EU Countermeasures Chartbook
An analysis of the EU's proposed tariff response to US trade measures
This chartbook analyses the European Union's proposed countermeasures against imports from the US, covering 6,458 product lines worth EUR 110 billion. The measures were proposed in July 2025 but never activated following the Turnberry accord. The analysis covers the four implementation waves, member state exposure, sectoral breakdown, and tariff rate distribution.
In response to US tariff measures announced in 2025, the European Union prepared a comprehensive countermeasure package targeting US imports. Although these measures were never activated following the Turnberry accord, this chartbook provides a detailed analysis of what the EU had prepared.
Key Findings
- 6,458 product lines were targeted across four implementation waves
- EUR 110 billion in US imports would have been affected (2024 values)
- This represents 33.5% of all US imports into the EU
- The trade-weighted average tariff increase was 24.0%
- Estimated annual tariff revenue: EUR 26.4 billion
Implementation Timeline
The countermeasures were structured in four waves:
- Wave 1 (7 August 2025): 1,676 products, EUR 18.9 bn affected
- Wave 2 (7 September 2025): 4,692 additional products, EUR 72.1 bn affected
- Wave 3 (1 December 2025): 5 additional products, EUR 3.5 bn affected
- Wave 4 (7 February 2026): 85 additional products, EUR 15.5 bn affected
Tariff Rates
Additional duties ranged from 15% to 50%, with most products facing increases of 21-25%.
Note
These countermeasures were proposed but never activated. They provide insight into potential EU responses to future US trade threats. All tariff figures represent additional duties imposed on top of existing EU tariff rates. All trade figures refer to extra-EU imports only.
Data Source
Analysis based on GTA State Act 91584, using COMEXT trade data for 2024 and January-November 2025.