• 12 March – 25% import duties on UK and global steel, aluminium and derivative products entering the US. Applies to wide range of products from furniture, construction, tableware, nuts, screws.
• 2 April – reciprocal tariffs announced (see next section)​
• 3 April – 25% additional import duties on UK and global automotive vehicles entering the US. This is on top of previous duties of 2.5%, making duty payable at the rate of 27.5%. ​
• 5 April – 10% additional import duties on affected products took effect (global baseline rate)​
• 9 April – US reciprocal tariffs on 50 countries above 10% global baseline came into effect, but were suspended on the same day for 90 days for non-retaliating countries. For China, the increase in duty was raised to 145%. EU Ministers voted on first sets of retaliatory tariffs on steel and aluminium
• 11 April – China 125% retaliatory tariffs on all US goods imports came into effect.
• ​11 April – US exempts smartphones, flatscreen TVs, solar cells, flash drives, memory cards, solid state data drives from scope of reciprocal tariff (10% Global baseline tariff rise, and 145% additional duties on China goods).
• 15 April – First set of EU retaliatory tariffs was due to take effect but were suspended until 14 July, and then to 1 August.
• 17 April – Decision from US Trade Representative Office on shipping landing charges – stepped back from new charges of $1.5m per landing for shipping lines at US ports which have China made boats in their fleets or on order. New plans exempt non-China made boats. Impact on logistics.​
• 3 May – 25% duties were due to apply to automotive parts imported for use in US-made vehicles (estimated $460bn of cars and car parts covered by new duties) – engines, lithium batteries, tyres, shock absorbers, computers. US Customs and Border Protection now had 30 days to implement new scheme with exemptions focused on US manufacturers up to a certain percentage of the value of the vehicle.​
• 8 May – UK-US deal reached on partial tariff reduction, removing tariffs from steel and aluminium products, reducing automotive tariffs to 10% for a quota of 100,000 cars per year, creating reciprocal tariff free quotas for 13,000 tonnes of beef exports in both markets. Other tariffs remain in place as before.​
• 4 June – Duty rates on steel, aluminium and derivative products increased to 50% for all countries apart from the UK, where duties remain at 25%, pending phased implementation of the deal with the US.
• ​16 June – President Trump issues Executive Order implementing parts of UK deal on zero tariffs for UK imported jet engines and other aerospace parts, and lower 10% tariff rate on automotive vehicles and associated parts imports. Duty changes taking effect before end of June.
• 30 June – Duty reductions on UK automotive vehicles (within quota), automotive parts and aerospace engines and components imports to the US took effect.
• 8 July – 90 day suspension period for non-retaliating countries of reciprocal tariffs above global baseline rate of 10% ended. Letters to range of countries informing them of higher tariffs to apply from 1 August sent out.​
• 9 July – Deadline for assessment by US Administration on implementation of quotas on steel and aluminium products from the UK passes – tariff rates remain at 25% pending further negotiation on the quotas.
• 27 July – US reaches deal with EU for 15% tariffs across most sectors inclusive of previous duties. 50% tariffs remain for steel, aluminium, copper imports from EU into the US. Other deals reached with Japan and South Korea for 15% tariffs – potentially stacked upon previous duties from January 2025.
• 1 August – Tariffs on copper and derivative products imported into the US rise to 50% – both on semi-finished copper products and intensive derivative products, including copper wiring and pipes. UK-US co-operation and further talks on supply chains, but no UK exemption on the increased duties for now. For goods not-within scope of its trilateral trade agreement with the US and Mexico, tariffs on Canadian goods raised to 35%.
• 7 August – Implementation day for new reciprocal tariff rates for those countries identified by US President as being subject to higher rates. This includes Brazil 50%, Switzerland 39%, South Africa 30%, India 25%, Bangladesh 20%, Malaysia 19%, Indonesia 19%, Israel 15%,Turkiye 15% and Vietnam 20%.
• Goods which are trans-shipped to avoid duties otherwise applicable will be subject to additional tariffs of 40%.
• 30% duties on goods from Mexico not within scope of the trilateral trade agreement with the US and Canada were paused for 90 days.
• Products stored in customs warehouses in the US must be released by 5 October in order to enter US market for consumption.
• 19 August – 407 steel and aluminium products added to tariff list under section 232 tariffs, includes many more industrial products with steel such as wind turbines, mobile cranes, furniture, frames for construction. UK origin products on the list subject to 25% duties, 50% for rest of the world from that date.​
• 29 August – removal of de minimis threshold took effect meaning all goods valued under $800 will be subject to US customs duties. For goods from the UK, for the first 6 months either 10% duty rates on value of the item must be paid or a specific rate of $80 per item arriving in the US. After 6 months, the specific rate option will be abolished.
• ​Still to come – announcements on pharmaceutical and semiconductor product tariffs.

