US-EU Trade Deal Oct 2025: Implementation Guide
Thursday, November 13, 2025
General
Key takeaways
The US-EU Framework Agreement establishes a 15% all-inclusive tariff ceiling on most European Union products entering the United States
Generic pharmaceuticals, ingredients, and chemical precursors receive exemption from reciprocal tariffs under special provisions
Automobile and automobile parts tariffs apply retroactively to August 1, 2025, with specific reporting requirements
Aircraft products covered under the Civil Aircraft Agreement gain exemption from both reciprocal and Section 232 tariffs
Companies can claim retroactive refunds through Post Summary Corrections for eligible products imported during transition periods
Framework Agreement Overview
The United States and European Union finalized a comprehensive trade agreement that fundamentally changes tariff structures for EU products entering American markets. This Framework Agreement modifies reciprocal tariff rates across multiple sectors including pharmaceuticals, automobiles, aircraft components, and natural resources.
The agreement applies retroactively to August 1, 2025, for automobiles and automobile parts. All other covered products receive retroactive application to September 1, 2025. This timeline creates opportunities for importers to file corrections and reclaim duties paid during the transition period.
Generic Pharmaceutical Exemptions
Healthcare companies shipping generic pharmaceutical products from the EU benefit significantly from the new agreement. Generic pharmaceuticals, their ingredients, and chemical precursors now qualify for exemption from reciprocal tariffs.
Pharmaceutical classification requirements include:
Products must be generic formulations not patented in the United States
Ingredients and chemical precursors used in generic drug manufacturing qualify for exemption
Entry documents must include statements confirming non-patented status
Importers report these products using tariff code 9903.02.77
The pharmaceutical sector represents the EU's largest export category to the United States, totaling approximately $120 billion in 2024. This exemption protects critical supply chains while maintaining access to essential medications and research materials.
Automobile Sector Changes
The Framework Agreement establishes clear tariff structures for automobiles and automobile parts based on existing duty rates. Products with Column 1 duty rates at or above 15% face no additional reciprocal duties. Items with lower rates see combined tariffs adjusted to reach the 15% threshold.
Automobile imports use reporting code 9903.94.50 when Column 1 rates meet or exceed 15%. Products requiring rate adjustments to reach the combined 15% rate use code 9903.94.51. Automobile parts follow similar logic with codes 9903.94.52 and 9903.94.53 respectively.
These modifications apply retroactively to August 1, 2025, creating significant opportunities for importers who paid higher rates before implementation. Companies can pursue refunds through customs correction procedures for shipments processed during the transition window.
Aircraft and Aerospace Products
Civil aircraft and component manufacturers benefit from comprehensive exemptions under the Framework Agreement. Products covered by the Civil Aircraft Agreement receive exemption from both reciprocal tariffs and Section 232 measures, excluding unmanned aircraft systems.
Eligible aerospace products report using tariff code 9903.02.76. Entry documentation must include clear statements indicating products serve civil aviation purposes. This distinction proves critical for customs authorities processing shipments and determining applicable duty rates.
Natural Resources and Essential Oils
Unavailable natural resource products no longer face reciprocal tariff rates under the new agreement. This category includes cork and other materials where domestic production cannot meet demand. Importers report these products using code 9903.02.74.
Essential oils imported specifically for religious purposes receive special consideration. Products classifiable under 3301.29.51 gain exemption from reciprocal tariffs when properly documented. Entry paperwork must include statements confirming intended religious use, reported under code 9903.02.75.
Section 232 Product Continuity
Products already subject to Section 232 actions maintain their existing treatment under the Framework Agreement. Steel, aluminum, and copper products from the EU continue reporting under code 9903.01.33, remaining exempt from additional reciprocal tariffs while maintaining current Section 232 duties.
This continuity provides predictability for medical device manufacturers (https://www.shipmercury.com/industry/medical-devices) and biotechnology companies (https://www.shipmercury.com/industry/biotechnology) using these materials in production. Companies can plan inventory and sourcing strategies without concern for sudden tariff escalation on critical raw materials.
Claiming Retroactive Refunds
Companies that imported eligible products during retroactive periods can recover overpaid duties through established customs procedures. The refund process depends on the shipment's liquidation status and requires specific documentation.
Refund procedures include:
Post Summary Corrections for unliquidated entries
Formal protests for liquidated entries within the protest period
Detailed documentation supporting tariff code corrections
Evidence of product eligibility under Framework Agreement provisions
International shipping documentation plays a crucial role in refund success. Companies must maintain comprehensive records linking products to applicable tariff codes and demonstrating compliance with agreement requirements.
How Mercury Supports Trade Compliance
Mercury provides comprehensive guidance on navigating complex trade agreements and customs requirements. Our logistics specialists monitor regulatory changes affecting healthcare and life sciences shipments, ensuring clients maintain compliance while capturing available benefits.
We handle customs brokerage services, including tariff classification, documentation preparation, and refund filing support. Our team understands the specific requirements for pharmaceutical products, medical devices, and biological materials crossing international borders.
For companies shipping clinical trial materials or biological specimens, we coordinate both customs compliance and temperature-controlled logistics requirements. This integrated approach protects product integrity while ensuring regulatory adherence throughout the supply chain.
Strategic Planning for Trade Policy Changes
The Framework Agreement represents an ongoing evolution in international trade relationships. Companies shipping between the United States and the European Union should establish processes to monitor policy developments and adjust strategies accordingly.
Regular review of tariff classifications ensures continued compliance as products evolve and regulations change. Organizations benefit from establishing relationships with customs experts who understand industry-specific requirements and can anticipate regulatory shifts before they impact operations.
Ready to optimize your international shipping strategy under the new US-EU trade framework? Partner with Mercury for expert customs guidance and comprehensive logistics support. Contact our team today to ensure your shipments capture available tariff benefits while maintaining full regulatory compliance.
