Make UK is monitoring the latest developments on additional US tariffs in relation to Greenland. We'll provide an update once there is more clarity around the situation. You can read our latest statement on the matter here.

Latest Update - 05.01.2026

The latest announcements on trade and tariff treatment measures and rules as they directly affect UK trade interests are set out below.

This remains a developing global situation, and we are in close contact with the UK government to assist with relevant analysis and responses.

In summary

US

Canada

List of steel derivative products subject to 25 per cent tariffs effective December 26, 2025 | CSCB National Office

China

EU

  • Cyprus Presidency publishes priorities: trade priorities for the six-month Presidency of the EU Council of the EU include signing and ratification of EU-MERCOSUR and other finalised trade agreements, progress on ongoing negotiations, progress on UCC Customs Reform and the WTO’s MC14 on March 20.
     
  • Steel trade remedies: EU Council has adopted a mandate to seek new regulation that will protect the EU steel market from global overcapacity. The new regulation is designed to replace the existing steel safeguard measure, which is due to expire on 30 June 2026. https://www.consilium.europa.eu/en/press/press-releases/2025/12/12/steel-overcapacity-council-adopts-mandate-on-new-rules-to-protect-eu-steel-industry-from-global-overcapacity/?utm_source=brevo&utm_campaign=AUTOMATED%20-%20Alert%20-%20Newsletter&utm_medium=email&utm_id=3318
     
  • Customs Reform: EU Council has agreed to apply a fixed customs duty of €3 on small parcels valued at less than €150 entering the EU, largely via e-commerce, from 1 July 2026. The measure will stay in place until the permanent arrangement for such parcels, agreed in November 2025, enters into force. The rate will be applied to all goods entering the EU for which non-EU sellers are registered in the EU’s import one-stop shop (IOSS) for value-added tax purposes.
     
  • EU-US: discussions continue focused on the transatlantic trade relationship after concluding the EU-US Joint Statement on trade of 21 August 2025 and shared global challenges linked for instance on global overcapacities, supply chain resilience, and economic security. Mandates for the EU to conclude talks with the US on (a) the adjustment of customs duties and granting tariff rate quotas for US industrial products and certain seafood and agricultural products and, (b) extending the duty suspension for imports of lobster and processed lobster are being finalised. EU proposals to the US seeking tariff exemptions for key products like wine and pasta and a reduction in the 50 percent Section 232 tariff on steel and aluminium, remain unlikely to be resolved soon.
     
  • Definitive safeguard measures on certain ferroalloy: new measures imposed consist of country-specific tariff rate quotas (TRQs) per type of ferroalloy, limiting the volume of imports to enter the EU duty-free. Imports exceeding these quota volumes may enter duty-free if their price exceeds the established threshold.

Current US tariff treatment measures to be alert to

  • Reciprocal tariffs entry-into-force: Entry into force on 6 August 2025. There is an exception for products in transit prior to that date. In addition, products stored in US-based customs warehouses had a deadline of 5 October 2025 to be withdrawn for consumption.
     
  • Non-listed countries: Where a country has not been specifically listed, they have been set 10% baseline tariff for exports to the US.
     
  • Transhipment: For products determined to have been transhipped to evade “applicable duties”, an additional 40% tariff will be applied as well as imposing any other “appropriate fine or penalty”.
     
  • S232 Copper: effective from 1 August 2025. Tariff lines of derivative and semi-finished products has been published. CSMS # 65794272 - GUIDANCE: Section 232 Import Duties on Copper and Copper Derivative Products
     
  • S232 Steel & Aluminium derivative products. Announcement on 407 steel and aluminium derivative products effective from 18 August 2025. Of the new additions, 124 codes are flagged as both aluminium and steel derivatives. Importers must now declare which material is present, even if the product contains only one. This will increase complexity in supplier data collection and customs documentation. Further announcements expected in 2026.  Section 232 Tariffs on Steel and Aluminium Frequently Asked Questions | U.S. Customs and Border Protection
     
  • De minimis: applied to all goods shipped outside the global postal network to US from 29 August 2025. For imported goods sent through means other than the international postal network that are valued at or under $800 and that would otherwise qualify for the de minimis exemption will be subject to all applicable duties. For goods shipped through the international postal system, packages will undergo one of the following methodologies: Ad valorem duty or Specific duty. Factsheet Suspension of Duty-Free De Minimis Treatment | U.S. Customs and Border Protection
     
  • Future measures: US Administration can amend the reciprocal duty rates once the trade deals with those countries listed have been concluded.

