Trump Administration tariffs: Responses from the EU, the UK, and APAC

On Wednesday 2 April 2025, US President Donald Trump signed an Executive Order declaring a national emergency “arising from conditions reflected in large and persistent annual US goods trade deficits.” In response, the President announced the implementation of a new set of tariffs on all goods imported into the US. These tariffs consisted of:

• A 10% baseline tariff on all imports into the US, which came into effect on 5 April.


• Higher reciprocal tariffs on 60 trading partners with which the US determined it had the largest trade deficits. The tariff rates levied on each jurisdiction vary, with the European Union subject to a 20% tariff on all goods and China an additional 34%. Countries in south-east Asia faced some of the highest rates – including 46% for Vietnam, 49% for Cambodia, 36% for Thailand, and 24% for Japanese goods.

On Wednesday 9 April, President Trump announced a 90-day pause in the implementation of the higher reciprocal tariffs. In the interim period, all countries will face the same baseline tariff rate of 10%. The Trump Administration have indicated their intention to use this time to carry out parallel trade discussions to agree trade deals with key trading partners.

The notable exception to this global de-escalation is China, which responded with countermeasures to the Trump Administration’s reciprocal tariffs. The resulting escalation means that, as of Friday 11 April, China has imposed tariffs of 125% on US goods and faces combined US tariffs of 145%.

The tariffs do not apply to US neighbours Canada and Mexico, who will continue to be subject to tariffs set out under previous Executive Orders in February and March, as discussed in our earlier client alert.

In addition, there has been no change to the previously announced 25% tariffs on all global car and truck imports which came into effect on Thursday 3 April. They will be joined by a 25% levy on automobile parts from 3 May – covering up to USD460 billion worth of vehicle and automobile parts imports into the US annually (Reuters).

Other goods currently exempted from the reciprocal tariffs include bullion, energy and minerals not found in the US, as well as semiconductors, pharmaceuticals, copper, and lumber.

Response from the European Union

UPDATE: On Tuesday 8 April, President Trump announced a 90-days drop in the tariffs – from 20% for the EU to 10%. As a consequence, the EU has now paused the collection of the duties of the recently agreed measures responding to the tariffs on steel and aluminium, to allow room for negotiations with Washington.

In just a few months, the EU-US trade relationship has changed significantly.

European Commission President Von der Leyen outlined the EU’s approach to respond to the imposition of tariffs, which consists of the adoption of two sets of countermeasures. Furthermore, Von der Leyen indicated that the EU will also closely monitor the potential indirect consequences of the tariffs, including potential dumping of goods from third countries as a consequence of disruption of trade with the US. She also stressed the EU’s openness to negotiate with Washington and put forward a proposal for a "zero-for-zero" tariff deal on industrial products, including cars and all other industrial goods, such as chemicals, pharmaceuticals, rubber, and plastic machinery.

The EU's response is divided in three different packages: mid-April for the reinstatement of the dormant tariffs agreed during President Trump's first mandate, mid-May for the additional counter-tariffs on US imports, and a final round later in the year. Furthermore, the EU will likely explore other non-tariffs option from its "trade bazooka" to leverage its negotiating position with the US.

Please note that the historically rapid changes in President Trump's tariffs could significantly impact the EU's planned response.

EU response to tariffs on steel and aluminium

As a response to the imposition of tariffs on European steel, the EU adopted on Wednesday 9 April a set of countermeasures worth EUR22 billion in total.

As a first step, the EU lifted the suspension on the additional tariffs on products included in Implementing Regulations 2018/886 and 2020/502. These tariffs were originally adopted during President Trump’s first presidency as a response to the US steel and aluminium tariffs. These EU countermeasures were suspended in 2021. The additional 25% customs duty will hit key US exports, such as motorcycles, jeans, orange juice, and tobacco/cigars. The suspension was first expected to be lifted on Tuesday 1 April, but it has been delayed until mid-April in order to coincide with the set of brand-new countermeasures.

Additionally, the EU agreed to impose countermeasures on a wide array of additional US imports, subject to tariffs up to 25%. A 99-page list of potential products was first published in early March. The European Commission launched a public consultation until Wednesday 26 March to gather feedback from stakeholders on the impact of the counter-tariffs to be introduced by the EU. Economic operators were asked to mention which good(s) they are concerned with and to highlight which EU economic interest is at stake as a consequence of: (a) US tariffs; and/or (b) EU’s proposed counter-tariffs. Based on the feedback received, the European Commission prepared a draft implementing act containing the measures under Regulation (EU) 654/2014 (Enforcement Regulation) and consulted Member States under the comitology procedure.

