Proposed EU countermeasures to target U.S. exports

Background 

On 23 March 2018, the US imposed a 10% tariff on all aluminium imports and a 25% tariff on all steel imports, under Section 232 of the Trade Expansion Act of 1962¹. Additional tariffs were introduced in January 2020, affecting various steel and aluminium derivative products arriving into the US, including exports from the EU. In response, the EU imposed countermeasures in 2018² and 2020³ , with new tariffs ranging from 10% to 50% on various US exports into the EU. Further rebalancing measures were due to enter force on 1 June 2021. Following negotiations, the US implemented a quota tariff system⁴ on EU steel and aluminium imports and the EU agreed to suspend its countermeasure tariffs on US goods⁵. The suspension was renewed in December 2023⁶, and is set to expire on 31 March 2025. 

On 10 February 2025, the US imposed a new tariff on all aluminium imports into the US, which led to an increase of the existing tariffs from 10% to 25%⁷. On the same day, the US also announced further measures applicable to the 25% tariff on steel imports⁸. This includes an end to all existing exemptions and quotas granted to the EU, the United Kingdom and various other countries, that were previously in place. Both measures came into force on 12 March 2025. The effect of the measures is that all imports of steel and aluminium into the US, including a wide range of their derivative products, are now subject to a 25% tariff, regardless of the country of origin. On the same day the US measures came into force, the European Commission launched a series of countermeasures,⁹ due to come into force in April 2025, in response. 

Key EU proposals 

1. Reimposition of the suspended 2018 and 2020 rebalancing measures: The EU's countermeasures from 2018 and 2020 will be implemented in full mid-April 2025, following the expiry of the suspension on 31 March 2025 and the European Commission’s reported decision to further delay their entry into force to allow additional time to find a mutually agreeable solution with the US.¹⁰ The new date will also give the European Commission time to refine its tariff package following the expected US reciprocal tariffs on 2 April 2025, and to consider recent statements from President Trump, including the threat of 200% tariffs on EU alcohol. This will be the first time that the 2018 countermeasures will be implemented in their entirety. Tariffs ranging from 10% to 50% will apply to a range of US exports to the EU, including bourbon whiskey, furniture, certain textile products and tobacco. The full list of products covered by the 2018 measures includes steel and aluminium products, agricultural goods, clothing and textile products, whiskey, motorcycles, and other industrial goods, and is available here. The products covered by the 2020 rebalancing measures, which include lighters, plastic fittings for furniture and coachwork and playing cards, are available here. 
2. New countermeasures: The European Commission has also announced that it will introduce a new package of tariffs on US goods¹¹, in response to the broader scope of the current US steel and aluminium tariffs. These will target approximately €18 billion worth of US goods and will apply in conjunction with the reinstated measures from 2018 and 2020. Goods covered by the new EU tariff package will include various industrial products, steel and aluminium products, plastics, additional textiles, home appliances, and agricultural products such as beef and poultry. The European Commission anticipates that the new tariffs will be imposed mid April 2025. The list of proposed targets announced by the European Commission can be found here. 

Legal framework and procedure 

1. While the European Commission initially announced that the reimposition of the suspended 2018 and 2020 rebalancing measures will automatically come into force when the suspension of the implementing regulations expires after 31 March 2025, it has subsequently indicated that their entry into force will be delayed to mid-April 2025. 
2. The EU plans to adopt the new tariffs under Regulation (EU) No 654/2014¹², which allows the suspension of tariff concessions and the imposition of new or increased customs duties to protect EU economic interests, including in response to safeguard measures by third countries. The 2018 EU countermeasures was based on this ground. Although several WTO panels have since ruled that the 2018 US steel and aluminium tariffs do not constitute safeguard measures¹³, the European Commission maintains its 2018 assessment and plans to justify the new countermeasures on this basis as well. 
3. The process of implementing these measures begins with a two week stakeholder consultation¹⁴, running until 26 March 2025, to discuss the targeted products. Following this, the European Commission will finalise its proposal and consult Member States through the comitology procedure. The European Commission aims to have the legal act enforcing the new countermeasures in place by mid April 2025. 

Implementation timeline 

• Reintroduction of 2018 and 2020 countermeasures: mid April 2025. 
• New countermeasures: mid April 2025. 

Authored by Aline Doussin, Lourdes Catrain, Kate Poppitt, Pierre Estrabaud, Alp Ozturk, Dan Shapland, Chris James, Timothy Waitt, Kacper Maksymczuk.