On September 24, 2025, the U.S. Department of Commerce announced tariff exemptions for certain goods imported from the EU. The notice modified additional duty rates applicable to certain imported products of EU member countries.

On August 21, 2025, the United States and the EU announced an agreement that adjusted tariffs on certain EU products, including automobiles and auto parts, unavailable natural resources such as cork, civil aircraft, and generic pharmaceuticals and their ingredients and chemical precursors. For some of these goods, the revised tariff rate is zero, provided they are properly entered.

The CBP Cargo Messaging Service (CSMS) released guidance offering additional information on tariff exemptions on EU goods. Notably, it provided guidelines for importers to recover tariffs paid on eligible goods imported between August 1 or September 1 (the tariff exemption effective date) and September 24—a period during which the notice was intended to be effective but had not yet been implemented. If the entry has not liquidated, the importer must file a Post Summary Correction (PSC) to request a refund. For liquidated entries, importers may request a refund by filing a protest, 180 days after liquidation.

Tariff exemptions for automobiles and auto parts took effect on August 1. A new subheading 9903.94.50 now applies to passenger vehicles and light trucks with a most-favored nation (MFN) duty rate over 15%, with no reciprocal tariff applicable. Passenger vehicles and light trucks with an MFN rate under 15% are classified under a new subheading 9903.94.51. Importers must pay a flat 15% tariff under this subheading. The same tariff treatment applies to auto parts under new subheadings 9903.94.52 and 9903.94.53.

The notice also adds exemptions from reciprocal tariffs for more than 200 subheadings covering certain EU natural resources under new subheading 9903.02.74, effective September 1. Further, essential oils other than those of citrus fruit used for religious purposes only are classifiable under new subheading 9903.02.75.

EU civil aircraft and aircraft parts are also exempt from tariffs under new subheading 9903.02.76, beginning September 1. In addition, EU pharmaceutical products are exempt under new subheading 9903.02.77 on this date.

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Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.

Photo of Kristina Shcheglazova* Kristina Shcheglazova*

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control…

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control matters, including compliance with various sanctions and export control requirements, due diligence and sanctions screenings, and advises clients on the application of U.S. sanctions and export control licensing requirements. Her experience extends to addressing issues of forced labor in supply chains, assisting clients with government contracting matters and advising on anti-corruption policies.

*Licensed in MO only, not IL; limited to federal practice only.