The US administration has introduced a new tariff regime covering imports from 60 trading partners, including the European Union, following a Section 301 investigation concerning the enforcement of prohibitions on goods produced using forced labour.

The measures enter into force on 24 July, and replace the temporary global 10% tariff previously applied by the US.

EU implications

Products originating in the EU will generally be subject to a total tariff of up to 10%. Importantly, the new measure is not intended to add a further 10% duty on top of the existing US Most-Favoured-Nation tariff:

• where the existing MFN tariff is below 10%, an additional duty will be applied to bring the total tariff to 10%;
• where the existing MFN tariff is already 10% or higher, no additional Section 301 duty should apply under this measure;
• certain EU products are fully exempted, including aircraft and aircraft parts, generic medicines, active pharmaceutical ingredients, cork and diamonds.

The European Commission has cautiously welcomed the fact that the new framework appears consistent with the tariff commitments made under last year’s EU–US agreement, under which tariffs on most EU products were not to exceed 15%. However, the EU has rejected the US assertion that it does not effectively enforce its forced-labour import prohibition and is seeking further clarification from Washington.

More information

The structure of the measure could be comparatively less detrimental for sporting goods products that already face relatively high US MFN tariffs, particularly certain footwear, apparel and textile products. These products should, in principle, not receive an additional Section 301 tariff where their existing MFN rate is already at least 10%.

Conversely, sporting goods and equipment currently entering the US at duty rates below 10% may see their total tariff increased to 10%. Companies should therefore assess the impact at individual tariff-code level, as the treatment will vary considerably between footwear, apparel and equipment categories.

It is also worth noting that US stakeholders requested exemptions for sporting goods during the consultation process, citing limited domestic availability. However, the final decision did not provide a general exemption for the sporting goods sector. A separate mechanism is expected for certain textile and apparel imports from Bangladesh, Cambodia, Indonesia and Malaysia, linked to their use of US cotton and textile inputs.

We will continue monitoring the implementation of the new regime, including its product-level application and any further EU–US discussions or exemptions