Implementation of tariffs under the US-EU framework agreement

Under the new Agreement, the U.S. will apply only the normal "most‑favored‑nation" (MFN) or 15% (whichever is higher) on the majority of EU exports to the United States (including pharmaceuticals, automobile and semiconductors), as well as product-specific exemptions and commitments to enhanced cooperation in key sectors including energy, investment, and advanced technologies. The agreement specifies this as an “all-inclusive” ceiling rate, preventing the accumulation of additional duties. In the opposite direction, U.S. exports to the EU will experience zero or minimal tariff rates, creating asymmetrical market access conditions.

Key effective dates

:

August 1, 2025:
New auto and auto‑parts (Proclamation 10908 items) tariff treatment applies to EU products. Filers will start applying the 15% combined duty rule at entry.
September 1, 2025:
MFN-only treatment and exemptions for EU civil aircraft/parts, cork/natural resources, and non-patented pharma items (and many inputs/precursors) begins at entry.
September 5, 2025:
Executive Order 14346 issued to implement framework.
September 25, 2025:
Federal Register notice takes effect; FTZ privileged foreign status requirement for covered EU autos/parts begins.

Antidumping and countervailing duties still apply where in force and agencies may update the product lists and procedures as needed.

Automobiles and automobile parts

New standardization: For EU passenger vehicles, light trucks, and covered auto parts:
If the MFN rate is 15% or higher: The additional tariff imposed under Proclamation 10908 is removed; you pay the MFN rate only.
If the MFN rate is below 15%: The Proclamation 10908 tariff is reduced so that the MFN plus the residual Proclamation tariff equals a combined 15%.
Practical effect: EU autos/parts face a floor of 15% combined duty. If an item’s MFN is already ≥15%, there is no extra charge beyond MFN.
Entry date: Applies to goods entered or withdrawn for consumption on or after 12:01 a.m. EDT, August 1, 2025.
FTZ status: Starting September 25, 2025, EU autos/parts subject to these rules must be admitted to U.S. FTZs in privileged foreign status (19 CFR 146.41). That locks the duty rate to the status at admission for later entry.
Interactions with other tariffs: The notice specifies that certain "232/derivative" duties (aluminum/steel/copper lists) do not apply to entries covered by the new EU auto headings, but any AD/CVD still applies.
Usual Chapter 98 eligibility applies, but for 9802.00.60 the duty is assessed on the full value of the imported article (no cost‑of‑repairs calculation). No other Chapter 99 provision can be used to reduce duty below what 9903.94.50–.53 require; other additional duties (e.g., AD/CVD) still apply.

Civil aircraft and aircraft parts

Under the “zero-for-zero” tariff arrangement, both the EU and U.S. will levy zero tariffs on all aircraft and components, marking a significant stabilization step for an industry extremely sensitive to cross-border trade barriers.
MFN-only and broad exemptions: Civil aircraft, their engines, parts, components, subassemblies, and ground flight simulators (meeting General Note 6 criteria) are exempted from the reciprocal tariff and from the 232-style duties on aluminum, steel, and copper. They get MFN treatment regardless of whether entered under "Free (C)" special rates.
Entry date: Applies to goods entered or withdrawn for consumption on or after 12:01 a.m. EDT, September 1, 2025.

Generic pharmaceuticals and their ingredients/precursors

MFN-only: Non‑patented articles for use in pharmaceutical applications (including an extensive list of chemical inputs - “Pharma” tagged list in Annex I) receive MFN treatment; they are carved out from the reciprocal tariff add‑ons.
Entry date: Applies to goods entered or withdrawn for consumption on or after 12:01 a.m. EDT, September 1, 2025

Unavailable natural resources (e.g., cork)

The EU items listed in Annex I (a long HTSUS list that includes cork and many raw/mineral inputs) are exempted from the reciprocal tariff under EO 14257 via new Chapter 99 headings 9903.02.74 and 9903.02.75.
MFN-only: This defined set of natural resources and cork products from the EU are exempt from the reciprocal tariff and receive MFN treatment.
Entry date: Applies to goods entered or withdrawn for consumption on or after 12:01 a.m. EDT, September 1, 2025

The Federal Register notice (FRN) published on September 25, 2025, introduced new tariff subheadings that importers must use when entering covered products from the EU. CBP also published CSMS 66336270 with guidance on the same.

9903.94.50: EU autos with Column 1 duty ≥ 15% (no additional Section 232 duty).

9903.94.51: EU autos with Column 1 duty < 15% (combined duty rate = 15%).

9903.94.52: EU parts with Column 1 duty ≥ 15% (no additional Section 232 duty).

9903.94.53: EU parts with Column 1 duty < 15% (combined duty rate = 15%).

9903.02.76: Civil aircraft and parts.

9903.02.74: Unavailable natural resources (including cork).

9903.02.75: Essential oils (HTS 3301.29.51) for religious purposes.

9903.02.77: Non-patented products for pharmaceutical use.

U.S. Notes to Subchapter III, Chapter 99, have been updated to spell out scope, country list (all EU Member States), ad valorem equivalent calculations for specific duties, and interactions with other special tariffs.

The notice reiterates that antidumping and countervailing duties continue to apply in addition to the treatments above.

As a result of the effective dates stated in the FRN, it is possible that importers may need to file post-summary corrections or protests to obtain refunds where duties were overpaid under the prior requirements. According to CBP guidance, filers can update their previously filed entries to apply the newly issued HTSUS numbers as needed after they are deployed on September 25, 2025. Considerations include:

For products covered under HTSUS headings 9903.94.50 through 9903.94.53 (autos and parts, effective August 1, 2025) and 9903.02.74 through 9903.02.77 (exemptions, effective September 1, 2025), filers should take action to correct entries promptly to reflect the modified duty treatment.

For entries filed within the last 10 days, correct them within 10 days of cargo release from CBP custody and before estimated duties are deposited to avoid refund requests.

For unliquidated entries with duties already paid, file a post-summary correction (PSC) to request a refund. Approved PSCs will be refunded at liquidation.

For liquidated entries, file a protest within 180 days of liquidation under 19 U.S.C. 1514 to claim a refund.

Due to the ongoing complexity and changing nature of the tariffs, importers should consult with their broker(s) and trade counsel for input on this subject.

The updated agreement creates a notably uneven tariff structure. For U.S. businesses, it opens new opportunities for market access in important sectors such as energy, digital services, agriculture, and advanced manufacturing. In contrast, EU companies will encounter increased export expenses and will need to adjust their supply chains and accelerate investment strategies focused on the United States.

As the legal environment continues to develop and negotiations in specific sectors progress, businesses should proactively evaluate the risks and benefits associated with these evolving transatlantic trade dynamics. Additionally, companies should explore ways to participate in the ongoing implementation process.

For more information on how ONESOURCE Global Trade solutions can assist you in managing supply chain risk and regulatory compliance, contact your Account Manager or Client Success Manager.