• 10% global baseline tariff on all imports applied from 5 April.​
• Beyond the baseline, differential tariffs country by country represent biggest shift in global goods trade since 1947. Tension with WTO most favoured nation principle.
  
• Pharmaceuticals, semiconductors, lumber, copper, energy, critical minerals, steel, aluminium excluded. From 11 April smartphones, computers and devices, flatscreen TVs, solar cells, memory drives, solid state storage drives exempt from the new tariffs.​
• May be further sectoral tariffs announced eventually on pharmaceutical, semiconductors and critical minerals.​
• Duties not stacked – so no supplement on steel/aluminium/automotive tariffs.​
• 9 April – further reciprocal duties applied if tariff assessment made beyond 10% for individual states, but were suspended for 90 days for non-retaliating countries. New rates announced in July to enter into force on 7 August in most cases.
• These duties are not cumulative with the sectoral tariffs announced, but are with previous most-favoured nation duties in the US tariff schedule (apart from with the European Union).
• China is the exception – faced additional duties since start of 2025 of 145% on 10 April, but then additional duties were temporarily reduced to 30% in May until mid-November while US-China negotiations continue.
• How the US Government did the assessment for each country – focus on trade balances in goods.​
• Reciprocal tariffs meant to examine line by line tariff, regulatory, fiscal issues in each trading market.​
• Final plan applied a formula focused on goods trade surpluses between the US and trading partners.​
• Examples of country assessments for tariffs applied from 9 April (suspended for 90 days for non-retaliating states) – ​
• Brazil 10% (raised to 50% in July statement), Vietnam 46%, Thailand 36%​​
• China 34% (increased to an additional 125% but suspended in May 2025), Taiwan 32%, South Africa 30%​
• Switzerland 31% (later increased to 39%), India 26% (later increased to 50%), South Korea 25%​
• Japan 24% (later increased to 25%), EU 20%
• UK 10% – global baseline
• De minimis threshold ($800) abolished on China and Hong Kong origin goods entering the US – took effect from 2 May. Suspension extended to rest of the world imports into the US from 29 August.
• UK goods face either 10% duties by packages arriving via international postal services, or a flat rate of $80 (whichever is the lower) from end August 2025. After the initial six month introductory period, the flat rate option will be removed, and duties will need to be paid on arrival at 10% of the value of the good.
• If countries reduce their trade imbalances or produce plans to achieve that, reciprocal tariffs can be adjusted downwards by the President.
• If countries adopt further retaliatory measures, their reciprocal tariffs can be adjusted upwards by the President – see potential changes in tariff rates to be applied to China imports.

On 5 April, 10% additional duties were added to duties on UK origin goods in the reciprocal tariffs sectors.Here are some worked examples (duties correct at 29 August):​

Goods sent by sea or air freight –

• Scotch whisky – MFN rate 0, reciprocal tariff rate 10%, total tariffs due 10%
• Copper wiring – sectoral tariffs apply at 50%, total tariffs due 50%
• Woollen jumper – MFN rate 12%, reciprocal tariff rate 10%, total tariffs due 22%
• Food processor – MFN rate 4.2%, reciprocal tariff rate 10%, total tariffs due 14.2%
• Steel forks – steel sectoral tariff rate applies at 25%, total tariffs due 25%
• Car part for UK vehicle to US – UK-US deal lowers rates to 10%, total tariffs due 10%
• Aircraft components – US-UK deal lowers rates to 0, total tariffs due 0%
• On 29 August, tariffs were introduced for low value consignments under $800 from countries across the world. 10% additional duties applied on UK origin goods or for the first six months a flat rate of $80 – whichever is the lower. Here are some worked examples (duties correct at 29 August):​
• Goods sent by international postal services –​
• Woollen jumper – Reciprocal tariff rate 10%, total tariffs due 10%​
• Food processor – Reciprocal tariff rate 10%, total tariffs due 10%
•  

