Section 301 Tariffs from EU – Preliminary List

Section 301 Tariffs from EU – Preliminary List

Possible Additional Duty up to 100% on EU Imports

The Office of the United States Representative (USTR) announced a preliminary list of products that could be the target of Section 301 ad valorem tariffs of $11.5 billion worth of goods brought into the United States from member States of the European Union. The tariffs could reach up to 100% duty.  The final decision and figure will be announced by a WTO arbitrator in the summer of 2019.

Download Preliminary List

The preliminary list includes 317 tariff subheadings when imported from members of the 28 EU member states as well as 9 Harmonized Tariff Schedule statistical reporting numbers being considered for additional duties.  The estimated import value of the goods on the preliminary list was approximately $21 billion in 2018. However, the final list will reflect only the amount of trade found to be adversely affected in the arbitrator’s decision. USTR states that retaliatory tariffs imposed on goods included in the final list will only be lifted “when the EU ends these harmful subsidies.”

Section 301 EU

What the List Includes:

Section 1

Imports from Germany, France, UK or Spain

The products listed in Section 1 of the Annex are being considered for additional duties if they are the products of Germany, France the United Kingdom or Spain. Some of these products include new helicopters, new aircrafts and parts thereof.

Section 2

Imports from the 28 Member States of the European Union

The products listed in Section 2 of the Annex are being considered for additional duties if they are the products of any of the 28 member states of the EU.
Some of these products include specific subheadings under the following types of goods, but are not limited to:

  • different types of seafood
  • different types of dairy products
  • fruit, jams, juices and pastes
  • olive oils and essential oils
  • olives
  • wine and other liquor
  • tools and nails
  • handbags
  • certain types of paper and pictures
  • books
  • yarns and fibers
  • carpets
  • glassware
  • precious metal and silver, iron or steel
  • ferrochromium and other related material
  • zinc and other related material
  • microwaves
  • motorcycles
  • bicycle parts
  • lenses
  • clocks
  • artist brushes

EU Section 301

What should you do

The USTR released an Initiation of “Investigation and Notice of Hearing and Request for Public Comments” pertaining to the “Enforcement of U.S. WTO Rights over the Large Civil Aircraft Dispute” dating back to 2004.  Scarbrough suggests to any importer with goods on this list to consider taking proactive measures to alleviate the impact of any potential tariff increase. Our team of experts is available to discuss different options by emailing, but we also first suggest submitting your own public comments.

Public comments are due May 6, 2019 and a public hearing will be held on May 15, 2019.  May 28, 2019 marks the due date for submission of written comments including post-hearing rebuttal comments.

How to Submit Comments

The docket number is USTR-2019-0003

Submit written comments through the Federal eRulemaking Portal:  To view further instructions, click here and navigate to Section E and Section F.

For issues with online submissions, please contact the Office of the United States Trade Representative (USTR) Section 301 line at (202) 395-5725.


On October 6, 2005, the United States requested WTO dispute settlement consultations with the European Communities (now the EU), France, Germany, Spain and the United Kingdom (certain member States) concerning certain subsidies granted by the EU and certain member States to the EU large civil aircraft domestic industry, on the basis that the subsidies appeared to be inconsistent with the obligations under the General Agreement on Tariffs and Trade 1994 (GATT 1994) and the agreement on Subsidies and Countervailing Measures (SCM Agreement).

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