Insights on US-EU Trade Agreement for Irish businesses

On Sunday 27th of July 2025, negotiators from the EU and US trade delegations announced a trade framework deal which provides that a 15% tariff rate would be applied to many EU goods being imported into the USA.

In her press conference, President Ursula von der Leyen said that a “single all-inclusive” 15% tariff rate would be applied across most products of EU origin being imported into the US. It was also clarified that this is a ceiling rate and that a tariff stacking approach would not be applied to EU imports to the US.

What does this mean for Irish businesses?

The uncertainty caused by the US tariff policies has had a dampening effect on levels of investment and trade. In the early months of 2025, the CSO trade statistics showed significantly elevated exports to the US, which was indicative of stockpiling, i.e. a hedge against the implementation of tariffs by the US government. It is expected that the presence of these forward purchased stockpiles will cool demand for Irish exports in the 2nd half of 2025.

Following a period of considerable turbulence and uncertainty, this deal provides a platform on which businesses on both sides of the Atlantic can once again begin to operate in a more predictable trading environment.

However, as more details of the framework agreement are released and further negotiations on certain aspects continue, there will be greater clarity on the potential impact of the framework trade agreement on Irish businesses. In particular, clarity on the potential impact on the pharmaceutical sector, a significant exporter of goods from Ireland to the US, will be very important.

There are a number of actions that Irish businesses should consider in response to the trade framework agreement.

1. Understand your exposure to exporting to the US

• Consider impact of 15% tariff to be levied on goods of EU origin
• Consider sectoral tariffs (e.g. steel/aluminium) which are levied in addition to the baseline tariffs
• Map your supply chains and consider if your business has exposure resulting from incorporation of materials originating in other jurisdictions (e.g. parts/materials from China that are processed in Ireland)
• Analyse differences between Customs and TP valuations including any specific price corrections required for Customs purposes.

2. Revisit value for customs purposes

• Assess feasibility of tariff mitigation strategies (short and long term) including any associated direct and indirect tax implications
• Review current and alternative transfer pricing models which may impact on the product price for good acquired by a US affiliate. Analyse alignment between Transfer Pricing and Customs valuations for any revised models
• Evaluate opportunities to identify and separate non-dutiable charges from the custom value through bundling and unbundling strategies
• Consider application of First Sale for Export methodology

3. Diversify

• Consider whether supply chains can be diversified to increase tariff efficiency where necessary.

4. Comply

• Good customs compliance – particularly in respect of HTSUS (Harmonized Tariff Schedule of the United States) codes and the originating status of goods must be treated as a priority.

5. Monitor

• Monitor developments – stay up to date with developments and adapt where possible.