In last month’s Trade and Manufacturing Alert, we reported on Brasil Maior (Bigger Brazil), Brazil’s comprehensive industrial plan to revive manufacturing, in which Brazil announced its intention to reduce unfair import competition. On September 12, 2011, Brazil published a change to its trade regulations, which allows the retroactive application of antidumping and countervailing duties, up to 90 days before the publication of an affirmative preliminary determination. The domestic industry bringing these unfair trade cases must request retroactive application of duties. The intent of the regulation is to prevent importers from stockpiling products after a new investigation is announced. Importers can be deemed to have knowledge that a producer was dumping if a bill of lading is dated after the start of an investigation.