Latest Update. 21.04.2026
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.
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
New Updates
US
- Section 232 (Trade Expansion Act 1962) tariffs on steel, aluminium, and copper products: changes came into effect on 6 April 2026
- Requirements and processes under Proclamations 10895, 10896, and 10962 (issued in 2025) are now terminated.
- Replaced with a process based on ad valorem tariffs now applying to the full customs value of imported metal products, not just the metal content.
- US administration has now rolling authority to add derivative articles to the tariff scope should it be determined that imports threaten national security objectives.
- Announcement includes exemptions including Derivative Products that are no longer subject to Section 232 duties, other products are removed due to low metal content and specific arrangements for metal products from Trade Agreement Partners (incl. UK).
- This announcement does not affect other tariff and trade policy investigations or ongoing measures. These include: Trade Act 1974: Section 122 (universal tariff 10% plus MFN) & Section 301 probes into trading partners trading practices (includes UK); Trade Expansion Act 1962 Section 232 (e.g. wind turbines)
Key elements:
- US-UK Pharmaceutical Agreement
- 0% tariff.
- Support to meet US national security requirements: bi-lateral commitment to work together to support UK companies exporting to the US to meet US national security requirements.
- New US-UK Pharmaceutical Supply Chains Partnership: strengthen medicines supply chains and undertake resilience-building activities.
- Tariffs on medtech: UK-origin medical technology exports will not face any additional new tariffs for at least 3 years.
- Mutual recognition: The UK and US have agreed to work together towards mutual recognition of medical device approvals.
Key elements:
- IEEPA Tariff refunds
- IEEPA refund al opened 20 April 2026. The final guidance notes that unliquidated entries that are eligible for Phase I CAPE will liquidate within 45 days of CAPE file acceptance and refunds will be processed within 60-90 days after CAPE file acceptance except entries in “suspended,” “extended” or “under review” liquidation status, warehouse entries, and entries flagged by CBP for additional review. Liquidated entries will reliquidate one day after CAPE file submission and will be subject to the 60-90 day refund period, which includes a 45 day review period.
gov.uscourts.cit.17610.15.0.pdf
UK
- The UK Steel Strategy 2026 aims to revitalize domestic steel production, strengthen economic and national security, and introduce new trade measures including reduced import quotas and tariffs.
Key Issues
- From 1 July 2026, the UK will implement significant trade measures to protect domestic steel producers:
- Import quotas for steel will be reduced by 60% from current levels.
- Tariffs of 50% will apply to imports exceeding these quotas, limited to steel products that can be produced domestically.
- Transitional arrangements may exempt goods under contract before 14 March 2026, imported between 1 July and 30 September 2026
The UK steel strategy (web version) - GOV.UK
European Union
- European Council adopts mandate on new rules to protect EU steel industry from global overcapacity
Key Issues
- New measure is expected to enter into force by 1 July 2026. The current safeguard measure expires on 30 June 2026
- Tariff quotas for 28 product categories
- Out-of-quota duty at 50%
- Quarterly management of quotas
- The "melt and pour" principle: mandatory to identify the country in which the steel used in the production of the product was melted and poured
New measures to protect EU steel market from global overcapacity | News | European Parliament
Current
US
- US Supreme Court rules against Tariff measures introduced in Apr 2025 under the International Emergency Economic Powers Act:
- Tariffs under IEEPA ended from 00.01 (Eastern time) 24 Feb 2026.
- US Admin invoked Section 122 of the 1974 Trade Act—a legitimate trade policy tool under US law
- Tariff level is 10% plus MFN for all countries including UK applies up to 24 July 2026.
- Section 122 tariffs do not stack with existing Section 232 duties
- US Admin continues with ‘de minimis’ suspension including on postal shipments. Prior to Aug 2025, import shipments under $800 were customs, tariff, and admin exempt.
- US Admin (through US Trade & Representative Office) signalled new and expanded trade and market investigations. The potential for future tariff action in 2026.
Links
Continuing the Suspension of Duty-Free De Minimis Treatment for All Countries – The White House
Ending Certain Tariff Actions – The White House
Unstacking Certain Tariffs Chart | U.S. Customs and Border Protection
CSMS # 66684128 - GUIDANCE: Duty Offset for Imports of Automobile Parts
Canada
- New support for steel and lumber industries: New support measures for Canada’s steel and lumber industries. The new measures include tightened tariff rate quota levels for steel products from both FTA (which includes UK) and non-FTA partners; new tariffs on imported steel derivatives with effect 26 Dec 2025.
China
- China introduces an order of the State Council, setting out the "Regulations of the People's Republic of China on Prohibiting Foreign Unilateral Extraterritorial Jurisdiction" (hereinafter referred to as the "Regulations"), which came into effect the same day. The purported aim of the regulation is to “safeguard national sovereignty, security and development interests, protect the legitimate rights and interests of Chinese citizens and organizations, and maintain the international order based on international law.” The measure grants the Chinese government the authority to implement extraterritorial jurisdiction measures against actions impacting China.
EU
- 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.
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.
Tariff Overview | U.S. Customs and Border Protection
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.
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
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
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
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
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 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 as countries and economic blocs respond to ongoing US tariff announcements.
- 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]