Trade Update: Detailed Guidance for Implementing Tariff-Related Elements of U.S.-EU Agreement
Customs and Border Protection (CBP) has provided more guidance to implement tariff-related elements related to Executive Order (EO) 14346, “Modifying the Scope of Reciprocal Tariffs and Establishing Procedures for Implementing Trade and Security Agreements,” from September 5.
“Implementing Certain Tariff-Related Elements of the U.S.-EU Framework on an Agreement on Reciprocal, Fair, and Balanced Trade” (2025-18660.pdf), was posted by the Commerce Department and Office of the U.S. Trade Representative (USTR) and is scheduled for publication today.
The Federal Register Notice (FRN) includes modifications to the IEEPA and Section 232 of the 1962 Trade Expansion Act of 1962 tariffs applicable to imported articles that are products of EU member countries and amends the HTSUS to adjust tariffs on certain articles that are products of EU member countries, including automobiles and automobile parts, unavailable natural resources (including cork), aircraft and aircraft parts, and generic pharmaceuticals and their ingredients and chemical precursors.
These HTSUS modifications were deployed in ACE at 12:01 a.m. ET on Sept. 25, the date that the FRN will be published in the Federal Register, CBP said. Filers can update their previously filed entries to apply the newly issued HTSUS numbers as needed after they are deployed on Sept. 25.
Notable Updated Guidance for Application of Modified Duty Rates Includes:
Changes to Section 232 Duties on Automobiles and Automobile Parts
The FRN modifies the Section 232 duties on passenger vehicles and light trucks (automobiles) and automobile parts that are products of EU member countries. And is effective for automobiles and automobile parts entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. ET on Aug. 1, 2025, the Section 232 tariff is based on the ad valorem Column 1 tariff applicable to the products.
General Reciprocal Tariffs
As a reminder, pursuant to Executive Order 14236 of July 31, 2025, Further Modifying The Reciprocal Tariff Rates, the Reciprocal tariff currently in place for products of EU member countries, other than those products specified above, entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. ET Aug. 7, 2025 is dependent on the Column 1 ad valorem or ad valorem equivalent duty rate applicable to the products. (See also CSMS # 65829726, GUIDANCE: Reciprocal Tariff Updates.)
For any product of an EU member country subject to a specific or compound rate of duty under column 1-General, the ad valorem equivalent rate of duty of such product is determined by dividing the amount of duty payable under column 1-General by the customs value of the product. For example, if a product were subject to a specific duty of 50 cents per kilogram, and one kilogram of the product were entered with a customs value of $10, then the ad valorem equivalent rate of duty would be obtained by dividing 50 cents by $10, yielding 5%.
When submitting an entry summary to declare the 15% ad valorem duty on products of EU member countries, file using heading 9903.02.20 followed by the appropriate classification under Chapter 1 to 97, HTSUS. Report the 15% ad valorem duty amount on heading 9903.02.20 and report the entry summary line value and 0 duty on the Chapter 1 to 97 HTSUS classification.
Exemptions from Reciprocal Tariffs
Beyond the changes explained above, all other aspects of the Reciprocal tariffs remain in effect for products of EU member countries, including the exemptions from the Reciprocal tariffs that are provided for products covered by HTSUS headings 9903.01.30, 9903.01.31, 9903.01.32, 9903.01.33 and 9903.01.34.
CBP will provide additional guidance through CSMS messages as appropriate. If you encounter any errors in filing an entry summary, contact your CBP Client Representative or the ACE Help Desk, while questions regarding this message should be directed to CBP Trade Remedy at traderemedy@cbp.dhs.gov.
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