The EU has published a legislative proposal to implement its commitments to reduce tariffs on U.S. industrial goods and certain seafood and agricultural goods. Tariffs on lobster imports are addressed in a separate proposal.

U.S. industrial goods and certain seafood and agricultural goods

The listed U.S. industrial goods should not be subject to any tariffs. The items listed in Annex I include various items across multiple chapters of the EU Customs Tariffs. This tariff elimination should extend the tariff-free treatment to the remaining 34% of goods that were subject to EU tariffs in 2024.

For some agricultural goods in Annex II, the EU proposes to eliminate the ad valorem component but to keep the specific tariff, which depends on import prices. For instance, fresh table grapes under 0806 10 10 are subject to a tariff of 17.6% and EUR 1.1 per 100 kg net if the entry price from July 21 to October 31 is between EUR 53.5 and EUR 54.6. The 17.6% tariff should be eliminated, but the EUR 1.1 tariff is maintained.

The U.S. goods listed in Annex III will be subject to EU quotas. Pigmeat, bison, dairy products, cheese, nuts, soybean oil, some animal feed preparations, Alaska pollock, squid, unprocessed and processed salmon, prepared shrimp, hake, dogfish, mannitol, sorbitol, some non-alcoholic beverages, odoriferous substances, and dextrin should be subject to no tariff. Some other goods, including cocoa powder and chocolates and some food preparations of Chapter 19 and 21, except for a few products with no tariff, should be subject to ad valorem tariff from 1% to 3.9% and/or specific tariff.

The EU will suspend the above measures in whole or in part if the U.S. fails to implement its commitments under the Framework Agreement, or there are sufficient indications that it will happen in the future; if there are changes of objective circumstances from those that existed at the time of issuing the Framework Agreement; and if imports volume cause or threaten to cause serious injury to EU’s domestic industries.

Once the proposal is adopted, it enters into force on the first day after its publication in the EU’s Official Journal.

Imports of Lobster

With regard to imports of lobster, the EU proposes to continue the non-application of tariffs on certain types of lobster and to additionally exclude processed lobster from any tariff.

The proposal also provides for the suspension provision, which is worded in a similar way to that found in the proposal on industrial goods and certain seafood and agricultural goods. However, it excludes injury to the EU’s domestic industry as a suspension ground.

Unlike the proposal on industrial goods and certain seafood and agricultural goods, the tariff elimination will be applicable with a retroactive effect. For that reason, importers may request a refund of the paid tariffs from August 1, 2025, until the entry into force of the proposal.

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Photo of Daniel Cannistra Daniel Cannistra

Dan Cannistra is a partner in the firm’s Washington, D.C. office. His practice focuses on legislative, executive and regulatory representation of domestic and international clients on a broad spectrum of international trade matters. Dan has represented domestic and foreign companies in over 75

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Dan Cannistra is a partner in the firm’s Washington, D.C. office. His practice focuses on legislative, executive and regulatory representation of domestic and international clients on a broad spectrum of international trade matters. Dan has represented domestic and foreign companies in over 75 U.S. antidumping and countervailing duty cases before the U.S. Department of Commerce and the U.S. International Trade Commission under the Tariff Act of 1930. Many of these matters involved appeals to the U.S. Court of International Trade, the U.S. Court of Appeals for the Federal Circuit, binational panels under the North American Free Trade Agreement (NAFTA), and dispute settlement proceedings before the World Trade Organization (WTO). Dan has also represented clients in antidumping proceedings in the European Union, Canada, Mexico, Brazil, India, Thailand, Singapore, Guatemala and Taiwan.

Prior to joining Crowell & Moring, Dan was a director in a national accounting firm providing customs and international trade guidance to multinational clients related to the supply and distribution of goods and services across international borders. Areas of specialization included antidumping and countervailing duties and policy, trade remedies and litigation, free trade agreements and negotiations, classification and valuation, and international trade and development.

Dan’s government appointments include service to U.S. Trade Representative on the roster of international trade practitioners to resolve antidumping disputes involving NAFTA members. For the European Commission, Dan provided advice and training on international trade and antidumping methodology and practice. In addition, Dan has served as an international trade consultant to the governments of Guatemala and Singapore, providing technical advice to these governments on the application of international trade regulations consistent with international law and World Trade Organization agreements and the General Agreement on Tariffs and Trade, Agreement on Antidumping.

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