G/LIC/Q/BRA/18  
 
16 May 2014  
(14-3004)  Page: 1/2  
Committee on Import Licensing  Original: English  
 
QUESTIONS FROM THE EUROPEAN UNION TO BRAZIL REGARDING  
THE IMPORTATION OF  NITROCELLULOSE 
QUESTIONS FROM THE EUROPEAN UNION TO BRAZIL 
The following communication, dated 15 May 2014, is  being circulated at the request of the 
delegation of the European Union.  
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  As a follow-up of the discussion held at the Import Licensing Committee on 15 April 2014, the EU 
would like to receive several clarifications on the Import procedures applicable to industrial 
nitrocellulose in Brazil.  
Before listing the questions, the EU would like to re call that the industrial nitrocellulose is a binder 
used in the printing ink-, wood coating-, leather-, nail varnish- and many other industries. To be noted that this product differs substantially from the military nitrocellulose. 
 
Despite the fact that they are two chemically  different products, industrial and military 
nitrocellulose are under the same tariff line in Brazil (CET 3912.20) as well as in the EU (HS code 3912.20). 
 
Brazil has put in place a non-automatic import licensing regime for the importation of industrial nitrocellulose that operates de facto as a ban. EU nitrocellulose-users have asked the Ministry of 
Defence of Brazil for an import license; however none of the EU companies has got an import 
license in recent years.    
The EU would like Brazil to demonstrate how their legislation on the importation of industrial 
nitrocellulose does not have any trade-restrictive or trade-distortive effects on imports. In this respect, we would like Brazil to reply to the following questions: 
 
EU Questions: 
 
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 ye ars? Could Brazil provide the 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%? 
 
2. Could Brazil provide import statistics ov er the last 5 years of nitrocellulose 
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 
nitrocellulose and are products us ed mainly for military purposes. 
 G/LIC/Q/BRA/18 
 
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  3. Could Brazil provide statistics over th e last 5 years regarding the Brazilian 
production of nitrocellulose with reference to the nitrogen content  below and 
above 12.5% and also name the produc ers of nitrocellulose products? 
 
4. Could Brazil submit sound and detailed arguments for explaining why import 
licenses for industrial nitrocellulose are denied? 
 
5. Could Brazil clarify which are the proced ures to be followed by importers of 
industrial nitrocellulose? In particular , could Brazil clarify 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? 
 
 
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