Client Alert 19 May. 2025

European Commission Engages Stakeholders in Consultation on Strategic Trade Rebalancing Amid US Tariff Threats

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On May 8, 2025, the European Commission has commenced a public consultation to assess potential trade countermeasures targeting specific US imports and select EU exports in light of the heightened commercial frictions with the United States.

Prompted by US-imposed tariffs deemed inconsistent with WTO obligations, the consultation, which remains open until 10 June 2025, 12:00 (UTC+01:00), Brussels time, invites stakeholders to provide their insights regarding the economic implications of US tariffs and of proposed EU trade policy measures, encompassing additional import duties and export restrictions.

Background

On 2 April 2025, the US administration announced the introduction of so-called “reciprocal” tariffs, imposing an additional 20% duty on selected EU goods. This measure was implemented alongside the imposition of a 25% tariff on all imports of vehicles and car parts, further compounding the existing 25% tariffs on steel, aluminum, and derivative products initially proposed in February 2025.

In response, the EU signaled its intent to implement countermeasures should diplomatic efforts prove unsuccessful.

On 9 April 2025, the US announced a 90-day suspension of the EU-specific 20% tariff, maintaining a 10% rate during negotiations. The EU then postponed the implementation of a set of countermeasures prepared against US tariffs on steel and aluminum imports, thereby allowing space for further dialogue.

Despite these provisional measures, the economic repercussions of US tariffs remain substantial, impacting approximately €379 billion in EU exports, which represent 70% of total EU exports to the US. The tariffs have already resulted in heightened operational costs, disrupted supply chain, and increased economic uncertainty.

EU’s forthcoming actions will be determining in shaping its trade stance.

Thus, the Commission, acting pursuant to Article 9 of Regulation (EU) No 654/2014, is seeking to gather comprehensive information from stakeholders concerning the consequences of US trade measures impacting goods originating in or exported from the EU.

Simultaneously, the EU will initiate a WTO dispute against the US by formally lodging a request for consultations, reserving the right to request the establishment of a panel should negotiations fail to yield to a resolution.

EU Survey: assessing economic impact for strategic trade realignment

The Commission calls upon stakeholders to provide detailed assessments of the commercial impact of these US tariffs.

In particular, the consultation targets three critical areas: the universal tariffs, currently set at 10% ad valorem, with a prospective increase to 20%; the US Section 232 tariffs of 25% on cars and car parts from the EU; and the expanded Section 232 tariffs on certain aluminum derivatives as well as the operational challenges resulting from the US requirement to declare steel or aluminum content in exported goods

Additionally, feedback is sought on the economic effects of potential EU countermeasures, including proposed import duties on US products and export restrictions.

Concerning imports from the US, the focus extends to agricultural and food products, including meat, dairy, and prepared foods, as well as select raw materials and processed goods such as tobacco and coal valued at approximately €95 billion.

On the export side, potential restrictions may affect certain chemical substances and metal waste, particularly ferrous and aluminum scrap worth €4.4 billion.

The Commission will consider the information collected in determining the scope and nature of possible EU commercial policy measures in response to the US actions so as to prepare a formal proposal to finalize potential trade measures.

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