A fresh look at US customs tariff policy
Tariff policy

A fresh look at US customs tariff policy

Customs tariff by the United States of America are dominating the headlines. An interim assessment of the legal basis and current tariff rates.

A look back at the US tariff developments

The 47th US President has made tariff policy a priority in his term in office. He initially imposed tariffs on products such as steel, aluminum, and automobiles, based on the Trade Expansion Act of 1962. These sector-specific tariffs remain in effect.

He referred to the announcement of reciprocal, country-specific tariffs in the Executive Order of April 2, 2025 – issued under the International Emergency Economic Powers Act (IEEPA) – as “Liberation Day.” On February 20, 2026, however, the US Supreme Court ruled that the President does not have the authority to do so. The ruling thus limits the President’s emergency powers in trade policy.

Relying on a different legal basis – Section 122 of the Trade Act of 1974 – the White House responded with a temporary global special tariff of 10%. This took effect on February 24, 2026, for a period of 150 days. Since July 24, 2026, the special tariff has been in effect under Section 301 of the Trade Act of 1974.

The agreement between the EU and the US

As described above, the EU is subject to the 10% special tariff as well as the Section 232 measures on steel and aluminum products, copper goods, wood and sawn lumber, semiconductors, trucks, and buses.

Exception: For motor vehicles and motor vehicle parts originating in the European Union, a customs duty cap has been in effect since August 1, 2025. The total duty burden resulting from the regular MFN tariff rate and additional duties may not exceed 15%.

This was negotiated in Turnberry, Scotland. The joint statement by the EU and the US forms the basis of the agreement that the EU intends to conclude with the US by the end of 2029. Consequently, subject to certain safeguard mechanisms, the EU has allowed the US to import the vast majority of all US products duty-free, without ad valorem duties, or at reduced duty rates under quotas, effective July 1, 2026. 

Valid worldwide: Tariffs on imports to the US

Tariffs on steel and aluminum were already imposed during President Donald Trump's first term in office. After suspensions and quota regulations, measures were once again enforced during his second term, and tariffs were gradually increased. They are based on Section 232 of the Trade Expansion Act of 1962. A tier model was introduced with the proclamation of April 2, 2026. The most important points in brief:

Tariffs on steel, aluminum and copper

  • Since June 4, 2025, the US has levied a 50% tariff on steel and aluminum imports. Since then, importers have been required to ensure that a report on melting and casting or a material test report (Mill Test Certificate) is available, otherwise there is a risk of up to 200% additional duty for Russian steel and aluminum.
  • With the White House announcement Adjusting imports of copper into the United States of July 30, 2025, the 50% tariff was also introduced on copper and derivatives.
  • Since April 6, 2026, a new tiered model applies – now the duty is calculated on the total value of goods made of steel, aluminum or copper and no longer just on the metal content. More on this in the fact sheet: Tariffs on Steel, Aluminum, and Copper Imports
  • On June 8, 2026, further changes took effect: With the Proclamation Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper into the United States, additional products were added to Annex III, for which only a 15 percent tariff applies, and the definition of “derivative products” was expanded. The US origin threshold was also relaxed. Annex I-C lists the modified rates by product and partner country: For products from the EU, for example, a 15 percent rate applies. These changes are temporary and will remain in effect until December 31, 2027. The corresponding CBP guidelines for determining tariffs on aluminum, steel, and copper have been revised.

Tariffs on semiconductors and derivatives

  • With Proclamation 11002 of January 14, 2026, the USA introduced additional tariffs on integrated circuits or products containing them. As per the Annex, the goods currently affected are classified under 8471.50, 8471.80 and 8473.30. 
  • However, the additional duty rate does not apply if the semiconductors and derivatives are intended for critical infrastructure or defense. Further exceptions are listed in the proclamation. 
  • The U.S. Customs and Border Protection (CBP) provides guidance on the implementation of the proclamation in their Cargo System Messaging Service under CSMS #67400472.

Tariffs on cars/trucks, car/truck parts and buses

  • Since the White House proclamation on March 26, 2025, Adjusting Imports of Automobiles and Automobile Parts into the United States, the US has imposed an additional tariff of 25% on US imports of motor vehicles from compact cars to sedans to light commercial vehicles, and motor vehicle parts such as engines, transmissions, and electrical components. 
  • The tariffs on automobile imports took effect on April 3, and the supplemental tariffs on automobile parts came into effect on May 3. To avoid a double burden, additional tariffs on aluminum and steel are not due for automobile parts. Please note: Imports of automobiles and automobile parts from the EU are only subject to a 15% tariff.
  • A tariff rate of 25% has applied to medium- and heavy-duty trucks (US classes 3 to 8) and certain parts of these vehicles since November 1, 2025 in accordance with the proclamation of October 17, 2025 Adjusting Imports of Medium- and Heavy-Duty Vehicles, Medium- and Heavy-Duty Vehicle Parts, and Buses Into the United States
  • The same proclamation also includes certain buses for which a tariff rate of 10 % is introduced. The documentation process for exemptions for medium- and heavy-duty trucks and parts thereof that are covered by the US agreement with Mexico and Canada (USMCA) is described in the Federal Register Notice dated February 2, 2026
  • In addition, refunds are possible until 2030 for final assembly in the US. 

Tariffs on timber and sawn timber

  • As of October 14, 2025, a general tariff of 10% will apply to imported softwood and construction timber and a 25% duty on kitchen and bathroom furniture and upholstered wood products. 
  • Exceptions apply to Japan and the EU. In the EU, tariffs will not exceed 15%. 
  • The affected timber and sawn timber products are listed in the Timber HTS List.

Tariffs on pharmaceutical products

  • The Proclamation of April 2, 2026, is intended to impose a 100% ad valorem duty on (patented) pharmaceutical products and their ingredients from July 31, 2026. The additional duties under Section 232 Trade Expansion Act are to come into force in stages: 
  • For certain large companies listed by name in Annex III of the proclamation, the duties will come into force on July 31, 2026, and for all other companies on September 29, 2026. 
  • Generics, biosimilars and their ingredients are currently completely exempt from these duties. This also applies to specialized pharmaceutical products – the list can be viewed in Annex IV.
  • Pharmaceutical products from the European Union, Japan, the Republic of Korea, Switzerland, and Liechtenstein are only subject to a duty rate of 15%. For the United Kingdom, only 10% applies with the possibility of a further reduction.

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De minimis: Customs duties for small consignments

Since August 29, 2025, the de minimis value limit has been reduced from 800 to 50 US dollars. With the Executive Order Suspending Duty-Free De Minimis Treatment for all Countriesof July 30, 2025, small shipments above the new limit will be subject to country-specific customs duties (ad valorem method).

With the Executive Order Continuing the Suspension of Duty-Free De Minimis Treatment for All Countries, the US President declared on February 20, 2026, that the suspension of duty-free de minimis treatment will continue to apply to all countries.

Search for supplemental tariffs affecting your goods

You can search for US tariffs affecting your goods using the Harmonized Tariff Schedule, a database maintained by the US International Trade Commission that catalogs the tariffs imposed by the United States. It contains the US duty rates and special classification provisions (chapter 98) or temporary regulations (chapter 99). Start by entering the international six-digit code of your merchandise here, or use the keyword search.

Alternatively, you can use the EU Commission's database Access2Markets. The current duty rates of all countries are made available there. From the main page, enter the six-digit HS code, your country of origin, and the United States under the country of destination.