Last updated 10.04.25 (10:00)

The locational tariffs on goods entering the US market that came into effect at 00.01hrs (EDT) on 9 April 2025 (05.01hrs BST) have been suspended for 90 days.  

The imposition of a US baseline tariff of ten per cent that came into effect on 5 April 2025 remains in effect. UK origin goods are subject to the baseline tariff (ten per cent) but are not subject to further (suspended) locational tariff schedule.  

The (suspended) locational tariff schedule is separate to that applied to specific goods, under Section 232 (U.S. Trade Expansion Act, 1962) - automotive and automotive parts, steel, aluminium and derivative products.   

Goods subject to Section 232 tariffs are exempt from (suspended) locational tariffs (9 April 2025).  

We encourage all members, in addition to referencing and using the information provided, to please remain in close contact with your suppliers, customers and your intermediary advice services such as customs agents, brokers and other logistics providers, for details pertinent to your individual circumstances.   

The UK Secretary of State for Business and Trade made a statement to the House of Commons on 3 April 2025, outlining the Government’s intention to continue working for a deal with the United States that would see the avoidance of the locational and product tariffs recently announced. During this statement, the Secretary of State announced that a request for input from industry, to influence the design of any potential response actions from HM Government, will be open for four weeks, until 1 May 2025. This will allow HM Government to take the views of business on products and areas that should be considered for inclusion in any UK tariff response. This is now live, and you can find the link to take part here and under the list of further information below. 

Make UK welcomes the announcement that the Government will continue to work urgently to explore and negotiate a new mutually beneficial economic agreement with the US to reverse this highly damaging development.  

UK business will need support to help navigate through the complexity and uncertainty brought about the imposition of tariffs. Make UK are calling on the Government to convene a Tariffs Taskforce to bring together all major sector of British industry and all relevant Government departments to make sure they work effectively together to help business navigate its way through this tariffs crisis. 

The full statement by Make UK CEO Stephen Phipson, in response to the announcement of tariffs on UK goods into the US market, can be found here 

Further information can be found here 

Links to U.S. Government sources: 

Links to UK Government sources: 

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

Impacts of US Tariffs on the UK  

As of 5 April 2025, United Kingdom goods are subject to the US baseline tariff of ten per cent, this is in addition to the standing MFN tariff against specific product codes (link to US MFN tariff schedule below) implemented by the USA when entering the United States market; the European Union is subject to a twenty per cent locational tariff rate when sending goods to the United States market, this is in addition to the US MFN rate.  

According to the factsheet published by the US administration,    

“Some goods will not be subject to the Reciprocal Tariff. These include: (1) articles subject to 50 USC 1702(b); (2) steel/aluminum [sic] articles and autos/auto parts already subject to Section 232 tariffs; (3) copper, pharmaceuticals, semiconductors, and lumber articles; (4) all articles that may become subject to future Section 232 tariffs; (5) bullion; and (6) energy and other certain minerals that are not available in the United States.”    

The full factsheet can be found at this link   

As stated above. UK goods exported to the United States are subject to the new baseline US tariff of ten per cent plus the addition of any MFN tariff rate (a guide to rates applied can be found in the links above). 

Crucial will be the demonstration that the product is UK originated. This will be confirmed by Certification of Origin and can be achieved by origin calculations and ongoing due diligence. 

An example of non-qualification for the UK baseline tariff would be a product / component / material of non-UK origin that had simply been stored / warehoused in the UK prior to its export to the United States market. 

The origin condition implies two specific requirements, 

  • that the product wholly originates in the UK 
  • that the product acquires UK origin based on the substantive transformation rule 

The United States defines ‘substantial transformation’ as follows, 

“Substantial transformation means that the good underwent a fundamental change in form, appearance, nature, or character. This fundamental change normally occurs as a result of processing or manufacturing in the country claiming origin. Additionally, this change adds to the good’s value at an amount or percentage that is significant, compared to the value which the good (or its components or materials) had when exported from the country where it was first made or grown.” 

