As is well known, just over a week ago, Donald Trump's new executive order came into force, aiming to remedy “the persistent and significant trade deficit caused by international trade practices” by introducing import tariffs. We have examined how these measures may affect Europe and, within it, Hungarian businesses.
Target Countries, Tailored Exemptions
According to the U.S. government, the countries subject to these “punitive tariffs” are engaged in unilateral or discriminatory trade practices, thereby justifying the imposition of tariffs exceeding standard rates. As a first step, on April 5, 2025, a general 10% import tariff was imposed on all goods entering the U.S., except for iron, steel, and aluminum products, as well as automobiles, which were subject to a 25% tariff. In the second phase, differentiated tariffs ranging from 11% to 50% were introduced for imports originating from 57 countries.
In addition to these tariffs, the Trump administration also eliminated a number of preferential measures starting May 2, 2025 – for example, the exemption for goods valued under USD 800 originating from China and Hong Kong.
As these changes affect the European Union, Hungary – as a member of the EU customs union – cannot opt out. Therefore, under the new rules, all goods exported from the EU to the U.S. would be subject not only to the general 10% or 25% tariffs, but also to an additional differentiated tariff of 20%.
These differentiated tariffs were originally set to take effect from April 9, 2025, but the U.S. suspended their implementation for 90 days at the last moment – with one exception: China is already facing a total tariff rate of 145%, combining both previous and new tariffs (amounting to 34%).
Following the suspension, the Trump administration further softened the measures on April 11, 2025, by temporarily exempting certain electronic products – such as smartphones, computers, semiconductors, solar panels, and memory cards – from import tariffs. (The detailed list is available here)
Due to the suspension, the differentiated tariffs are currently not in force – however, the general 10% and, for example, the 25% tariff on the automotive industry remain applicable.
Administrative Challenges
Nevertheless, companies exporting to the U.S. should remain cautious. One major challenge in applying the new U.S. measures is the correct determination of the product’s country of origin, as the U.S. non-preferential rules of origin differ significantly from those applied within the EU. Currently, there is also uncertainty regarding how U.S. customs authorities will accept and evaluate certificates of origin issued in Europe.
Therefore, it is strongly advised to consult with a U.S.-based trade advisor if the product being exported involves multiple countries in its production chain, as determining the correct country of origin may require additional analysis.
The EU May Retaliate
The European Union previously responded to similar actions taken by the first Trump administration in 2018 and 2020 by introducing 10% and 25% import tariffs on selected U.S. goods. However, once the Biden administration suspended the tariffs on European products, the EU reciprocated and suspended its own countermeasures until March 31, 2025. The EU then extended the suspension until April 14, 2025, and most recently, through a new regulation, extended the suspension until July 14, 2025, to facilitate further negotiations with the U.S.
Beyond the earlier tariff measures, the European Commission has also prepared a new and broader package of countermeasures in response to the Trump administration’s latest trade policy actions. Estimated at approximately EUR 18 billion, the package would affect a much broader range of industrial and agricultural goods from the United States. The measures were planned to be introduced in two phases – starting on May 16 and December 1, 2025 – but in light of the latest developments in the trade conflict, the Commission has postponed their implementation until July 14, 2025.
As a result, the EU will not impose any additional tariffs on U.S. goods until at least July 14, 2025. However, given the current unpredictability of the trade war, businesses importing from the U.S. are likewise advised to proceed with heightened caution.
This caution should involve not only closely monitoring customs regulations, but also reviewing existing contractual arrangements – and, if necessary, amending certain contracts. This is especially important for businesses with long-term agreements, as experience shows that most contracts are not adequately equipped to address commercial disruptions arising from sudden changes in tariff rates.