last updated 26.03.2025

Trade and related tariff measures have been announced and enacted by the United States (US) from February 2025. Described as moves to protect national security concerns and improve domestic manufacturing capability, the implications for manufacturing sector importers and exporters in areas such as finance, tax and supply chain management is of critical concern.

The trade and tariff actions announced by the US has been focused on a few named countries, and on specific products. The potential also remains that the US will apply new reciprocal tariffs on trading partners who they contend apply taxes and rules that are seen as being uncompetitive and additional barriers for US exports. The expectation is that countries or economic blocs affected by these trade and tariff measures will apply similar measures against imports from the US and potentially consider other trade and investment measures against US economic interests in their countries.

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 to the UK

Steel & Aluminium

On March 12th, the US Administration applied tariffs on steel and aluminium imports including on derivative products. This included imports from the UK. A tariff of 25% is now applied: in the case of aluminium an increase from 10%; the addition of a tariff on derivative products covers a range of US imports that were not previously impacted by previous tariff regimes. In response, a number of retaliatory measures have been applied by countries and economic blocs directly who are now affected by these measures.

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

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

  1. https://www.whitehouse.gov/presidential-actions/2025/02/defending-american-companies-and-innovators-from-overseas-extortion-and-unfair-fines-and-penalties/
  2. https://www.federalregister.gov/documents/2025/02/18/2025-02832/adjusting-imports-of-aluminum-into-the-united-states
  3. https://www.federalregister.gov/documents/2025/02/18/2025-02833/adjusting-imports-of-steel-into-the-united-states

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

  1. https://luxembourg.representation.ec.europa.eu/actualites-et-evenements/actualites/eu-countermeasures-us-steel-and-aluminium-tariffs-explained-2025-03-12_en
  2. https://www.europarl.europa.eu/topics/en/article/20250210STO26801/eu-us-trade-how-tariffs-could-impact-europe

What this 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. 

Firms will need to map supply chains and trade flows to understand direct and in-direct impacts. 

Immediate questions to consider by UK business:

  • Determine what’s ‘in scope’ and ‘out of scope’ for product exports to the US
  • How accurately are you classifying your goods for US import
  • Are you at risk of mis-classifying your goods therefore by implication, likely to be affected by tariffs
  • Assess whether to change your input supply chain from ‘country A’ to ‘country B’ to limit tariff exposure
  • Consider revising goods origin calculations and valuation procedures to the US, to ensure compliance and minimise ‘over statement’ of tariff amounts

Check your commercial/Incoterms agreements with your customer to ensure that the burden of cost responsibility. Tariffs are generally paid by the importer