Steel and Aluminium Tariffs 

Prior to the now suspended locational tariff schedule coming into effect on 9 April 2025, the US Administration applied tariffs to steel and aluminium imported into the US market, including on derivative products. This product-based schedule came into effect on 12 March 2025. As such, a tariff of twenty-five per cent is now applied to these products entering the US market.

The 12 March product measures introduce three primary changes: the termination of country-specific arrangements such as full exemptions, quotas, or tariff-rate quota programs; the increase of tariffs on aluminium imports from ten per cent to twenty-five per cent; and the inclusion of numerous downstream or ​“derivative” products subject to the tariffs. In response, a number of retaliatory measures have been applied by countries and economic blocs directly who are now affected by these measures. 

Annex I (detailed below) of the Proclamations expand the Section 232 duties details the additional derivative products of steel and aluminium covered by the tariff measures.  The additional derivative products are identified by Harmonized Tariff Schedule of the United States (“HTSUS”) code in each annex.  

The tariffs applied will depend on the derivative product’s HTSUS classification.  For any derivative article of steel not classified in Chapter 73 of the HTSUS, the additional duty will apply only to the steel content of the derivative steel article.  Likewise, for any derivative article of aluminium not classifiable in HTSUS Chapter 76, the additional duty will apply only to the aluminium content of the derivative aluminium article. 

The effective date for any derivative steel or aluminium articles not classifiable in Chapters 73 or 76 will be the date upon which the Secretary of Commerce issues public notification that “adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles.”  All derivative articles classified in Chapters 73 or Chapter 76 will be effective on March 12, 2025. 

Guidance from U.S. Customs and Border Protection (“CBP”) instructs that importers must declare, separately from the value of the merchandise, the value of the steel and aluminium content for covered derivative products classified outside of HTSUS Chapters 73 or 76, respectively. Guidance for declaring the dutiable value of merchandise covered by the Section 232 derivative product tariffs to CBP can be found in the messages below. Notably, the Section 232 duties are applicable to the value of the steel or aluminium content and importers must also declare the weight of the steel or aluminium content. Further, melt and pour (steel) and smelt and cast (aluminium) reporting requirements expressly apply to derivative products, which are not subject to the Section 232 duties if produced from mill products melted/poured or smelt/cast in the United States. 

Further information on the measures affecting Steel, Aluminium and derivative products exported to the USA can be found on these links: 

 As stated above, the current UK Government position has been not to retaliate with countermeasures. For the moment, a pragmatic position has been taken, instead on focusing on strengthening trade and economic ties with the US. Intense diplomatic efforts continue to seek an ‘economic pact’ with the US, that would neutralise current and a future threat of tariffs. 

To understand and protect the UK economy from the potential of trade diversion to the UK as supply chains may adjust away from the US, the UK’s Trade Remedy Authority will work with the UK Government on measures to protect domestic production capability. 

Northern Ireland Tariffs

The EU has announced that it will consider applying retaliatory measures on US imports from April. The potential divergence between the UK and EU from April has impacts on Northern Ireland.  

Though Northern Ireland is part of the UK Customs Union, it is also part of the EU Single Market. In the circumstances of trade defence measures being actioned by the EU against a third country (i.e. US), Northern Ireland must follow the EU rules. Though a reimbursement scheme is available to firms if they can demonstrate that goods imported from the US into Northern Ireland are sold there, the tariff cost must be borne by the firm located in Northern Ireland before a reimbursement application can be made.  

Information on the measures introduced by the EU on USA imports can be found here 

What US Tariffs means for UK business 

The measures on Steel and Aluminium producers and to exporters to the US of derivative products, will require firms to understand the delineated and specific HS codes for the products that are impacted by the tariff measures. 

On a wider level, firms will need to map supply chains and trade flows to understand direct and in-direct impacts – as locational tariffs might impact where components or materials are coming from. 

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, 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 responding 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.