The EU countermeasures to US tariffs

1. US measures 

As trade tariffs between the European Union (EU) and the United States (US) continue to reshape the global economic landscape, few will be unaware that these are dynamic times. 

On 10 February 2025, President Trump issued two proclamations entitled “Adjusting Imports of Aluminum into the United States” and “Adjusting Imports of Steel into the United States”. The purpose of these proclamations is to modify the steel and aluminium tariffs that were imposed in 2018 by the First Trump Administration. By way of background, in 2018 the first Trump Administration introduced tariffs on European steel and aluminium exports, also known as the “Section 232 tariffs” – this refers to Section 232 of the Trade Expansion Act of 1962, under which the tariffs were imposed. The tariffs included a 25% tariff on steel imports and a 10% tariff on aluminium imports. In addition, in 2020, the First Trump Administration extended the tariffs to cover certain steel and aluminium derivative products, such as nails and car body and bumper stampings. Until 10 February 2025, the tariffs were subject to a product exclusion application process, as well as General Approved Exclusions ("GAEs"), which are product exclusions that received no previous objections.

Following the above proclamations, on 12 March 2025, the Second Trump Administration implemented US measures consisting of three key elements: 

1. Reinstating the Section 232 tariffs on steel and aluminium products. These covered different types of semifinished and finished products, such as steel pipes, wire and tin foil.
2. Increasing the tariffs imposed on aluminium from the original 10% to 25%. 
3. Extension of the tariffs to other products, namely: 

• Steel and aluminium products, such as household products like cookware or window frames;
• Products that are only partially made of steel or aluminium, such as machinery, fitness equipment, certain electrical appliances or furniture.

Furthermore, by 12 May 2025, the US Secretary of Commerce will establish an system whereby the US will continue to expand the list of steel and aluminium derivatives products subject to additional tariffs of up to 25%.

2. EU’s response 

On the same day, 12 March 2025, the EU expressed its regret at the US decision to impose such tariffs considering them “unjustified, disruptive to transatlantic trade, and harmful to businesses and consumers, often resulting in higher prices”.[1] Further, the EU responded to the imposition of these new US tariffs on European steel and aluminium by way of countermeasures on US imports into the EU. To match the economic scope of the tariffs from the US worth USD 28 billion, the EU’s countermeasures are worth EUR 26 billion.[2]

The EU’s countermeasures include in short: 

1. The reimposition of the suspended 2018 and 2020 rebalancing measures; and
2. The imposition of a new package of additional measures.

2.1. The reimposition of the suspended 2018 and 2020 rebalancing measures

As mentioned above, the First Trump Administration imposed tariffs on European steel and aluminium exports in 2018 and 2020, prompting the EU to impose so-called rebalancing measures. These measures included additional tariffs on imports into the EU of various products originating in the US, as set out in Implementing Regulation (EU) 2018/886[3] and Implementing Regulation (EU) 2020/502[4]. According to Implementing Regulation (EU) 2023/2882 these rebalancing measures have been suspended from 1 January 2024 until 31 March 2025. However, as one of the countermeasures, the EU has decided to reimpose these rebalancing measures, which will therefore apply from 1 April 2025. 

Examples of products originating in the US that will be subject to additional tariffs from 1 April 2025 include (in sum): 

• Various food products (such as rice products, corn and fruit juices); 
• Whiskey;
• Cigarettes and tobacco; 
• Cosmetics;
• Clothing (such as t-shirts and jeans); 
• Products of steel and aluminium;
• Motorcycles;
• Boats.

The additional tariffs range from 10% to 50%. 

The full lists of products can be found HERE and HERE – please note that these lists only include the commodity codes of the goods. 

2.2. The imposition of a new package of additional measures 

The other countermeasure consists of imposing a new package of additional measures which will apply together with the reimposed measures.

According to the European Commission, the first step in this new package is the launch of a two-week consultation with EU stakeholders, which started on 12 March 2025. This consultation will not only ensure that the right products are selected for inclusion in the new countermeasures to provide an effective and proportionate response to the US measures, but also to minimise disruption to EU businesses and consumers. With regard to the latter, the list of targeted products proposed by the European Commission was published on 12 March 2025.[5]

In short, the proposed targeted products include a mixture of industrial and agricultural products, such as: 

• Industrial products: steel and aluminium products, textiles, leather goods, home appliances, house tools, plastics, wood products;
• Agricultural products: poultry, beef, certain seafoods, nuts eggs, diary, sugar and vegetables. 

The full list of US products which could be subject to additional tariffs on imports into the EU can be found HERE.

Following the reporting of the European Commission, the stakeholder consultation will close on 26 March 2025. After this date, the European Commission will consolidate and assess stakeholder input, finalise its draft implementing act and consult EU Member States about it. It is expected that the adoption process will be completed by mid-April 2025 and the act imposing the countermeasures will enter into force shortly thereafter.[6]

Finally, we note that the EU has made it clear that the EU countermeasures can be revised at any time if the US and the EU are able to reach an agreement. 
 

[1]https://ec.europa.eu/commission/presscorner/detail/en/ip_25_740

[2] Press statement by President von der Leyen with Commissioner Šefčovič on EU countermeasures to US tariffs of 12 March 2025 (https://ec.europa.eu/commission/presscorner/api/files/document/print/es/statement_25_752/STATEMENT_25_752_EN.pdf) 

[3] Commission Implementing Regulation (EU) 2018/885 of 20 June 2018 on certain commercial policy measures concerning certain products originating in the United States of America and amending Implementing Regulation (EU) 2018/724, L 158/5, 21 June 2018.

[4] Commission Implementing Regulation (EU) 2020/502 of 6 April 2020 on certain commercial policy measures concerning certain products originating in the United States of America, L 109/10, 7 April 2020.

[5] https://ec.europa.eu/commission/presscorner/api/files/document/print/en/qanda_25_750/QANDA_25_750_EN.pdf

[6] https://ec.europa.eu/commission/presscorner/api/files/document/print/en/qanda_25_750/QANDA_25_750_EN.pdf