could Brazil confirm that the Technical Group is in charge of the review of the 
import procedures applied to nitrocellulose ?  
 
In its written re plies, Brazil state that all proceeding regarding nitrocellulose  can be downloaded at 
“http://www.mdic.gov.br/index.php/comercio -exterior/importacao/tratamento -administrativo -de-
importacao ”. However, the EU still fails to find the relevant information and therefore, would ask 
Brazil once more to present in details the current requirement for the importation of Nitrocellulose  
for commercial use. In particular, as asked in this committee seve ral times, the EU continues to 
request reciprocal treatment of the import of nitrocellulose  products for industrial purposes with a 
nitrogen content of max. 12.5% and would need further clarifications on the procedures for the 
importation of nitrocellulose  under NCM 3912.20 (nitratos de cellulose/ nitrocellulose ).   
 
EU question No 3 : Could Brazil present in details with reference to the procedures to be followed 
for the importation of nitrocellulose ?  
 
Brazil claims that the procedures are in place to guar antee national security interest. In this 
respect, the EU would like to underline that a stability test for industrial nitrocellulose  declared the 
EU products to have the highest safety standard worldwide and that these products are stable and 
will not sho w a dangerous decomposition, even if they should get dry. Therefore, the national 
security in B razil will not be affected negatively.  
 
EU question No 4 : Could Brazil clarify what it is meant with “ national security interests”?  
 
Looking back at the past years, the EU is pleased to note some positive developments. In 
particular, we are pleased to note that Brazil agrees with us that there is a difference between 
military and industrial -grade nitrocellulose . More recently, we were p leased to learn from the 
Ministry of Defence that the import in Brazil of industrial grade nitrocellulose  is also allowed; G/LIC/Q/BRA/22  
 
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  however only if the product is originating in Uruguay. This has been recently clarified by the 
Brazilian authorities who expressly st ated the following:  
 
Nitrocellulose  is a product controlled by the Army and its importation is restricted on the basis of 
Article 190 of Decree 3.665 of 20 November 2000 (R -105) [ Art. 190.  O produto controlado que 
estiver sendo fabricado no país, por indús tria considerada de valor estratégico pelo Exército, terá 
sua importação negada ou restringida, podendo, entretanto, autorizações especiais ser concedidas, 
após ser julgada a sua conveniência.]  
 
Currently, the importation of this product is only authorized  when the Nitrocellulose  degree of 
nitration is below the level required for military applications, is in dissolved or suspended form and 
originating only in Uruguay.  Legal persons duly registered with the Army for the import of the 
product in question wo uld be able to import the product under the above mentioned conditions. 
Brazil also submitted us Portaria 56/2017 setting the rules for the procedures to be followed for 
obtaining the registration by the Army For each importation, the registered company wo uld have 
to transmit to the Army´s Direction for the Enforcement of Controlled Goods ( Diretoria de 
Fiscalização de Produtos Controlados - DFPC) a request for an International Certificate of 
Importation, using a specific template1. 
 
EU question No 5 : Could Brazil clarify why the nitrocellulose  for industrial use originating in 
Uruguay can be imported?  
 
EU question No 6 : Is it due to a specific bilateral agreement between Brazil and Uruguay? Could 
Brazil submit the legal basis?  
 
EU question No 7 : Could Brazil clarify why the nitrocellulose  for industrial use originating in 
Uruguay is different from the EU products?  
 
 
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1 Annex I  to this document (available for consultation in the Market Access Division, in English only).