• Goods that are wholly obtained in the UK — with all content and manufacturing processes carried out domestically —attract the 10% global baseline tariff increase (in effect since 5 April), provided the US classifies the UK as the country of origin under its non-preferential origin rules.​
• For mixed-origin goods, or goods comprising imported components assembled in the UK, U.S. Customs and Border Protection (CBP) will apply the non-preferential rules of origin to determine the correct country of origin and, in turn, the applicable tariff rate​
• To qualify a good as being of UK origin, the product must satisfy the substantial transformation test.​
• This test has been developed through CBP rulings and US court decisions, and determines whether the processing or assembly in the UK results in a new and different article of commerce — with a distinct name, character, or use — compared to the original imported materials or components.​
• Substantial transformation typically requires that the manufacturing process adds significant value and results in a fundamental change to the product’s form, function, or essential character. Simple packaging, dilution, or minor assembly operations do not qualify as substantial transformation.​
• Assembly can amount to substantial transformation, depending on the nature and complexity of the process. ​
• A key CBP decision from 2016 (HQ H287548) clarified this multi-factor approach, emphasizing that no single factor is determinative, but rather the totality of circumstances must support a finding of substantial transformation.
• CBP considers a range of factors when assessing substantial transformation, including:​
• Number of components assembled​
• Number and type of operations involved​
• Time required for assembly​
• Skill levels of workers​
• Level of detail and precision in assembly​
• Value added by assembly​
• Design and development resources expended​
• Extent of post-assembly inspection and testing​
• Nature of post-assembly testing​
• Origin and significance of components used​
• Employment generated by the process

• China – imposed 125% retaliatory duties on US goods imports. In excess of 50% of China exports to the US affected by the high tariff wall. Risk of diversion of goods into other markets with low MFN tariffs, eg. the UK. These duty rates were reduced to 10% until July 2025 following a temporary suspension agreement with the US.​
• EU – two stage response – vote on 9 April on steel and aluminium tariff response – was due to take effect on 15 April (now suspended until 14 July). EU scaled back scope of response from original €26bn in tariffs to around €21bn. 
• 25% duties on some products, 10-25% on orange juice, poultry, soyabeans. Bourbon, wine and dairy products not subject to retaliatory tariffs. ​
• EU – second tranche of measures being considered if no deal is reached: tariffs only, or using the EU Anti Coercion Instrument to target US tech companies, intellectual property, procurement and services market access?​
• UK – no increase in duties. HMG considered how tariffs might increase if required – call for input for businesses which BCC submitted to on 1 May.​
• Australia – no increase in duties for now.
• India – no increase in duties for now. ​
• Japan – no increase in duties for now. ​
• Canada – retaliatory package including 25% tariffs on US auto exports. ​
• US discussions underway with over 70 countries.​
• US response: consideration of measures like export tax credits (generally permissible under WTO rules)​
• Non-preferential rules of origin and relevant certification to prove origin will become key for trade with the US if goods have China-origin content.

• PM – calm, cool headed approach. No retaliatory action for now.​
• Achieved economic prosperity deal with the US to lower some tariffs and remove others.​
• Prepared for eventuality of future response with Call for Input on tariffs.​
• UK offer: lower tariffs on certain agri-food and ethanol imports, co-operation on technology, digital trade agreement.​
• Industrial policy: changes to Net Zero timeline for automotive companies and EV mandate. Changes to subsidies rules to authorize individual awards of up to £25m without mandatory investigations. BCC called for uprating of threshold.​
• Trade policy: increased resources at Trade Remedies Authority, using policy levers on anti-dumping duties to address unfair competition on prices where domestic industry faces injury; steel safeguard duties due to expire in June 2026 – BCC calling on these to be renewed.

