The escalation of the tariffs imposed traces its origins back to Donald Trump’s first term in office. It rests on his view that tariffs can be used to shore up the U.S. federal budget and that American consumers will, as a result, feel compelled to buy American products.
The United States imposed additional tariffs, on the basis of Section 232 of the U.S. Trade Expansion Act of 1962, on imports of certain steel and aluminium products originating in the EU, effective from 1 June 2018, and on imports of derivative steel and aluminium products originating in the Union, effective from 8 February 2020.
The EU responded to the initial additional tariffs on 20 June 2018 with Regulation (EU) 2018/886, imposing additional tariffs on certain goods originating in the United States. The additional tariffs are defined for individual tariff codes and can amount to 10%, 25%, 35%, or even 50%. Affected goods included items such as Harley Davidson motorcycles and Bourbon whiskey.
In response to the second round of additional tariffs, the EU reacted on 7 April 2020 with Regulation (EU) 2020/502, adding a small number of further goods.
Under President Joe Biden, the trade dispute was subsequently resolved, with the additional tariffs fully suspended by the EU and suspended by the United States through a tariff-rate quota arrangement.
Right at the start of his second term in office, relying on emergency legislation, Donald Trump imposed additional tariffs on imports, including, on 10 February 2025, tariffs on imports of steel and aluminium products and derivative steel and aluminium products, at rates of 25% or 10%, effective from 12 March 2025 (Proclamation No. 10896 of 10 February 2025, “Adjusting Imports of Steel into the United States,” and its accompanying annexes; Proclamation No. 10895 of 10 February 2025, “Adjusting Imports of Aluminum into the United States,” and its accompanying annexes; Notice by the Bureau of Industry and Security of 4 April 2025: “Implementation of Duties on Aluminum Derivatives Beer and Empty Aluminum Cans Pursuant to Proclamation 10895 Adjusting Imports of Aluminum Into the United States”).
On 26 March 2025, the United States then introduced new safeguard measures in the form of additional tariffs of 25%, of indefinite duration, on imports of motor vehicles and motor vehicle parts originating, among other places, in the Union, effective from 3 April 2025 for motor vehicles, and from the date specified in the Federal Register, but no later than 3 May 2025, for motor vehicle parts (Proclamation No. 10908 of 26 March 2025, “Adjusting Imports of Automobiles and Automobile Parts into the United States”).
On 31 March 2025, the Commission adopted Commission Implementing Regulation (EU) 2025/664, suspending the additional ad valorem tariffs until 14 April 2025 (Implementing Regulations (EU) 2018/886 and (EU) 2020/502). Here, the EU Commission once again extended the suspension of its two earlier responses from the initial tariff dispute with the United States, in order to wait cautiously for further action that had already been vaguely announced.
On 2 April 2025, the United States introduced tiered additional tariffs applying to the whole world, effective from 9 April 2025 and of unlimited duration. Dr Möllenhoff reported on this under the heading “Disunited States of America” For the EU, this resulted in a rate of 20% on imports of all goods originating in the Union (Presidential Executive Order 14257 of 2 April 2025, “Regulating Imports With a Reciprocal Tariff To Rectify Trade Practices That Contribute to Large and Persistent Annual United States Goods Trade Deficits”).
On 9 April 2025, the United States reduced, effective from 10 April 2025 and for a period of 90 days, the additional tariffs on imports of goods originating in the European Union from 20% to 10%.
On 14 April 2025, the Commission adopted Commission Implementing Regulation (EU) 2025/778 on trade policy measures to rebalance trade in respect of certain goods originating in the United States of America, and amending Implementing Regulation (EU) 2018/886, providing for the application of additional tariffs on imports into the Union of certain other goods originating in the United States, and for the amendment of certain additional tariffs introduced by Implementing Regulation (EU) 2018/886, including a reduction to a maximum of 25%.
On the very same day, however, the EU also adopted Implementing Regulation (EU) 2025/786, initially suspending the introduction of the additional tariffs until 14 July 2025.
Through this wait-and-see response, the EU has secured itself some room for manoeuvre. It need only act again once it becomes clear what will follow the U.S. suspension. At the same time, it stands ready, through the regulations already adopted but merely suspended, to respond immediately with counter-tariffs. It has not drawn the same level of anger as China has, but it nonetheless demonstrates strength: the additional tariffs have already been adopted and can enter into force at very short notice.
