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EU Strikes Back: New U.S. Countertariffs

Updated: Jul 25

The EU will impose significant new tariffs and trade bans against products originating in the U.S. if trade talks fail.


EU Introduces Counter Tariffs on US Goods: A New Era for Trade Compliance and Customs Management.
EU Introduces Counter Tariffs on US Goods: A New Era for Trade Compliance and Customs Management.

Major new EU customs duties and export bans targeting U.S. goods are rewriting the trade landscape and raising the stakes for compliance professionals worldwide.

On 24 July 2025, the European Union launched a powerful package of countertariffs and export restrictions in direct response to sweeping new U.S. tariffs, signaling a new era of trade friction and regulatory complexity.


Customs, compliance, and trade management are once again front and center.


Whether you import, export, or advise on customs compliance, these measures will fundamentally reshape your daily operations, pricing strategies, and risk assessments for the foreseeable future.

Adapting quickly is no longer optional — it’s essential to stay ahead in this evolving trade environment.


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Key Questions Answered in This Blog

  • Why did the EU introduce new customs rebalancing measures against the USA in 2025?

  • What products and sectors are hit by these new EU duties?

  • Why are there export prohibitions from the EU to the US in the legal text?

  • How do the measures work, and what are the main legal and economic justifications?

  • What’s the immediate impact on compliance, supply chains, and costs?

  • What do customs consultants, importers, and exporters need to do next?



“With over €285 billion in EU exports now caught in the crossfire, this isn’t just a tariff spat — it’s a full-scale economic counteroffensive. The EU is sending a clear message: it will match Washington’s escalation sector for sector, euro for dollar.” Arne Mielken, Managing Director, Customs Manager


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Abbreviations Used In This Blog

  • EU – European Union

  • US/USA – United States of America

  • WTO – World Trade Organization

  • GATT – General Agreement on Tariffs and Trade

  • CN – Combined Nomenclature (customs tariff codes)

  • MFN – Most-Favoured-Nation



Why did the EU introduce new customs rebalancing measures against the USA on 24.07.2025?


The EU’s latest move is a direct response to escalating US tariffs imposed throughout 2025, including safeguard duties on steel, aluminium, autos, and a new “reciprocal tariff policy.”


The US expanded and increased tariffs—sometimes up to 30%—on a massive range of EU exports, with little warning and unlimited duration. After years of fraught negotiations and failed consultations, the EU invoked its WTO rights to suspend “substantially equivalent obligations,” legally rebalancing trade relations and signalling to the world that it won’t accept one-sided protectionism.



What products and sectors are hit by these new EU duties?


A dizzying list: over 400 tariff lines, covering everything from steel, aluminium, and autos to food, chemicals, consumer goods, and even specific export bans. Some of the highest-profile targets include US-made steel pipes, cars and car parts, certain agricultural goods, tobacco, chemicals, and even machinery and electronics.


Starting 7 August 2025, the European Union will apply ad valorem import duties ranging from 4.4% to 30% on a broad list of U.S.-origin products, depending on their CN code and the specific annex in Regulation 2025/1564.including:


  • 🔧 1. Steel & Aluminium (Annexes I–V)

    Key impact: The heart of the retaliation. The EU is targeting a wide range of semi-finished and finished metal products, especially those benefiting from U.S. Section 232 tariffs or subsidies.


    • Carbon and alloy steel pipes and tubes

    • Stainless steel flat-rolled products

    • Aluminium sheets, plates, foil, and bars

    • Iron and non-alloy steel bars and rods

    • Steel wire, rails, and forgings


    Tariff range: 10%–25%


    🚙 2. Automobiles & Auto Parts (Annexes VI–VII)

    Key impact: High-value goods, symbolic retaliation. Hits U.S. carmakers and suppliers.

