EU Products Get More U.S. Tariff Relief

On September 25, 2025, the International Trade Administration, U.S. Department of Commerce and the U.S. Trade Representative announced changes to the Harmonized Tariff Schedule of the United States (HTSUS) to implement elements of the U.S. – EU Framework Agreement on Reciprocal, Fair, and Balanced Trade Agreement that adjust tariffs on certain articles that are products of the European Union (EU).

Amendments include changes to:

• Automobiles and automobile parts subject to Section 232 auto/auto parts tariff
• Aircraft and aircraft parts that fall under the World Trade Organization (WTO) Agreement on Trade in Civil Aircraft
• Reciprocal tariff exemption on certain products:
  • Unavailable natural resources (including cork)
  • Generic pharmaceuticals, their ingredients and chemical precursors (not patented in the U.S.)
  • Essential oils for religious purposes

Details

The following information is from the U.S. Customs and Border Protection (CBP) CSMS # 66336270 – Guidance – Implementation of Tariff-Related Elements of the United States-European Union Framework Agreement, and applies to products of EU member countries.

EU Member Countries include:

Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia (Czech Republic), Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, and Sweden

Section 232 Duties on Automobiles and Automobile Parts

Effective Date

When entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern daylight time on August 1, 2025, the Section 232 tariff is based on the ad valorem Column 1 tariff applicable to the products.

Automobiles

• 9903.94.50 – For an automobile that is the product of an EU member country with a Column 1 duty rate greater than or equal to 15 percent ad valorem, the additional Section 232 duty rate is zero (0). 
• 9903.94.51 – For an automobile that is the product of an EU member country with a Column 1 duty rate less than 15 percent ad valorem, the combined Column 1 and additional Section 232 duty rate is 15 percent ad valorem. 

Automobile Parts

• 9903.94.52 – For an automobile part that is the product of an EU member country with a Column 1 duty rate greater than or equal to 15 percent ad valorem, the additional Section 232 duty rate is zero (0). 
• 9903.94.53 – For an automobile part that is the product of an EU member country with a Column 1 duty rate less than 15 percent ad valorem, the combined Column 1 and additional Section 232 duty rate is 15 percent ad valorem. 

Interaction with Other New Tariffs

Automobiles and auto parts subject to Section 232 are exempt from reciprocal tariffs under HTSUS 9903.01.33.

These products are also part of the unstacking rules, which state that if a product pays Section 232 Auto/Auto Parts, it is exempt from tariffs imposed by:

• Section 232 – Aluminum
• Section 232 – Steel
• Section 232 – Copper (refer to: New Copper Tariffs Start Friday – NNR Global Logistics)
• IEEPA – Canada
• IEEPA – Mexico

List of HTS numbers subject to Section 232 Auto Part Tariffs

Source: CSMS # 64916652 – UPDATE to CSMS # 64913145:D GUIDANCE: Import Duties on Certain Automobile Parts

Civil Aircraft

Effective Date

When entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern daylight time September 1, 2025.

Details

Products of EU member countries that fall under the World Trade Organization (WTO) Agreement on Trade in Civil Aircraft, are no longer subject to additional tariffs imposed through:

• Executive Order 14257 of April 2, 2025 (Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits), as amended;
• Proclamation 9704 of March 18, 2018 (Adjusting Imports of Aluminum Into the United States), as amended;
• Proclamation 9705 of March 8, 2018 (Adjusting Imports of Steel Into the United States), as amended;
• Proclamation 10962 of July 30, 2025 (Adjusting Imports of Copper Into the United States), as amended.

Additional HTSUS Numbers

9903.02.76 – Articles of civil aircraft (all aircraft other than military aircraft); their engines, parts, and components; their other parts, components, and subassemblies; and ground flight simulators and their parts and components that are the products of the EU member countries, excluding unmanned aircraft, that otherwise meet the criteria of General Note 6 of HTSUS (Articles Eligible for Duty-Free Treatment Pursuant to the Agreement on Trade in Civil Aircraft), and are classified in the HTSUS classifications listed in subdivision (v)(xviii) of U.S. note 2 to subchapter III of chapter 99 of the HTSUS, but regardless of whether a product is entered under a provision for which the rate of duty “Free (C)” appears in the “Special” sub column.

List of Civil Aircraft-Related HTSUS Numbers

For a list of civil aircraft-related HTSUS numbers that shall not be assessed additional duties as per above, refer to Annex II(B)(4)(xviii).

Reciprocal Tariff Exemption on Certain Products

Certain products including unavailable natural resources and generic pharmaceuticals and their ingredients and chemical precursors that are products of EU member countries are no longer subject to Reciprocal tariffs.

Effective Date

When entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time September 1, 2025.

Exempt Products

Products exempt from the reciprocal tariffs can be found in Annex I of the Implementing Certain Tariff-Related Elements of the U.S.-EU Framework on an Agreement on Reciprocal, Fair, and Balanced Trade. Please note that there are scope limitations indicating only a portion of the HTSUS is covered. Scope Limitations can be found in the “Scope Limitations” column of the table in Annex I when “Ex”, “Aircraft”, or “Pharma” is listed.

• A subheading marked with “Ex” is defined and limited by the product description.
• A subheading marked with “Aircraft” includes only articles of civil aircraft (all aircraft other than military aircraft); their engines, parts, and components; their other parts, components, and subassemblies; and ground flight simulators and their parts and components, that otherwise meet the criteria of General Note 6 of HTSUS, regardless of whether a product is entered under a provision for which the rate of duty “Free (C)” appears in the “Special” sub-column.
• A subheading marked with “Pharma” includes only non-patented articles for use in pharmaceutical applications.

Additional HTSUS Numbers

9903.02.74 – Products of EU member countries that are unavailable natural resources (including cork) as provided for in subdivision (v)(xvi) of U.S. note 2 to subchapter III of chapter 99 of the HTSUS.

• A list of natural resources HTSUS numbers may be found in Annex II(B)(4)(iii).

9903.02.75 – Products of EU member countries, that are essential oils other than those of citrus fruit, other, nesoi, classified under HTS 3301.29.51, for religious purposes only as provided for in subdivision (v)(xvii) of U.S. note 2 to subchapter III of chapter 99 of the HTSUS.

• The only HTSUS number qualifying for this exemption at this time is “Essential oils other than those of citrus fruit, other, nesoi, for religious purposes only,” classifiable in subheading 3301.29.51.
• Recordkeeping Requirement: Filers should ensure that all supporting documentation that substantiate proof of the product’s intended use for religious purposes be kept on file for recordkeeping purposes.

9903.02.77 – Products of the EU member countries, that are not patented in the U.S., and that are for use in pharmaceutical applications, classified in the subheadings enumerated in subdivision (v)(xix) of U.S. note 2 to subchapter III of chapter 99 of the HTSUS. 

• A list of articles that are not patented in the U.S. for use in pharmaceutical applications may be found in Annex II(B)(4)(xix)
• Recordkeeping Requirement: Filers should ensure that all supporting documentation that substantiate proof that the products are non-patented articles for use in pharmaceutical applications are kept on file for recordkeeping purposes.

FAQs

Can a customs entry be retroactively corrected?

Yes. Entries for which duties have not yet been paid, the filer may correct entries to avoid needing refunds.  For unliquidated entries for which estimated duties have already been deposited, importers may file a post summary correction (PSC) to request a refund.  Upon PSC approval, the refund will be issued at liquidation.  For liquidated entries, importers may request a refund by filing a protest within 180 days after liquidation in accordance with 19 U.S.C. 1514.

Have Questions?

Contact your local NNR Representative