BDO Trade Update - 10th April 2025

US Exports

• Universal Tariffs

Tariffs of 10% were introduced on a significant number of EU exports to the US on the 5^th April. This was due to increase to 20% on the 9^th April but has been suspended for 90 days for countries which have not retaliated. 

A list of products are exempted either fully or at present but for example with regard to Pharmaceuticals and Semiconductors we do not expect this exemption to last.

The current product list which are exempted are outlined on the link here. At a high level these include copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, and energy and energy products.

• Sectoral Tariffs

There are a number of sectoral tariffs in place which are separate to the above list for example in relation to steel and aluminium and automotives. Of most relevance to Irish Exporters will be the impending tariffs that might be applied on Pharmaceuticals and Semi-conductors.

President Trump announced on the 8^th April that the Pharmaceutical Tariffs are due shortly which will be a particular concern.

What should Irish Exporters do? 

Some critical points which have emerged are: 

1. Review your customs valuation and Transfer Pricing position and look at possibilities of unbundling certain payments from the Import Value.
2. Review options for reducing the price on import through use of First Sale.
3. Review your US Content in your exports.  It may be possible to exempt from the tariff the value of US content included in the value for customs purposes if this represents at least 20% of the content
4. Check your contracts to establish the responsibility for the duties payable. 

European Union Reaction 

The EU have consistently confirmed they would prefer to negotiate rather than retaliate however, notwithstanding this, there would alternatively be a firm and proportionate response.  In this context the first set of retaliatory measure were approved on 9^th April and were due to come into effect on 15^th April.

These tariffs cover aluminium and steel items along with many items for retail and consumer sale such as, we understand, jeans, cosmetics, textiles, soybeans, sweet corn etc.

With the suspension of the 20% US Tariffs on non-retaliating countries for 90 days this is now also paused for 90 days and as a result EU counter tariffs will not proceed on 15th April.

While the second group of products may be replaceable by EU suppliers, the aluminium and steel imports may be more difficult. The second broader list is still being finalised and is due to come into effect from 15^th May.

What are the Next Steps for Importers? 

Please download our Trade guide below which outline the steps for you to take as an Importer.  Of critical importance at this stage we advise: 

1. Check your tariff classifications of your imports – are these on the EU targeted lists part 1 or part 2?
2. If you import for manufacture and re-export can you avail of reliefs such as Inward Processing?
3. Check the origin of your imports – are they actually of US origin or transhipped though the US or only minimally finished in the US and thus not qualifying as US originating
4. Check your contracts – who is liable for the import duties

BDO Trade Guide - Key Steps 

We recommend all Importers and Exporters affected by these measures complete a full supply chain analysis to determine risks and identify any opportunities. Assess and determine:

1. The impact on your sales
2. The potential to mitigate costs through efficient tax and customs planning