    • Passenger vehicles and SUVs

    • Motorcycles over 500cc

    • Engines and gearboxes

    • Braking systems, clutches, radiators

    • Electrical lighting and signalling equipment

    Tariff range: 10%–30%


    🍺 3. Beer & Beverage Packaging (Annex VIII)

    Key impact: Focuses on high-volume consumer exports.

    • Beer made from malt

    • Aluminium beverage cans and closures

    • Carbonated drinks in aluminium packaging

    Tariff range: ~15%


    🌾 4. Agriculture, Consumer Goods, & Intermediate Inputs (Annexes IX–XIII)

    Key impact: Targets influential U.S. agricultural lobbies and export-driven manufacturers.


    Food & Agriculture:

    • Sweetcorn (fresh, chilled, frozen)

    • Cranberries and cranberry juice

    • Peanuts and peanut butter

    • Tobacco and cigars

    • Processed meats and certain dairy products

    • Chewing gum and confectionery


    Consumer Goods:

    • Cosmetics and skincare products

    • Detergents, soaps, and cleaning products

    • Textile articles (e.g. bed linen, curtains)

    • Wood furniture and mattresses


    Chemicals & Intermediate Goods:

    • Polyethylene, polypropylene, and other polymers

    • Synthetic rubber

    • Certain pharmaceuticals and intermediates

    • Machinery components

    • Measuring instruments and valves


    Tariff range: 4.4%–25%, depending on product



Why are there export prohibitions from the EU to the US in the legal text?

The EU’s new countermeasures against the U.S. under Regulation (EU) 2025/1564 do more than impose import tariffs. In a rare but deliberate move, the EU has also introduced export bans on certain EU-origin goods destined for the United States, effective 7 September 2025. These are not broad-based embargoes — they are strategic and surgical, with a clear intent.


Here’s the legal and strategic rationale:


🎯 1. Retaliatory Leverage Without Domestic Pain

The EU explicitly framed these export bans as counter-retaliation tools that:

  • Do not harm EU producers, because the U.S. is not a critical destination for the selected goods.

  • Still inflict commercial and operational inconvenience on U.S. importers and manufacturers.


This is targeted escalation, intended to:

  • Pressure U.S. companies relying on EU-sourced inputs (e.g., scrap metal for U.S. recycling or smelting industries).

  • Show Brussels is willing to fight back symmetrically, not just by taxing imports.


🧯 2. Strategic Resource Control


The goods banned for export (listed in Annex XIV) include, for example:


  • Ferrous metal scrap: CN 7204

  • Aluminium scrap and waste: CN 7602


These are strategic raw materials in the EU’s view, tied to:

  • The EU Critical Raw Materials Act (CRMA)

  • The Green Deal Industrial Plan

  • Circular economy and EU domestic recycling policies


Export restrictions here signal:

  • The EU intends to retain valuable raw materials to support its own industrial base, especially green tech and steel decarbonisation.

  • It wants to discourage raw material outflows to competitors (e.g., U.S. processors who may compete with EU green steel or battery producers).


🛡️ 3. Exceptions for Humanitarian & Emergency Use


As per the legal text, exports are still allowed in narrowly defined cases:


  • Exempted purposes:

  • Humanitarian aid shipments

  • Public health emergencies

  • Environmental disaster response


But: All such exemptions must be pre-authorised by national competent authorities (e.g., customs, foreign ministries) under strict licensing terms.


What is the Legal Basis in the Regulation for these restructions?


The recitals and Article 6 of Regulation (EU) 2025/1564 lay out that:


  • These export bans are part of a calibrated, proportionate response under WTO rules.

  • The EU is acting under Article 3 of Regulation (EU) 654/2014 (Enforcement Regulation), which allows the EU to suspend concessions or obligations vis-à-vis third countries violating trade agreements or applying unjustified restrictions.


Will some prodcuts be exempted from EU tariffs coming from the US?