External Links

US

US Federal Register: The Federal Register (FR or sometimes Fed. Reg.) is the official journal of the federal government of the United States that contains government agency rules, proposed rules, and public notices. It is published every weekday, except on federal holidays. The final rules promulgated by a federal agency and published in the Federal Register are ultimately reorganized by topic or subject matter and codified in the Code of Federal Regulations (CFR), which is updated quarterly.

Federal Register :: Current Federal Register Document Issue

Federal Register :: Document Search

US Customs and Border Protection: CBP takes a comprehensive approach to border management and control, combining customs, immigration, border security, and agricultural protection into one coordinated and supportive activity.

New Tariff Requirements for 2025

Trade Remedies | U.S. Customs and Border Protection

Cargo Systems Messaging Service | U.S. Customs and Border Protection

Harmonized Tariff Schedule: The Harmonized Tariff Schedule of the United States (HTS) sets out the tariff rates and statistical categories for all merchandise imported into the United States. The HTS is based on the international Harmonized System, which is the global system of nomenclature applied to most world trade in goods.

Harmonized Tariff Schedule

White House

News – The White House

Fact Sheets – The White House

UK

GOV.UK: US tariff changes updated. Check new taxes on imports to the US using the Check duties and customs procedures for exporting goods service on GOV.UK.

https://www.business.gov.uk/export-from-uk/markets/united-states/us-trade-tariffs

https://www.gov.uk/world/organisations/department-for-business-and-trade-in-the-usa?lang=en-gb

Canada

The Canada Border Services Agency (CBSA): CBSA oversees customs regulations and border security, ensuring safe and efficient travel into Canada.

Trade facilitation, compliance and incentives

Customs Tariff 2026

News | Prime Minister of Canada

UK-US Economic Prosperity Deal

In May 2025, the Economic Prosperity Deal agreed between the UK and the U.S. sets out high-level trade commitments and opportunities for further negotiation. A series of implementing measures is described in Executive Order 14309 dated 16 June 2025 “Implementing the General Terms of the United States of America-United Kingdom Economic Prosperity Deal”.

Currently, elements of the deal have been agreed and ratified. There has been no change to the baseline ten per cent tariff for UK origin goods entering the US market, except for aerospace and the future prospect for pharmaceutical and related products.

The 10 percent tariffs have been reduced to zero for aerospace goods which fall under the WTO Agreement on Trade in Civil Aircraft such as engines and aircraft parts.

UK Automotive manufacturers currently have an annualised tariff relief quota, allowing the sector to sell up to 100,000 vehicles to the US at a 10 percent tariff rate, including MFN duty. This could be reviewed during 2026.

Progress towards zero percent tariffs for core steel products continue to be discussed, but there is no further information on this part of an Aluminium and Steel deal at this stage.

All measures will be kept under review by the US administration.

External References

US

Federal Register :: Implementing the General Terms of the United States of America-United Kingdom Economic Prosperity Deal

Federal Register :: Imports of Automobiles, Automobile Parts, Civil Aircraft and Civil Aircraft Parts From the United Kingdom Under Executive Order 14309

Fact Sheets – The White House

UK

UK-US Economic Prosperity Deal (EPD) - GOV.UK

US_UK_EPD_050825_FINAL_rev_v2.pdf

UK-US trade deal kicks into gear: immediate tariff cuts for UK auto and aerospace sectors - GOV.UK

US Economic Prosperity Deal

UK-US economic deal

Check new tariffs on imports to the U.S. using the ‘Check Duties and Customs’ procedures for exporting goods service on GOV.UK.

