In April 2025, the European Union (“EU”) set tariffs on a series of US imports but immediately suspended their application until 14 July 2025. This was due to the US almost simultaneously announcing that it would be softening its across-the-board tariffs. In the case of EU exports, this meant going from a 20% to a 10% general “reciprocal” tariff for three months to negotiate better US/EU trade arrangements.

Possible further EU countermeasures on imports of US goods

Regardless, the European Commission (“EC”) hopes to have new countermeasures ready in case the ongoing trade negotiations between the EU and the US “do not produce a satisfactory result.” The EC has published a list of EU Combined Nomenclature (“CN”) codes, which represent categories of US goods which could be subjected to even further retaliation by the EU if the US does not adequately resolve its tariff dispute with the EC (vid. here). Examples of industries with goods that could be affected by the proposed countermeasures are: 

• Agrifood
• Agricultural equipment
• Chemical hydrocarbons
• Alcohol/Spirits
• Metals
• Appliances and other household items
• Sports equipment
• Automobile
• Turbines / related
• Seagoing vessels
• Aircraft
• Paper

On 8 May 2025, in light of the slow pace of the negotiations, the EC announced that it would be hosting a stakeholder consultation, running until 10 June 2025. All interested parties may participate in consultations, including EU stakeholders, as well as US and third-nation companies (vid. here). Any new countermeasures would presumably apply concurrently with those which were suspended in April 2025. 

The EC has not indicated what form these new countermeasures might take. The most likely scenario is that they would mostly take the form of retaliatory tariffs. The suspended April countermeasures constitute ad valorem tariffs ranging from 10% to 25%, depending on the type of good(s) in question.

The EC aims to make their newly proposed countermeasure operable before the US’ three-month tariff respite ends. Therefore, it would likely seek to have its proposals adopted by the time the temporary suspension of the April 2025 countermeasures runs out (i.e. on 15 July 2025).

It is important to note that, as of now, these new countermeasures are merely a possibility. Indeed, they have been proposed, and their implementation is being envisaged. Nevertheless, they are not yet definitive, as that would require their formal adoption by the EC and subsequent publication in the EU’s Official Journal. 

Possible EU export controls on US-bound goods

In tandem with the tariff countermeasures, the EC has also published a list of EU goods that could be subject to export controls when bound for the US (available here). This list is much shorter than the proposed US goods list discussed above, but it does contain certain key goods such as:

• Ferrous waste and scrap;
• Remelting scrap ingots of iron or steel;
• Aluminum waste and scrap;
• Toluidines and their derivatives, and salts thereof;
• Mixtures of odoriferous substances and mixtures of a kind used as raw materials in the food or drink industries, as well as other preparations based on odoriferous substances; and
• Certain enzymes.

According to the EC, exports restrictions would affect US-bound goods worth EUR 4.4 billion. The exact form that the possible export controls would take remains unknown.

During the aforementioned consultation period running until 10 June 2025, interested parties may likewise submit comments on the scope of these proposed export controls.

How we can help

The publication of the proposed lists of US and EU goods by the EC constitutes a significant moment in transatlantic trade relations. While the two parties are formally engaged in trade negotiations, the EU is now threatening to impose considerably more severe countermeasures on the US. This escalation could impact both importing and exporting companies, as well as businesses throughout the broader supply chains. Nevertheless, the EC’s stakeholder consultations provide a valuable opportunity to engage with EU authorities on this situation to advocate for targeted, meaningful adjustments. Time is of the essence for companies who wish to participate in the consultation. An effective, evidence-based submission must be made before the 10 June 2025 deadline.