1. Military Equipment (Regulation (EC) No 150/2003)


Under Council Regulation (EC) 150/2003, customs duties are suspended for weapons, ammunition, certain rare gases, explosives, and related equipment imported by—or on behalf of—EU defence authorities and military forces. This includes parts, components, and training/testing material, provided they are certified for legitimate defence use++.

2. Specific Civilian Product Exemptions

Additionally, select items listed in Annexes VII, X, and XIII will be exempt from the new tariffs. Though these annexes are not part of the defence regulation itself, they were designated in the tariff legislation as defence‑related or strategically critical goods that will not attract duties under the new package.


Important Context

  • The duty-free treatment under Regulation 150/2003 only applies when imports are for use by EU defence authorities and end-use is tightly controlled (e.g., via certification, customs supervision) 

  • The Annex-based suspensions are part of the tariff rollout and serve to preserve access to key defence or security-related goods in areas like automotive, consumer goods, industrial inputs, or other strategic categories.


Bottom line:Yes—U.S.-origin military equipment (under Regulation 150/2003) and certain goods listed in Annexes VII, X, and XIII are exempted from the new EU tariff regime. These exemptions are deliberate, limited in scope, and tied to defence or strategic use only. Let me know if you want a breakdown of the exact CN codes in Annexes VII, X, and XIII.



How do the measures work, and what are the main legal and economic justifications?


These are not “random” tariffs—they’re calculated, rules-based, and justified under the WTO Safeguards Agreement.


The EU argues that the US never proved an actual surge in imports or harm to its domestic industries.


As a result, the EU can suspend equivalent obligations immediately. Duties are precisely set to mirror the commercial impact of US tariffs, with multiple rates (10%, 25%, 30% etc.) depending on the product and which round of US tariffs they are rebalancing. The regulation details every rate, justification, and economic assessment, ensuring proportionality and minimal harm to EU interests.


This is compliance at its most strategic: every line, every product, every rate is chosen to maximize relief for EU industries while minimizing negative consequences for EU consumers and supply chains.



What’s the immediate economic impact on compliance, supply chains, and costs?


The estimated value of EU exports affected by U.S. trade measures is significant across multiple sectors:

  • €8 billion – Existing tariffs on traditional steel and aluminium

  • €18 billion – Newly announced steel and aluminium duties

  • €67 billion – Automobiles and automotive parts

  • €1 billion – Aluminium beverage cans and related packaging

  • €285 billion – Total value of EU goods subject to reciprocal countertariffs under EU Regulation 2025/1564


For customs professionals and compliance officers, the work starts now. Importers must review every affected tariff line, calculate landed costs, and ensure correct declaration of the new duties.


Exporters must check if their goods are now prohibited for sale to the US. For many, existing contracts may need to be renegotiated—or at the very least, prices updated. The regulatory risk? High.


Customs and compliance teams must update procedures, educate staff, and maintain up-to-date documentation to avoid penalties or delays at the border.


The cost impact is likely to be significant, especially in sectors most exposed to US–EU trade.


What do customs consultants, importers, and exporters need to do next?


  1. First, review the official annexes and identify which of your imports/exports are affected. Engage with a customs consultant to re-map your supply chain risk.

  2. Update your compliance checklists, adjust your customs valuation and landed cost models, and prepare to renegotiate supply contracts as needed.

  3. Monitor for updates: the Commission will adjust measures if the US changes its tariffs again.

  4. Above all, communicate.

  5. Inform your US partners, update your customers, and work with legal advisors to ensure you remain compliant with both EU and US regulations.

  6. This is a fast-moving game—and knowledge is your best defense.


Arne’s Takeaway

The EU’s 2025 rebalancing regulation is a masterclass in strategic customs response. It’s a reminder that customs compliance isn’t just paperwork—it’s high-stakes risk management at the heart of global trade. Stay proactive, seek advice, and keep your compliance house in order.


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Disclaimer

This blog is for educational and informational purposes only and does not constitute legal advice. Please consult a qualified trade or customs attorney for advice specific to your situation.


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