The European Union (EU) on 14 April 2025, published countermeasures against recently imposed United States (US) tariffs on steel and aluminum products. However, concurrently, the EU also suspended its countermeasures for 90 days (until 14 July 2025) to allow the US authorities and the European Commission to continue negotiations.

Background

On 9 April 2025, US President Trump announced a 90-day pause on most of his Reciprocal Tariff Policy, originally announced on 2 April 2025. While the additional 10% ad valorem duty rate on all imports into the United States (applicable since 5 April 2025) remains in place, the additional country-specific ad valorem duties are suspended for 90 days, except for the duties on China. (For details, see EY Global Tax Alert, US suspends President Trump's Reciprocal Tariff Policy for 90 days, except for China, dated 11 April 2025.) Moreover, certain electronic products have been exempted from President Trump's Reciprocal Tariff Policy (see EY Global Tax Alert, US exempts certain electronic products from tariffs under President Trump's Reciprocal Tariff Policy, dated 14 April 2025).

These pauses do not, however, affect US tariffs on imports of steel, aluminum and automotive products, which are being implemented against imports from all trading partners, including the EU.

EU countermeasures

Although the EU has published countermeasures against these additional US tariffs on steel and aluminum products, the EU has also decided to suspend its countermeasures for 90 days (until 14 July 2025) to allow the US authorities and the European Commission to continue negotiations.

The EU's countermeasures were due to follow a multi-staged implementation:

• As of 15 April 2025, the EU would impose additional tariffs of 10% and 25% on a variety of products listed in the legislation, including products that were already targeted in the 2018 countermeasures, such as motorbikes, boats and certain textiles. Compared to 2018, however, bourbon and other alcoholic beverages have been removed from the list. (For background, see EY Global Tax Alert, US suspends tariff exemptions on steel and aluminum for EU and NAFTA countries; EU, Canada and Mexico to impose retaliatory duties on a wide range of products, dated 1 June 2018.)
• As of 16 May 2025, an additional 25% tariff would be imposed on a range of products not previously covered by the 2018 countermeasures, covering more than 1,300 Combined Nomenclature (CN) codes (including poultry, meat, eggs, agricultural products, oils, plastics and leather).
• As of 1 December 2025, 25% additional tariffs would be imposed on a final list of five CN codes (e.g., almonds and certain soybeans).

Given the EU's decision to suspend applying the countermeasures, the actual implementation of the additional tariffs on 15 April 2025 and 16 May 2025 has now been postponed to 15 July 2025. Additionally, 15 July 2025 marks the end of the suspension of the additional tariffs adopted in 2020 against US lighters, fittings for furniture and playing cards.

In parallel, the EU will continue with preparations on further countermeasures against US tariffs.

Actions for businesses

Businesses should continuously monitor whether they have any trade flows that are affected by tariff measures adopted by the US, the EU, or any other country that may be relevant for their supply chain.

Starting from that impact assessment, businesses can consider specific actions for the affected flows, including transfer pricing, price setting, contractual clauses, supply chain routes and the use of special customs procedures.

Businesses should approach current tariff developments strategically and proactively by reviewing their global trade footprint to assess whether they are correctly applying legislation related to tariff classification, customs valuation and origin. At the same time, businesses should investigate optimization possibilities considering their global tax position as well as commercial and logistic interests.