Bússola Estratégica #04 | From the calendar to the origin
5 October 2026
In this edition:
- The changing landscape: why the month in which Europe starts to require documentary proof of origin changes the nature of the preparation required of Brazilian companies.
- Main developments under way: traceability of imported steel, Brazil's negotiation on quotas, the extension of the CBAM to processed products, the "Made in Europe" criteria and the new bilateral institutional channel.
- Implications for Brazilian companies: what changes for those who export, look for technology, are weighing up investment in Italy or are seeking partners.
- From intelligence to preparation: why understanding the context now also requires the ability to prove.
This Bússola Estratégica brings together the main developments followed by the Brazil-Italy-European Union Observatory over the period and sets out the Chamber's reading of their likely impact and of the opportunities they open for Brazilian companies.
A changing landscape
In this period the European Union took a step unlike the previous ones. Until now, European requirements set dates. Now they also set the type of proof: traceability of imported steel came into operation on 1 October 2026, with the melt-and-pour rule; the European Parliament endorsed the proposal to extend the CBAM to processed products, but the final text still depends on negotiation with the Council; and the industrial acceleration proposal sets minimum shares of European content in public procurement.
On the bilateral front, the period left a new institutional channel: a working group between the governments of Italy and Brazil, meeting annually.
Trade flows responded quickly: Brazilian exports to the European Union grew 23.5% in the first four months of provisional application of the agreement, and in August reached 5.82 billion dollars, 46.4% above the same month of 2025. The ability to document origin, emissions and content, by contrast, takes months to build and has to be built inside the company's own operations. It is worth remembering that the trade part of the agreement is still provisionally applied and that final ratification remains suspended: the tariff advantages are real and in force, but the agreement should not be treated as concluded
Main developments under way
▹ NEW | The origin of steel becomes a customs document → Since 1 October 2026 the traceability rules for steel imported into the European Union, set out in Implementing Regulation (EU) 2026/1963 published on 31 August, have been operational. Origin is attributed to the country where the iron or crude steel was first produced in liquid state and poured, not to the country of last processing. The importer must present a producer's certificate stating the place of melting, batch number and specification, or alternative documentation accepted by the customs authorities. The rules cover 26 categories of steel products, with a transition period until 30 September 2027. They implement Regulation (EU) 2026/1384, which replaced the previous safeguard regime from 1 July 2026, cut the duty-free quota to 18.3 million tonnes a year (47% less than in 2024) and set a 50% tariff on volumes above it.
What does this mean? For the Brazilian iron and steel chain, origin is no longer commercial information but a customs clearance document. A batch whose melting cannot be proven at the point of departure risks being held at customs, regardless of product quality or the relationship with the buyer. The transition period until September 2027 is the window to arrange, with the mill, the systematic issue of these certificates.
▹ NEW | Brazil brings steel quotas to the table with the European Union → On 30 September, on the sidelines of the G20 Trade Ministers' Meeting, Foreign Minister Mauro Vieira and Minister Márcio Elias Rosa met the European Commissioner for Trade and Economic Security, Maroš Šefčovič. The European side reported that the allocation of steel quotas is under review, with a potentially positive impact for Brazil, and that the process will have further stages in 2027. The meeting also covered the resumption of poultry and honey exports, after a European audit on antimicrobial use in Brazil, and Brazil's request to speed up approval procedures for beef.
What does this mean? The quota is not a fixed figure: it is open to negotiation, and the Brazilian government has formally put it on the table. But that negotiation runs in 2027, while the 50% tariff on excess volumes and the documentary requirement apply now. Following the review is worthwhile; planning shipments that count on it is not. The second point matters just as much: the reopening for poultry and honey shows that, in this relationship, what unlocks markets is audits and sanitary documentation.
▹ ADVANCED | The CBAM moves on to processed products → A trend identified in the previous edition moves forward. On 15 September 2026 the European Parliament adopted, by 464 votes to 50 with 159 abstentions, its negotiating position to extend the CBAM to processed goods containing steel or aluminium, such as screws, wire, springs and household articles. The three positions differ in scope: the Commission covers about 180 downstream products, the Council about 200 and Parliament 457 product lines. The final text depends on negotiation between Parliament and Council, and the current CBAM scope remains valid until the amending regulation is formally adopted. The extension is expected to apply from 2028.
What does this mean? The cost of carbon will no longer fall only on the raw material but also on the manufactured product that contains it. This affects Brazilian exporters who until now considered themselves outside the CBAM. Since the final scope is still being negotiated, the step to take now is not compliance but mapping: identifying which of one's own product codes appear on the three lists and the steel or aluminium content of each.