Check duties and customs procedures for exporting goods - GOV.UK

How to use Harmonised System (HS) or commodity codes | business.gov - business.gov.uk

We encourage all our members to refer to the information provided which will be frequently updated. We ask that firms remain in close contact with suppliers, customers and intermediary advice services such as customs agents, brokers, and other logistics providers, for details pertinent to individual export and trade activity with the US and other export markets.

Steel and Aluminium, including derivative products

The EPD has commitments to confirm a tariff treatment and quota arrangements for UK exports of aluminium and steel, as well as derivative steel and aluminium products. Referred to in the above Timeline, US and UK agreed in the EPD that the US, “shall design and establish a tariff-rate quota for steel articles and derivative steel articles that are products of the UK, consistent with the General Terms and the purpose of this order.”

The Executive Order (EO) in summer 2025 imposed an additional 25% duty on steel and aluminium imports into the U.S. (bringing the overall rate to 50%). The UK was exempted from the 50% tariff treatment as EPD talks continued. In addition, the EO stated that from 9 July 2025 onward, the U.S. may increase the tariff treatment rate on UK exports of steel and aluminium if the UK has not complied with relevant US guarantees and other assurances required in the EPD.

The talks on steel & aluminium between the UK & US continue, without agreement.

In August 2025, the announcement of tariff treatment on steel and aluminium products (as at Aug 25 - covering 407 steel and aluminium derivative products) included UK exports at the reduced rate of 25%. This has and will increase complexity in supplier data collection and customs documentation.

Of the new additions, 124 codes are flagged as both aluminium and steel derivatives. Importers must now declare which material is present, even if the product contains only one. This will increase complexity in supplier data collection and customs documentation. The tariff applies only to the steel or aluminium portion of the item’s value. The rest of the item (plastic, electronics, other metals, etc.) is still subject to normal MFN, reciprocal, or other applicable duties.

Key products:

Consumer packaged goods: products with aluminium packaging - everything from blister packs, condensed milk, shampoo, deodorants, and disinfectants in aluminium containers is covered

Household and industrial products: Tools, knives, blades, cutlery, furniture: seats, office furniture, metal shelving, air conditioners, filters, pumps, gear boxes

Heavy industry and transport products include: Bulldozers, cranes, industrial robots, rail cars, rolling stock, locomotives, semi-trucks, and buses

Chemicals & coatings products: cleaning products, soaps, surface-active agents, lubricants, paints, varnishes, mastics, caulking compounds, adhesives and glues, disinfectants, and sanitizers

Energy & infrastructure products: nuclear reactor parts, wind turbine towers, blades, and hubs, transformers, generators, extension cords

Pharmaceuticals

The UK-US Economic Prosperity Deal has significantly impacted the pharmaceutical industry by securing a zero percent tariff on pharmaceuticals to the US, making the UK the only country with such a concession. This deal is part of the UK-US Economic Prosperity Deal and aims to safeguard the UK's medicines access, drive investment, and support the UK's ambition to become Europe's leading life sciences economy by 2030.

Details here:

Landmark UK-US pharmaceuticals deal to safeguard medicines access and drive vital investment for UK patients and businesses - GOV.UK

U.S. Government Announces Agreement in Principle with the United Kingdom on Pharmaceutical Pricing | U.S. Department of Commerce

Northern Ireland

Confirmation that the US and European Union (EU) have concluded with a trade and tariff framework that exports from the EU that were at a temporary 10%, will be increased to 15% (with an MFN rate below 15%) or will stay above 15% (if the MFN rate is above this figure) starting from 1 August 2025.

This trade and tariff framework replaces the previously proposed potential 30% tariff by the US that was set to take effect on 1 August 2025.

The 15% tariff applies broadly across EU goods imported into the US. Tariffs on steel imports will remain at 50% until a new separate deal is agreed.

Which US products in your supply chain might face new tariffs?

