CBP Releases Guidance on the U.S.–EU Tariff Framework

The U.S.–EU tariff framework introduces new HTSUS provisions and exemptions that directly affect duty rates on autos, parts, and certain other EU imports.

The U.S. Customs and Border Protection (CBP) has issued guidance on new tariff measures affecting autos, parts, and related goods under the U.S.–EU tariff framework.

Under this framework, CBP has modified duty treatments, effective for entries on or after August 1 for autos/parts and September 1 for exemptions.

CBP has also introduced updated provisions in the Harmonized Tariff Schedule of the U.S. (HTSUS) to reflect these changes and outlined procedures for importers to make corrections or seek refunds where applicable.

Terms of the U.S.–EU tariff framework

On August 21, 2025, the United States and the European Union issued a joint statement announcing a Framework on an Agreement on Reciprocal, Fair, and Balanced Trade (Framework Agreement).

The framework outlines reciprocal tariff terms for U.S.–EU trade. It specifies which imports remain subject to Section 232 duties and which categories are exempt from them.

The terms of the agreement include the following:

EU commitments

• Eliminate tariffs on all U.S. industrial goods.
• Provide preferential market access for certain U.S. agricultural and seafood products and extend the 2020 lobster arrangement.
• Increase procurement of U.S. energy, technology (AI chips), and defense equipment.
• Address U.S. concerns on the EU Deforestation Regulation, CBAM, and corporate due diligence and reporting rules. 

U.S. commitments

• Apply, on EU-origin goods, the higher of the MFN rate or 15% (MFN + reciprocal tariff).
• Effective September 1, 2025, apply only MFN to specified categories, such as unavailable natural resources (including cork), civil aircraft and parts, and generic pharmaceuticals and their ingredients/precursors. 
• For EU autos and auto parts subject to Section 232: no extra 232 if the MFN rate is ≥ 15%; otherwise, a combined 15% rate (MFN + 232).
• Cap Section 232 tariffs on pharmaceuticals, semiconductors, and lumber at 15%. 

Joint commitments

• The U.S. and the EU will negotiate rules of origin that ensure the benefits of the Agreement on Reciprocal Trade mainly go to both parties.
• Both sides will cooperate to reduce non-tariff barriers, align standards, and facilitate conformity assessments.
• Both sides intend to cooperate in areas such as energy, technology, supply chains, investment, and addressing non-market practices.
• Both sides will strengthen cooperation in cybersecurity, digital trade, and critical minerals.
• Both sides will collaborate on sustainability, intellectual property protection, and labour rights, including the elimination of forced labour in supply chains.

HTSUS codes for affected goods

A Federal Register notice was published on September 25, 2025, to introduce new tariff subheadings that importers must use when entering covered products from the European Union: 

Automobiles

• 9903.94.50: EU autos with Column 1 duty ≥ 15% (no additional Section 232 duty)
• 9903.94.51: EU autos with Column 1 duty < 15% (combined duty rate = 15%)

Automobile parts

• 9903.94.52: EU parts with Column 1 duty ≥ 15% (no additional Section 232 duty)
• 9903.94.53: EU parts with Column 1 duty < 15% (combined duty rate = 15%) 

Exemptions

• 9903.02.76: Civil aircraft and parts
• 9903.02.74: Unavailable natural resources (including cork)
• 9903.02.75: Essential oils (HTS 3301.29.51) for religious purposes
• 9903.02.77: Non-patented products for pharmaceutical use

How to correct entries and claim refunds

Importers may need to file post-summary corrections or protests to secure refunds where duties were overpaid under the old provisions. 

• For products covered under HTSUS headings 9903.94.50 through 9903.94.53 (autos and parts, effective August 1, 2025) and 9903.02.74 through 9903.02.77 (exemptions, effective September 1, 2025), filers should take action to correct entries promptly to reflect the modified duty treatment.
  
  
• For entries filed within the last 10 days, correct them within 10 days of cargo release from CBP custody and before estimated duties are deposited to avoid refund requests.
  
  
• For unliquidated entries with duties already paid, file a post-summary correction (PSC) to request a refund. Approved PSCs will be refunded at liquidation.
  
  
• For liquidated entries, file a protest within 180 days of liquidation under 19 U.S.C. 1514 to claim a refund.

Next steps for U.S. importers

If you import autos, parts, and related goods from the EU, we recommend the following next steps:

• Review classifications to confirm that affected products are reclassified under the new HTSUS subheadings
• Determine whether your imports fall under the combined 15% duty rate or the exempt categories
• Use post-summary corrections or protests to recover overpaid duties where applicable
• Work with a customs broker to validate classifications, manage entry corrections, and ensure you are claiming the correct duty treatment under the U.S.–EU tariff framework

How Cole International can help

At Cole International, we constantly monitor changing trade regulations and offer customs and compliance consulting services to help businesses navigate these changes.

Additionally, we provide timely and efficient customs brokerage services to help U.S. importers streamline their customs clearance processes.

Please reach out to one of our trade professionals to confirm whether your EU imports are subject to the 15% duty rate, the standard MFN rate, or are exempt.