The EU has implemented its side of the Turnberry Agreement.

The critical elements are:

  • Duty on US-originating items listed in Annex 1 of the Regulation has been reduced to 0%. This covers pretty much all products outside of sensitive food and agricultural products. However, please check Annex 1 to ensure your products are included.
  • In order to qualify, goods must be considered "originating" under the rules of origin set out in the UCC. This is a similar principle to that applied in FTAs. The official preferential rules have not yet been drafted and, therefore, the non-preferential rules apply. Your goods must qualify as US-originating to avail of the 0% duty rate on import.


Other

  • Goods in Annex 2 can be imported at 0%, but imports will be monitored, and duty may be re-applied where the import price falls below the entry price. 
  • Goods that can be imported at 0% up to a quota level are listed in Annex 3.

Safeguard Clauses

The Commission is empowered to amend the Regulation suspending the duty reductions above if the US increases duties beyond the maximum 15% on all EU imports.

The 15% ceiling was introduced under the original IEEPA duty regime. When this was deemed illegal, the current Section 122 duties came into effect on a temporary basis at 10% plus MFN. These are now due to expire on 24 July and are expected to be replaced by a new Section 301 duty regime.

The Commission is also empowered to reinstate duties on goods within Chapters 72, 73 and 76 (essentially iron, steel and aluminium) if the current US Section 232 duties on iron, steel, copper and derivative products are not reduced to 15%. This will be reviewed on 1 December.

In this context, the Commission states in the preamble:

The Joint Statement does not provide for the application of the 15% tariff ceiling to steel and aluminium; therefore, the tariffs of 50% imposed by the United States in 2025 remain in place. The Union and the United States have, however, expressed their intention, in the Joint Statement, to consider the possibility of cooperating on ring-fencing their respective domestic markets from steel and aluminium overcapacity, while ensuring secure supply chains between each other, including through tariff quota solutions.

Authors

Carol-Lynch-customs-international-trade-partner-bdo
Carol Lynch
Tax Partner & Head of Customs and International Trade Services, BDO Dublin
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BDO Global Trade Services

As Global Trade becomes more complex, and more subject to risk, we can advise on your trade implications in a Geo-Political context, assess the Risk Landscape and provide proactive duty planning, ensuring security of supply, and support in accessing new markets. In addition, we can provide Board Level briefings in order to support and advise in this new environment. If you think any of these updates could affect your business, don’t hesitate to contact us for further information or to arrange a consultation.

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