The potential for the EU to apply retaliatory tariff measures from August had the US-EU trade and tariff framework not been agreed, has now resided. However, businesses should consider the US products that will be impacted and prepare for the potential new customs duties on imports to the EU should the position change. Under the Windsor Framework, imported goods subject to EU trade defence measures will be automatically “At Risk” and any EU tariffs will be payable on import to Northern Ireland.

The situation remains fluid, so it is advisable to regularly review official US government trade announcements and EU Commission updates for the latest details or specific product impacts.

How can the Customs Duty Waiver Scheme help your business?

  • You may be able to claim a waiver for goods brought into Northern Ireland so that you do not have to pay duty on those goods.
  • NI companies may be able to offset the cost of any additional tariffs using the Customs Duty Waiver Scheme.

General Questions to consider

The application of trade tariffs to export to the US will cause complexity on global trade and uncertainty on how long they will last and their longer-term impact on the UK economy, international economies and for trade dynamics.

UK businesses need to assess the implications and think through new commercial, trading, and financial strategies in what remains a highly fluid situation.

Impact on UK exports

Tariffs on US imports will lead to higher US prices being paid by importers and therefore increased prices for US consumers. This could have an immediate impact on the timely processing of goods through the US border affecting receipt with importers and customers. It could impact on the demand for UK exported goods.

Supply chain challenges

Increased costs on UK goods/components could also be seen as other countries' exports to the US that include UK content, will be affected by the tariff measures and the cost push through around the wider international supply chains. UK businesses relying on materials from China, India, Brazil, Mexico, and Canada, as well as those other countries with higher rates imposed could see cost increases, affecting manufacturing and demand for US goods.

Financial liquidity could have an impact on supply chain stakeholders, if an economic slow-down impacts on banking trends and appetite for risk. UK businesses should maintain as maximal view of their supply chains as possible to reduce the risk of disruption, in the event of decreased appetite for lending.

Currency & investment

International sentiment and unpredictability in currency and money markets particularly towards the US dollar, will affect the pound and other global currencies, impacting import costs and export competitiveness. UK firms with US operations should keep close observance on the impacts this could bring on heightened revenue and investment uncertainties.

Immediate questions and steps for UK businesses

The US tariff landscape demands immediate measures to be considered and some quick hints.

Keep informed

Monitor US, UK, EU, and other key nations (i.e. China, Canada, Mexico) trade policy changes and announcements. The position will remain fluid over the next few weeks as countries and economic blocs respond to the US tariff announcement.

Consider and respond to impact on your supply chains. Trade data will be a useful resource to help understand potential tariff impacts on specific products and materials.

Review and adapt your supply chain

  • Assess supply chain vulnerabilities to the tariff increases. Undertake an initial impact analysis and start to model cost and demand drivers.
     
  • Consider supply chain diversification by sourcing with countries that have more favourable tariff treatment.
     
  • Increase companywide supply chain visibility to identify known or potential disruptions. A key focus on your main producers or manufacturers and assessment of the impact on them.

Renegotiate contracts

  • Review commercial and trade contracts with suppliers and incorporate clauses addressing tariff fluctuations.
     
  • Consider force majeure clauses for significant tariff changes, allowing for renegotiation or termination.
     
  • Explore shifting tariff responsibility to suppliers through modified terms of sale.
     
  • Explore tariff mitigation strategies.

Tariff analysis

  • Analyse product classifications and explore modifications to potentially qualify for lower tariff rates.
     
  • Free trade agreements (FTAs): despite the changes to US tariff policy, options to see/use benefits from reduced or zero-rated tariffs. FTA rules of origin compliance essential.
     
  • Foreign trade zones (FTZs): Consider utilizing FTZs for potential duty deferral, reduction, and increased supply chain efficiency.

Optimise customs valuation and compliance

  • Accurately classify your goods for US import: review customs valuation methods to ensure accurate declarations and exclude non-dutiable costs.
     
  • Goods origin calculations: consider revising goods origin calculations and valuation procedures to the US, to ensure compliance and minimise ‘over statement’ of tariff amounts.
     
  • Trade compliance: engage trade compliance experts to navigate complex regulations and ensure accurate documentation.

For questions or other policy matters on Tariffs, please email [email protected]