EU prepares for entry into force of new US tariffs – opportunities for economic players to participate
On 8 May 2025, the EU Commission announced its next steps in the tariff dispute with the USA, including an extensive list of US products that would be affected by possible counter-tariffs. We summarise the most important developments for you. You can find a detailed description of developments ahead of Liberation Day in our news article from 13 March.
Trade dispute between the EU and the US
A look at the recent past shows the rapid pace at which economic operators must adapt to new developments in US customs policy: On 2 April 2025 ("Liberation Day"), US President Trump imposed so-called reciprocal tariffs of 20% on all EU imports, in addition to the 25% tariffs on steel and aluminium imports already in place since 10 February 2025. Trump also announced tariffs of 25% on imports of vehicles and their parts. The EU responded with the threat of countermeasures if the negotiations fail.
On 9 April, the US suspended the 20% tariff on EU imports for 90 days and reduced it to 10%, i.e. to the tariff rate that has applied to all imports of any origin since Liberation Day. As a result, on the afternoon of 14 April, the EU also suspended its counter-tariffs on steel and aluminium products, motorbikes, lighting and agricultural products, which it had announced the same day in the morning, for 90 days until 14 July 2025. The EU also suspended the reintroduction of the counter-tariffs that had already been imposed during Trump's first term in response to the US tariffs at the time.
The US sent a further signal of relaxation on 29 April 2025 by exempting imported cars (already subject to a 25% duty) from the 25% duty on their steel and aluminium components.
The EU is currently endeavouring to reach an agreement with the USA through negotiations. However, if these fail, the EU has now published even more extensive countermeasures and explained its next steps.
List of potentially affected US products; possible export restrictions for EU products
The more than 200-page list of US products that could be affected by possible EU counter tariffs includes a wide range of agricultural and industrial products worth 95 billion euros. They are a reaction to both the general 20% tariff and the tariff on cars and car parts. However, the individual tariffs on specific products have not yet been announced.
Restrictions are also being considered on some EU exports of steel scrap and chemical products worth 4.4 billion euros; a list of products potentially affected by export restrictions has also been published.
WTO proceedings; further negotiations
The EU Commission has also announced that it will initiate proceedings at the World Trade Organisation (WTO) by formally requesting consultations in order to establish the illegality of the blanket "reciprocal" tariffs and the tariffs on cars and car parts. At the same time, the EU emphasises its willingness to negotiate with the US. Negotiations are currently taking place at a political and technical level.
Feedback for affected companies possible – get involved!
The EU Commission is giving companies that would be affected by the proposed EU countermeasures the opportunity to express their views. An online platform is exclusively available for this purpose. The deadline is 10 June 2025.
Outlook
The results of the feedback are to be incorporated into the Commission's final draft of an implementing regulation. This draft must be submitted to a committee in which all member states are represented as part of the "comitology process". If this committee agrees by a qualified majority, the Commission can adopt the implementing regulation at any time. It would then have legally valid countermeasures up its sleeve should the negotiations fail.
Affected companies should take the opportunity to present their views on the potential countermeasures. The extent to which they are affected can be determined by comparing the CN codes of their own imported products with the CN codes of the potentially affected products, even if the exact tariff is not yet available for precise quantification. There are signs of easing tensions, such as the current agreement in principle between the US and the UK. However, in view of the numerous U-turns that the Trump administration has made in its tariff policy so far, companies should not base their strategy solely on the mere hope of detente.
