On September 25, 2025, the U.S. Department of Commerce and the Office of the U.S. Trade Representative issued a notice implementing various changes pursuant to the recent US-European Union trade deal. Retroactive to August 1, 2025, automobiles and automobile parts with a most-favored nation (MFN) rate of 15% or higher, will still be subject to that rate with no additional reciprocal rate. However, for those automobiles and automobile parts with an MFN rate below 15% a 15% flat rate will apply to the product.

Furthermore, retroactive to September 1, 2025, numerous products including unavailable natural resources, all aircraft and aircraft parts, and generic pharmaceuticals and their ingredients will only be subject to the MFN rate. Civil aircraft and related components, as well as non-patented pharmaceutical products, will be exempt from additional duties previously imposed under various proclamations and trade remedies. All product subject to this change may be found in Annex 1 to the notice. 

The Husch Blackwell team continues to monitor developments and will provide additional updates as they arise.