The final list – which has been shortened and now counts 66 pages – obtained approval by a qualified majority on Wednesday 9 April. The list includes US goods including ski suits, vegetables, fruits, nuts, diamonds, footwear, steel, meat, white chocolate, and polyethylene, targeted with a tariff of 25%. Fewer goods (such as essential oils and hair lacquers) are targeted with a lower tariff of 10%. These measures are applicable as of one month later, in mid-May. Following requests coming from some Member States fearing further retaliation, spirits and wine have been removed from the retaliatory list initially proposed.

Further goods are expected to be targeted later throughout the year.

EU response to  US “reciprocal” tariffs

Following the tariffs announcements of “Liberation Day”, the EU and its Member States will likely retaliate with broader – non-tariffs - measures potentially targeting also other sectors of the US economy. The Anti-Coercion Instrument (Regulation 2023/2675) appears to be the tool under consideration, as it provides the EU with some flexibility for its response. In view of the US surplus on services, some of the reported responses that the EU is considering include services and intellectual property rights (e.g. imposing digital taxes on Silicon Valley, regulatory clamps on Wall Street, or taxes on US pharma exports). Other measures could include taxing financial transactions and digital flows, restrictions under the new International Procurement Instrument, or additional fees on US airlines landing in EU airports. On top of additional retaliatory measures, the EU competition chief Ribera has warned of “brave” enforcement of digital regulation (i.e., DMA) on US companies.

The final measures will depend on what President Von der Leyen and Trade Commissioner Šefčovič will discuss with the Member States. US tariffs will likely be more impactful on certain Member States (e.g. France, Germany), which arguably will spearhead the discussions on countermeasures. Yet not all Member States have the same appetite for retaliation as to avoid potential escalation.

Following the industry's pressure on both sides of the Atlantic, pharmaceutical products – representing a key sector for the EU - have so far been spared by the reciprocal retaliations. However, it cannot be excluded that the sector may be targeted later on.

As for timelines, the European Commission has dismissed France’s claim that measures will be already agreed as of the end of April, stating instead that they would come at “appropriate time”. Trade Commissioner Šefčovič insisted that the EU will respond to tariffs in a calibrated and unified way, carefully balancing the interests at stake and the options available.

Response from the Asia-Pacific

Almost all governments in the APAC region voiced their strong disapproval and concern about the Trump Administration’s tariff announcements on Wednesday 2 April, while remaining cautious in announcing strategies for responding.

Governments of Australia, New Zealand, and Malaysia stated that they did not plan to retaliate with their own tariffs. Governments of South Korea, Japan, India, Indonesia, Malaysia, and Thailand described efforts to negotiate new resolutions with the US. Governments of multiple Asian countries, including South Korea, India, Thailand, and Cambodia, urged businesses and the public to remain calm and promised to support affected industries or establish plans in response to the tariffs. Vietnam’s Prime Minister ordered the establishment of a task force to address the situation, and media reports indicate that initial bilateral discussions between Vietnam and the US are taking place.

China, however, imposed its own countermeasures in response to the US tariffs. The Chinese government issued a statement opposing the US and took multiple countermeasures immediately on Friday 4 April, including imposing an additional 34% tariff on all imported goods originating from the US on top of the existing applicable tariff rate, adding 16 US entities to the Export Control Blacklist, suspending qualifications of 3 US companies for poultry meat and bone meal exports to China, and adding 11 US companies to the Unreliable Entity List. The US retaliated by increasing the tariff on Chinese goods to 104%, prompting China to increase the tariffs on US goods to 84%. On Wednesday 9 April, the Trump Administration announced a further increase of tariffs on China to 145%. As of Friday 11 April, China has responded with an increased tariff of 125%.

At this point, the extent of any future countermeasures against the US tariffs or the contours of any bilateral bargains to address US concerns remain unclear. President Trump has indicated that he is open to talks with his Chinese counterparts and that he expects discussions to commence in the near future. In the meantime, businesses caught in the economic uncertainty between the two countries have responded by increasing prices, cancelling shipments, or redirecting trade to other countries.

Countries in the wider region, including Japan and South Korea, may be able to negotiate a deal with the US before the end of the 90-day suspension period, and therefore avoid the direct impact of higher reciprocal tariffs.

