If you require support in any of these areas, contact our team directly or download the BDO Aviation Brochure for a detailed overview of how we can assist.
US TARIFFS AND TRADE
For 2025, the application of US tariffs to imports of aircraft and parts was one of the sector's biggest concerns, along with the reactive imposition of duties by other countries, such as China, to this measure. In addition, concerns about the EU position were also a worry.
So where do things stand now?
1. IEEPA Refunds
On February 20th, 2026, the U.S. Supreme Court ruled that President Trump’s imposition of additional tariffs under the International Emergency Economic Powers Act (IEEPA) exceeded his authority. As a result, these tariffs have been revoked.
Therefore, if you imported aircraft or aircraft parts into the United States that were subject to IEEPA tariffs, you may be eligible for a refund.
US Customs are currently developing a system to process these refunds.
In preparation for this Importers are advised to initiate “refund readiness” efforts now by:
2. Section 122 tariffs
Following the invalidation of the IEEPA tariffs, President Trump immediately introduced a new Section 122 tariff on February 24th, which imposes a 10% surcharge on top of MFN rates for imports into the US.
Note that these do not currently apply to civil aircraft and most related parts.
These tariffs are only temporary (150 days) and are currently subject to challenge. We also await further developments on what will happen after the 150-day period.
3. Ongoing Trade Friction with the U.S.
The EU and US agreement of September last year exempted aircraft and most parts from IEEPA duties and any EU retaliation.
However, following the Supreme Court ruling, the European Union (EU) paused the ratification of this trade agreement with the United States. While this has now resumed in Parliament, it remains a point of friction.
From a tariff perspective, the deal confirms that:
While EU-origin aircraft and most parts remain duty-free under both the US-EU deal and the recently introduced Section 122 10% global tariff, EU exporters should maintain vigilance for any potential policy changes impacting tariffs or market access, such as for example, the Section 301 and S232 investigations (see below)
4. Section 301 investigation
On 11th March, the USTR announced a Section 301 investigation targeting 16 countries, including the EU, and specifically called out Ireland. These investigations relate specifically to "structural excess capacity and production in manufacturing sectors".
Why?
“The United States will no longer sacrifice its industrial base to other countries that may be exporting their problems with excess capacity and production to us. Today’s investigations underscore President Trump’s commitment to reshore critical supply chains and create good-paying jobs for American workers across our manufacturing sectors,” said United States Trade Representative Jamieson Greer. “The Trump Administration’s reindustrialisation efforts continue to face significant challenges due to foreign economies’ structural excess capacity and production in manufacturing sectors. Across numerous sectors, many U.S. trading partners are producing more goods than they can consume domestically. This overproduction displaces existing U.S. domestic production or prevents investment and expansion in U.S. manufacturing production that otherwise would have been brought online. In many sectors, the United States has lost substantial domestic production capacity or has fallen worryingly behind foreign competitors."
For the EU, the announcement stated that “The European Union maintains a global goods trade surplus, led by exports in sectors such as chemicals and related products, machinery, and vehicles.”
For Ireland specifically, the pharmaceutical sector was called out.
5. Section 232 investigation
On 1 July, the US announced a Section 232 investigation into Commercial aircraft, jet engines, and parts, as well as separate investigations into unmanned aircraft systems (UAS). No results have been published at the time of writing, and the investigation remains open.
GEOPOLITICS
Along with the customs duty issues facing the sector, companies also need to keep up to date with changing Trade Regulations and the impact of geopolitics on what is arguably one of the most globalised industries. For example:
1. Sanctions and Export Controls
EU exporters must ensure full compliance with both dual-use, military and sanctions regulations. While civil aircraft are not covered by dual-use regulations, many parts can be on the list.
This is made more complex by, in particular, the Russian/Belarus sanctions regulations, which strongly focus controls on the aircraft sector. Notably, certain provisions—such as Article 12g of Regulation 833/2014—may apply even if the export is not destined for a sanctioned territory.
Article 12g obliges EU exporters to insert a "no re-export to Russia" clause in their export/sale/supply/transfer or similar contracts, and along with this, exporters in this sensitive area need to carry out due diligence on sales, leases and exports and be aware of the risks of diversion.
2. Middle East Conflict
The recent conflict with Iran in 2026 has resulted in significant disruptions to global trade. Key impacts include:
While all business should reassess their supply chains and logistics strategies to mitigate ongoing risks, the aircraft sector is also particularly vulnerable with increases in insurance costs and risks to assets and leases.
In the event aircraft need to be exported quickly from one jurisdiction to another, lessors need to have contingency plans in place. As we learnt from the Russian conflict, speed of recovery is of the essence and equally having a place to land and store aircraft is critical. Advance planning in relation to customs and trade impacts is advisable, but also the ability to react quickly and to obtain immediate expert advice regardless of jurisdictions becomes critical.
3. Aerospace and Defence
As Defence industry spending increases, companies are seeing rising demand for aviation-related products and services for military and dual-use applications. This is a complex area with risk for reputational damage and, therefore, is something companies need to prioritise in terms of internal expertise or external support.
CUSTOMS
Finally, in terms of horizon scanning, new rules around centralised clearance in Europe will be of interest to lessors and parts importers.
1. Centralised Clearance in Europe
Most lessors import into multiple EU Member States, and can require clearance support in a number of Member States. The new Centralised Clearance (CCL) procedure will enable traders to:
This Customs simplification allows businesses operating across several Member States to streamline and standardise their Customs procedures, enhancing operational efficiency.
As most aircraft lessors operate out of Ireland, centralising this clearance process here, using our in-house clearance service, makes this a viable option, providing access to both the aircraft advisory service and also the operational clearance service for interaction with Customs.
Consider leveraging the Centralised Clearance (CCI) procedure, recently implemented under the Union Customs Code (UCC), using BDO as your centralised operator.
2. ODS Reporting
Please note that the 31st of March deadline for ODS reporting is approaching. Aircraft operators should ensure the following reports are submitted:
CONCLUSION
As we can see, there is a lot to manage and keep up to date on regarding aircraft and parts shipments. In Europe, there are additional complexities, as notwithstanding all Member States operate under the rules set down by the EU Customs Code, there are operational variances at the local level.