• Under Windsor Framework, two effects –​
• First, if EU trade remedies, eg. anti-dumping duties diverge from those of the UK, EU duties will apply in NI. Means two different rates of trade remedies applicable within single UK customs territory. Despite the 90 day suspension in certain US duties from the EU, divergence over trade remedies could still affect NI businesses in the future.​
• Second, if EU tariffs (on US imports) are higher than UK tariffs, and the difference exceeds 3% on goods at risk of entering the EU Single Market, then NI importers will pay the EU tariffs. NI traders can seek to claim the additional duties back through the Duty Reimbursement Scheme (DRS).​
• NI businesses and some politicians say the DRS is not fit for purpose.​
• Consumer prices may rise in NI – which has the lowest disposable income of any part of the UK.

• 62% of UK firms with trade exposure to the USA say they will be negatively impacted by US tariffs, compared to 41% with no exposure
• 32% of firms with trade exposure to the USA say they will increase prices in response to the tariff​
• 44% of firms with exposure to the USA say the UK should seek to negotiate a closer trade relationship with the USA, and 43% want closer trade with other markets​
• Just under a quarter (21%) think the UK should impose retaliatory tariffs​
• ​45% of firms trading with the US think being outside the EU has given us a disadvantage, while 38% think it is an advantage 

• Negotiate not retaliate. Marathon not a sprint – and getting the best deal for the UK is what matters most. ​
• Some of our businesses are relieved they thought it would be much worse…Better news than feared – but still a bad situation.​
• Cars, steel and aluminium industries already facing much higher tariffs than at the start of 2025, but tariffs need to fall in other sectors too.​
• No winners in the current scenario. Lose-lose for everyone.

Impact is…. ​

1. orders falling​
2. prices rising​
3. global economic demand will be weaker as a result.  

Is the UK now heading for recession? ​

These tariffs will certainly increase the risk, and the wider the trade war spreads the harder it becomes to avoid. But it is by no means guaranteed. If the government takes a three-pronged approach around US/EU and Indo-Pacific trade, gets large-scale infrastructure projects moving, reforms business rates and cuts unnecessary red tape, there is still a way through. 

• Risks of trade diversion real – could mean some prices fall for consumers here, but UK market could face goods from SE Asia and China being re-directed here – the UK has a very low average trade weighted MFN tariff <3%.​

• If this is unfairly competing with UK firms that could be an issue, but the Trade Remedies Authority and DBT have a number of tools to manage this.

​

• But it needs intelligence from firms about what is happening so we would urge businesses to immediately report any concerns around cheap exports flooding their markets. 

• How are supply chains being already affected by steel/aluminium/automotive tariffs? How are they impacting upon sectors like aviation and aerospace?​
• Supply chain effects on tech goods (iPhones), clothing and textiles, industrial goods.​
• What do the 10% tariffs mean for traders in the affected sectors? ​
• How may future EU retaliatory measures or anti-dumping duties affect businesses in NI?​
• Goods from China and other markets with high tariff assessments in the US may look to find buyers in the UK – known as trade diversion. What risks are there for domestic industries?​
• How should the Trade Remedies Authority engage with business and undertake its vital tasks in this new era of tariffs?​
• How should Ministers seek to engage with us in this new trading environment?

• Known as the Economic Prosperity Deal (EPD)​
• Tariffs on UK exports of steel and aluminium products reduced from 25% to zero via operation of a quota. Scale of quota still to be determined. Will apply to “certain” derivative steel and aluminium products.​
• Tariff rate quota created for UK car exports to the US – 100,000 car units will have tariffs at 10% reduced from current 27.5%. Covers nearly all UK car exports to the US.​
• Tariffs cut on compliant beef products in both markets – UK/US exporters will have additional tariff rate quotas in the other market of 13,000 tonnes per annum at zero duty rates. Implemented in the UK from the end of June.
• Tariffs on ethanol – used in manufacture of beer – reduced to zero from end of June through a tariff rate quota of up to 1.4bn litres of ethanol from the US
  
