| TRUMP ADMINISTRATION TRADE ALERT – IMPORTS | |
| HEADLINE | Implementation of U.S.-EU Trade Framework |
| DATE | September 25, 2025 |
| AGENCY | Department of Commerce |
| EFFECTIVE DATE | Retroactive to August 1, 2025 (automobiles &
parts) Retroactive to September 1, 2025 (aircraft and aircraft parts) |
| BACKGROUND | On April 2, 2025, the Trump Administration issued
sweeping Reciprocal Tariff rates – with a 20% EU-specific
rate as specified in Annex I – which were then suspended
until July 9. On July 31, 2025, the Administration published
revised Reciprocal rates to go into effect on August 7, 2025,
applying a total 15% Reciprocal Tariff rate for products from the
EU when combined with the products' ordinary HTS rate. On August 21, 2025, the U.S. and the EU agreed to certain tariff modifications that set a flat 15% tariff rate on most goods of EU origin. This agreement included assurances of additional tariff reductions related to automobile, automobile parts, aircraft, and aircraft parts once the EU took legislative steps to implement changes to EU tariffs. Executive Order 14346 "Modifying the Scope of Reciprocal Tariffs" established procedures for implementing the tariff modifications. |
| DETAILS | On September 25, 2025, the Department of Commerce published a
Notice implementing the U.S.-EU agreement, with similar provisions
to the U.S.-Japan Agreement, as follows: The Section 232 sector-specific tariffs apply in the following way: – Automobile Tariffs on EU automobiles and automobile parts reduced from the current 25% to the 15% tariff calculation applied under the EU Reciprocal Tariffs (where the ordinary column one HTS duty rate + the Reciprocal rate will equal 15%, or for items with an ordinary HTS rate of 15% or greater, a 0% automobile tariff). – Civil aircraft parts as specified are subject to 0% steel, aluminum, copper, and Reciprocal rates. The Notice additionally provides the list of articles excluded from the EU Reciprocal Tariffs, as specified in Annexes I and II. These additional products are largely pulled from the Annex in the September 5, 2025, Order modifying the reciprocal tariffs, described as the "Potential Tariff Adjustments for Aligned Partners (PTAAP)." – Many of the exclusions have requirements beyond their HTS classification, largely (1) generic pharmaceuticals and (2) for use in aircraft. – A comparison of these three lists (the 9/5 Reciprocal exclusions, the 9/5 PTAAP list, and the 9/25 EU exclusions) is available here. |
| BASIS | International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.), section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862) (section 232), section 604 of the Trade Act of 1974, as amended (19 U.S.C. 2483), and section 301 of title 3, United States Code |
| HTS/ PRODUCTS |
– Automobiles and parts subject to the Section 232
Automobile tariffs – Aircraft and aircraft parts subject to Section 232 Steel and Aluminum tariffs |
| COUNTRY | EU (Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia (Czech Republic), Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden) |
| CITE | Fed. Reg: Federal Register :: Implementing Certain
Tariff-Related Elements of the U.S.-EU Framework on an Agreement on
Reciprocal, Fair, and Balanced Trade CBP: CSMS # 66336270 – Guidance – Implementation of Tariff-Related Elements of the United States-European Union Framework Agreement |
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