▹ Regulatory update | The "Made in Europe" criteria enter the amendment stage → The Industrial Accelerator Act, proposed by the European Commission in March 2026, introduces European content criteria in public procurement in strategic sectors, with shares that vary by product. The proposal treats as Union origin the content coming from partners with which the Union has concluded an agreement establishing a free trade area or customs union. The deadline for tabling amendments in the European Parliament was set for 30 September 2026, and part of European industry has asked for stricter criteria, including tougher rules against circumvention through assembled goods.
What does this mean? It is the development with the greatest potential consequences and, at the same time, the most uncertain. In the current wording, content originating from a partner with a free trade agreement in force could count as European in public procurement. This possibility should be treated with caution: the text is a proposal, it is at the amendment stage, and part of European industry is pushing to close this route. What can already be acted on is something else: access to the European market in strategic sectors comes to depend on where value is generated, not only on where the product is sold.
▹ ADVANCED | A bilateral institutional channel opens → On 9 September in São Paulo, Italy's Deputy Prime Minister and Minister of Foreign Affairs, Antonio Tajani, announced the creation of a working group between the two governments, meeting annually, at an event attended by Brazil's Minister of Development, Industry, Trade and Services, Márcio Elias Rosa. On 11 September, at the National Confederation of Industry in Brasília, the two sides set out four sector priorities: pharmaceuticals, digital technology, energy and infrastructure, machinery and mining.
What does this mean? A working group that meets on a set schedule creates a place where concrete barriers (certification, customs timelines, recognition of standards) can be raised and dealt with through institutional channels. And naming four priority sectors gives Brazilian companies a reference for judging whether they are inside or outside the declared focus of the relationship at this moment.
Implications for Brazilian companies
▹ For companies that export or intend to supply Europe: the document has become part of the product. Those shipping iron and steel need to secure from the mill a melt-and-pour certificate with batch and specification, making use of the transition period that ends on 30 September 2027. Those exporting processed goods containing steel or aluminium should check whether their own codes appear on the downstream CBAM lists under negotiation. Those working with coffee, soy, beef or timber still face the requirement to geolocate areas of origin from 30 December 2026. In every case, the most profitable investment of the quarter is in a record-keeping system, not in volume.
▹ For companies seeking technology and production capacity: structural support on the Italian side now centres on the Iperammortamento, valid for investments until September 2028, and on the Fondo Nazionale del Made in Italy. For buying machinery and technology, this means Italian suppliers are working today with instruments that have a set horizon, which leaves room to negotiate delivery times and payment terms. The moment favours those who already have a defined modernisation project.
▹ For companies considering investing in Italy: the decision gains a new argument and a new deadline. The argument is the European content perimeter under discussion: producing a significant stage inside the Union stops being a question of logistics and becomes a question of eligibility for public procurement in strategic sectors. The deadline is the Italian budget calendar, with the budget bill due by 20 October 2026 and approval by 31 December: that text will settle the continuation and funding of investment support instruments for 2027.
▹ For companies looking for Italian partners: the period left an institutional channel that did not exist in August and four sectors explicitly prioritised by both sides. An open channel, however, is no substitute for preparation. The partnership that lasts is the one with a company that arrives knowing which of these sectors it belongs to, what it can prove about its own operations and on what terms it can deliver on an ongoing basis.
From intelligence to preparation
Understanding market changes and identifying their implications is still the starting point. What this period adds is the requirement of proof: the context asks not only for knowledge and a timetable, but for the ability to demonstrate origin, emissions and content with documents accepted by those who decide on entry.
Translating this into each company's reality means identifying which requirements apply to its products, checking which documents its supply chain can already issue and which it cannot yet, agreeing with suppliers who certifies what, and ordering these adjustments according to the calendar that actually applies to its shipments.
That is the space in which the PAS, Percorso di Allineamento Strategico, operates: a methodology developed by the Chamber to support Brazilian companies that want to work in Italy and Europe better prepared and better aligned with the context in which they intend to compete.
The Observatory interprets the context and identifies what it implies. The PAS turns that intelligence into preparation applied to the company.
The Bússola Estratégica is a publication of the Brazil-Italy-Europe Observatory, an initiative of the Camera Italo-Brasiliana di Cooperazione Sostenibile, which follows, interprets and translates the changes affecting the relationship between Brazil, Italy and the European Union.