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 recall 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: