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EU Retaliatory Trade Measures Against the U.S. – Public Consultation

What You Need to Know

  • Key takeaway #1

    The European Union has added weight to its negotiating position for a trade deal with the U.S. by launching a public consultation on products imported from the U.S. that could be subject to new EU rebalancing measures (retaliatory tariffs).

  • Key takeaway #2

    As long as the ongoing EU-U.S. negotiations do not lead to a positive outcome, the likelihood of the EU imposing rebalancing measures continues to increase.

  • Key takeaway #3

    If EU-U.S. trade is important to your company or supply chain, you should make your voice heard by 10 June 2025, 12:00, Brussels time. European users should pay particular attention to imported raw materials or components from the U.S.; U.S. users should reflect on possible export restrictions from the EU.

Client Alert | 3 min read | 05.12.25

On 8 May 2025, the European Commission published new lists of products potentially subject to EU rebalancing measures in retaliation to U.S. tariffs. The proposed measures would apply if EU-U.S. trade negotiations fail. They are designed to stand alongside previously adopted EU countermeasures, which are currently suspended until 14 July 2025.

Why propose new EU rebalancing measures?

These new EU rebalancing measures have been proposed in response to the following U.S. measures:

What are these new EU rebalancing measures?

The new EU rebalancing measures include:

  • export restrictions on certain steel scrap and waste products, and on certain chemical products (worth €4.4 billion in total)
  • additional increased import customs duties on a wide variety of products (worth €95 billion in total)

The Commission has not yet determined the nature of the export restrictions or the level of the customs duties.

How can you participate in the consultation?

The European Commission has launched a stakeholders’ consultation phase to gather information in relation to these new rebalancing measures. All operators (from the EU, U.S., or other jurisdictions) affected either by the U.S. measures or the potential EU rebalancing measures are invited to submit their views with supporting information to the Commission by responding to a survey. Companies are not only invited to comment on the appropriateness of the EU imposing the rebalancing measures, but also to detail any difficulties that they may have encountered following the imposition of the three U.S. measures listed above.

Although the survey is open to all stakeholders, the Commission is especially interested in gathering information that will help it determine how the U.S. measures and the proposed EU response affect EU economic interests. Based on this information, the Commission will finalize its lists and present them to the EU Member States with a view to reaching a final agreement.

Anyone responding to the survey may request that the information provided be treated as confidential. Such information should be as detailed and technical as required, and may contain trade statistics, market analyses or proprietary information, all of which the Commission will treat as strictly confidential. Stakeholders may also set out their views on the nature and level of the measures proposed.

The deadline for responding to this survey is 10 June 2025, 12:00 (UTC+01:00), Brussels time.

If you have any questions about how to respond to the Commission's survey, our international trade team in Brussels is available to guide you. Crowell's trade experts have helped our clients during similar consultation phases in the past: we can ensure that your voice is heard.

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