EU prepares for the entry into force of new US tariffs - opportunities for economic operators to participate

On May 8, 2025, the EU Commission announced its next steps in the trade dispute with the US, including a comprehensive list of US products that could be affected by potential retaliatory tariffs. We summarize the most important developments for you. A detailed account of the developments leading up to "Liberation Day" can be found in our news article from March 13th. Trade dispute between the EU and the USA. A look at the recent past shows the rapid pace at which economic actors must adapt to new developments in US tariff policy: On April 2nd, 2025 ("Liberation Day"), US President Trump imposed so-called reciprocal tariffs of 20% on all EU imports, in addition to the existing tariffs of 25% on steel and aluminum imports that had been in place since February 10th, 2025. Furthermore, Trump announced tariffs of 25% on imports of vehicles and their parts. The EU responded by threatening countermeasures should the negotiations fail. On April 9, the US suspended the 20% tariff on EU imports for 90 days and reduced it to 10%, the tariff rate that has applied to all imports of any origin since Liberation Day. Subsequently, on the afternoon of April 14, the EU also suspended its retaliatory tariffs, announced that same morning, on steel and aluminum products, motorcycles, lighting, and agricultural products for 90 days until July 14, 2025. The EU also suspended the reintroduction of retaliatory tariffs that had already been imposed during Trump's first term in response to the US tariffs at that time. The US sent a further signal of de-escalation on April 29, 2025, with the rule that imported cars subject to a 25% tariff would not also be subject to a 25% tariff for their steel and aluminum components. The EU is currently seeking an agreement with the US through negotiations. However, in the event that these fail, it has now published even more extensive countermeasures and explained its further course of action. List of potentially affected US products; Possible Export Restrictions for EU Products

The over 200-page List of US products that could be affected by possible EU retaliatory tariffscontains a wide range of agricultural and industrial products worth €95 billion. These are understood as a response to both the blanket 20% tariff and the tariff on cars and car parts. However, the documents published so far do not specify the exact amount of tariffs that would be imposed on individual products. Furthermore, restrictions on some EU exports of steel scrap and chemical products worth €4.4 billion are being considered; a list of products potentially affected by export restrictions has also been published. Parallel negotiations

The EU Commission also announces that it will initiate proceedings at the World Trade Organization (WTO) by formally requesting a consultation to determine the illegality of the blanket "reciprocal" tariffs as well as the tariffs on cars and car parts. At the same time, it emphasizes its willingness to negotiate with the USA, which are currently taking place at both the political and technical levels.

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 present their views. An online platform is available exclusively for this purpose. The deadline is June 10, 2025.

Outlook

The results of the feedback will 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 approves it by a qualified majority, the Commission can adopt the implementing regulation at any time. It would then have legally binding countermeasures at its disposal should the negotiations fail.

Affected companies should take this opportunity to present their perspective on the potential countermeasures. Their own vulnerability can be determined by comparing the CN codes of their imported products with the CN codes of potentially affected products, although the specific tariff rate is still lacking for a precise calculation. While there are signs of easing tensions, such as the recent agreement in principle between the US and the UK, However, given the numerous U-turns the Trump administration has made in its tariff policy so far, companies should not base their strategy solely on this.