• Other tariffs to remain at current levels, including reciprocal tariffs in other goods sectors which raised tariffs by 10% on 5 April.
• UK to receive preferential treatment should the US engage in further section 232 investigations on new tariffs in the future, consistent with national security interests.
• Specific commitment to negotiate preferential outcomes for the UK in terms of the outcomes of the current section 232 investigation into pharmaceutical product tariffs.​
• Economic security alignment means zero tariffs on UK jet engines and aerospace components imported into the US.​
• Commitment by UK and US governments to negotiate digital trade agreement including on customs facilitations – a key BCC priority first raised four years ago.
• No change in UK food standards or sanitary or phytosanitary rules.​
• UK/US technology partnership to be negotiated by both countries.​
• No commitments made to change UK Digital Services Tax.​
• On 3 June 2025, new Proclamation on steel and aluminium tariffs released by the US President – provides that US tariffs on UK steel and aluminium products will remain at 25%.
• UK-US negotiations on the quotas and the implementation of the EPD continuing.​

• Executive Order made by US President on 16 June 2025.​
• Provides for the introduction of the lower 10% rate for automotive exports from the UK to the US within the scope of the quota before the end of the month. Will apply to vehicles in heading 8703 of HTSUS and note 33 (b), subchapter 11, chapter 99 HTSUS. New lower 10% rate applied from 30 June.    
• Automotive exports from the UK to the US in excess of the quota will continue to face tariffs at the rate of 27.5%. ​
• Specifies the category of UK automotive parts also subject to the lower 10% US tariffs by the end of June. ​Confirmed subsequently as 30 June.
• Ensures that Rolls Royce jet engine imports and other aerospace components, within the WTO’s Agreement on Trade in Civil Aircraft, from the UK were tariff free in the US from 30 June. 
• Clarifies the conditions required to be met by the UK prior to the tariff rate quota on steel and aluminium and certain derivative products being introduced by the US.  
• Triggers implementation of zero tariffs on UK jet engines and aerospace parts exported to the US. ​
• Annual US quota of 100,000 vehicles subject to lower rate of 10% applied to the UK from 30 June, backdated to 8 May 2025. ​
• Definition of automotive parts covers all automotive parts of UK origin for use in UK origin automotive vehicles – all imported parts of passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles, minivans, and cargo vans) and light trucks as specified in note 33 (g), subchapter III, chapter 99 HTSUS. New lower 10% rate applied from 30 June.
  
• Further negotiations on implementation of provisions of EPD on steel and aluminium products in terms of drawing up quotas, and treatment of those derivative products in scope. 

• DBT has produced comms and explainers in coming day to help businesses​
• BCC summarising President’s Executive Orders and Proclamations and the guidance produced by US Customs and Border Protection on release.​
• Updating tariffs explainer/FAQ document and reissue to BCC members.

• Secured: changes to subsidies rules and thresholds, permitting awards on community development using fast-track process and raising threshold limit for awards without mandatory call-in to £25m.​
• Secured: greater recourse to anti-dumping and import surge measures to avoid risk of trade diversion where unfair competition affecting UK production would be involved.​
• Secured: British Business Bank’s Growth Guarantee Scheme providing increased lending capacity for companies facing economic distress and cashflow problems from the sudden imposition of new tariffs, with loans of up to £2m.​
• Secured: Government raises lending capacity of UK Export Finance from £60bn to £80bn to  cushion the impact upon SMEs, including £10bn earmarked capacity for US tariffs related impacts.​
• Secured: Additional resource and new inputs into the Trade Remedies Authority to ensure data on any unfair competition leading to surge in imports and dumping of goods on the UK market is quickly acted upon. ​
• Secured: Economic Prosperity Deal with the US to relieve impact of new tariffs in as many goods sectors as possible. Now needs to be implemented as soon as possible. Implementation on automotive and aerospace tariffs on 30 June.
• Negotiate closer trading terms with EU and partners in CPTPP and wider Indo-Pacific trade zone. ​
• Outline BCC priorities for ongoing US trade negotiations to the PM and Secretary of State for Business and Trade.​
• BCC will continue to advocate for tariff reductions in other goods sectors, including those affected by the US reciprocal tariffs from 5 April (at 10% additional duty rates per good).​
• BCC will also seek inclusion of all derivative steel and aluminium products in the US tariff rate quota to be negotiated on UK steel and aluminium on entry to the US.

The British Chambers of Commerce (BCC), through its customs and trade team, ChamberCustoms, is already supporting UK businesses in responding to the new US tariff regime.

We provide expert advice on US tariff changes, including commodity code checks and rules of origin guidance, helping businesses avoid unnecessary duties and navigate new compliance requirements.

Contact us directly at [email protected]