Response from the United Kingdom

Alongside countries including Singapore and Brazil, the UK is not on the list of the 60 jurisdictions facing the Trump Administration’s now-suspended reciprocal tariffs – but will nevertheless be subject to the 10% baseline tariffs applied to all imports into the US. The UK’s car industry will also be impacted, with the c. USD10 billion of annual automobile exports from the UK to the US hit by the higher 25% levy (FT).

The US is the biggest buyer of British-made cars, making the automotive sector one of the most exposed to the tariffs. Other sectors hardest hit include the food and drink industry – the US is the largest market for exports of Scotch whisky – and chemicals, the second-largest commodity exported from the UK to the US (ITV).

Prime Minister Sir Keir Starmer set out his response to the Trump Administration’s actions in a speech to UK business leaders in Downing Street on 3 April. The speech indicated that the UK would not be immediately imposing significant retaliatory measures on the US in response, noting that a “trade war” would not be in the UK’s national interest.

The UK Government has published an indicative list of goods imported from the US that may be considered as part of future retaliatory measures. The list encompasses around 27% of British imports of US origin goods, while excluding products deemed to be in the wider public interest, such as medical supplies and military equipment.

Meanwhile, several policy changes have been fast-tracked in support of key British industries. On Sunday 6 April, Sir Keir Starmer announced plans to change the Zero Emission Vehicle Mandate to ease the pressure on the UK's car industry to upgrade to manufacturing electric vehicles.

Negotiating a trade deal

The Prime Minister’s speech also confirmed reports that negotiations are underway on a trade deal with the US – described by Sir Keir Starmer as “an economic prosperity deal, one that strengthens our existing trading relationship” with the US (Prime Minister’s Office). The UK Government may be pinning its hopes on such a deal leading to the removal or reduction of any or all of the US imposed measures – including the 25% tariffs on aluminium and steel imposed in March, the incoming 25% tariffs on cars and parts, and the 10% baseline tariff on all UK goods exported to the US.

Negotiations on this deal appear to be at an advanced stage. In an interview responding to the US tariff announcements, the Business Secretary confirmed that the deal had been agreed with US officials and is currently awaiting sign-off from the President (BBC).

The deal, which the UK has been keen to centre around advanced technology, may include offers from the UK to remove or water down the digital services tax introduced in 2022, or increase access for US companies to the technology corridor between Oxford and Cambridge (FT). 

Wider impact on UK industry

Importantly, the agreement of a UK-US trade deal is unlikely to resolve the indirect impacts of the Trump Administration tariffs and any resulting escalation, of particular concern should the escalating trade tensions between China and the US continue. This could lead to a wave of products being diverted from the US market to the UK, as Chinese exporters look for new markets. Depending on the severity of any resulting market distortions, the UK Government and Trade Remedies Authority could consider further trade defence measures to mitigate the impacts of dumping or import surges.

As the wider impacts of these tariffs make themselves known in the coming days and months, affected businesses are encouraged to engage in proactive mitigation planning. In particular, UK-based manufacturers with a presence overseas are encouraged to reassess and adapt their supply chains to this complex landscape. For more details, our article on mitigating tariff dispute sets out a range of supply chain mitigation strategies for your business to consider.

UK launches consultation

Addressing Parliament on 3 April, UK Business Secretary Jonathan Reynolds announced the launch of a consultation with businesses on the commercial impact of any potential retaliatory tariff measures taken by the UK against the US, closing on 1 May.

Affected businesses are encouraged to ensure their views are represented in UK Government trade policy ahead of time. If you would like support in responding to this consultation, contact DLA Piper’s UK Trade and Government Affairs team.

How we can help

At the interface of business, politics, and global trade, the DLA Piper International Trade and Regulatory and Government Affairs teams can help you assess and mitigate your risks, including by:

• Engaging with governments to seek product or sector exemptions; and
• Analysing supply-chain risk in both geopolitical and international trade contexts and draw up effective supply-chain mitigation strategies.

For questions related to matters outside the US, please contact Richard Sterneberg and Paul Hardy from the International Trade and Regulatory Government Affairs team. For questions regarding US-based issues, please contact Christine Daya and Nicholas Klein from the US National Security and Global Trade team.

This is a fast-moving area of international policy. The contents of this article reflect the latest developments as of the date of publication.