The Tariff Hub

The rate was calculated by taking trade deficits in goods ran by the US with a particular country, divided by the total goods imports from that country, and then dividing this result by two. A trade deficit occurs when a country buys (imports) more physical products from other countries than it sells (exports) to them. The tariff rate was calculated on the basis that it would eliminate the US's goods trade deficit with each country. The calculation does not include trade in services.

There is no full list of tariff codes, only a list of exemptions. If a product is not covered by these exemptions; it is subject to tariffs. Find the full list of exemptions here.

On 9 April, the Trump administration announced a 90-day pause on “reciprocal” tariffs to all countries apart from China. This refers to pause on the tariffs announced on April 2 and does not apply to pre-existing tariffs on steel, aluminium and auto vehicles. As a result, the EU will no longer face a tariff rate of 20%, rather it will be subject to the baseline tariff rate of 10% during a 90 day “negotiation period” before an agreement is reached. In response to this announcement, the EU has in turn paused its planned countermeasures to the steel and aluminium tariff package announced by President Trump in March. EU countermeasures to the “reciprocal” tariffs have not yet been announced.

The additional 10% ad valorem duty applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 5, 2025. However, goods that were already loaded onto a vessel and in transit on their final mode of transportation before that time are exempt from the additional duty, even if entered for consumption afterward.

The tariff rate applied will depend on the determined 'origin' of the product, i.e. whether a product is wholly obtained in one jurisdiction or, if not wholly obtained, "the last country in which it has been substantially transformed into a new and different article of commerce with a name, character, and use distinct from that of the article or articles from which it was so transformed". It is currently unclear how the US will precisely determine this origin, in particular for products with multiple components of different origin. 

The US administration has not yet announced exactly how tariffs will be applied to imported goods in practice. If a product falls under the scope of tariffs and is not covered by the exemption list, tariffs cannot be circumvented.

There is currently no information or suggestion regarding the possible future expansion of exemptions.

It is impossible to tell with certainty the duration of the tariffs, the Tump administration’s 90-day pause on reciprocal tariffs on all countries apart from China announced on 9 April underlines this climate of uncertainty. However, there is ongoing speculation that some of the products which are currently exempt (namely pharmaceuticals, semi-conductors, lumber, gold, and copper) may be targeted at a later date.

The US has given no clarification as to why services are not subject to tariffs; it is likely due to the fact that it currently runs a trade surplus on services but a deficit on goods. The details of the EU response are not yet clear.

Yes, an additional 20% tariff will be payable on the import of EU goods (which includes goods manufactured in Ireland as part of the EU) into the US once the 90-day pause ceases in July. The Executive Order ‘Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits’ resulting in the tariffs being imposed by the US authorities today states ‘Section 3 implementation (c) The rates of duty established by this order are in addition to any other duties, fees, taxes, exactions, or charges applicable to such imported articles, except as provided in subsections (d) and (e) of this section below.’

This will not be clear until retaliatory measures have been officially announced and will be dependent on established trade relationships between the EU/US and third countries. Over the last number of years, the EU has made substantial efforts to diversify and secure FTAs with third countries, we expect this trend will continue.

The tariff is calculated on the sale price of the Irish entity to the US entity, paid by the latter of purchase. This applies to both final and intermediate goods

There is unlikely to be an effect on consumer prices as a result of tariffs on Irish exports to the US. However, retaliatory arbitrary tariffs from the EU on US imports would impact consumer prices on listed products. The tariff list released (and since paused) by the European Union would have encompassed approximately 1% of total Irish imports.

In response to the U.S. 90-day pause on the additional “reciprocal tariffs” introduced on 9 April, the European Union has opted to delay the implementation of its own countermeasures relating to the U.S. tariffs on steel and aluminium by 90 days, which had been approved by Member States. The European Commission adopted two Implementing Acts (IA). The first lists US products to be targeted in EU countermeasures in response to the existing US tariffs on steel and aluminium, and another act immediately suspends these countermeasures until 14 July 2025.

1. COMMISSION IMPLEMENTING REGULATION (EU) 2025/778 on commercial rebalancing measures concerning certain products originating in the United States of America
2. COMMISSION IMPLEMENTING REGULATION (EU) 2025/786 suspending commercial rebalancing measures concerning certain products originating in the United States imposed by Implementing Regulation (EU) 2025/778

The EU has committed to using this window to pursue a negotiated solution, though preparations for the countermeasures are ongoing. If no agreement is reached by the end of the 90 days, the EU is expected to proceed with implementation. Please note that while this measure represents a de-escalation, 10% tariffs remain in place during the 90-day period and continue to apply to all imports in scope.

Ibec supports the EU's work towards a negotiated solution with the US and a de-escalation of trade tensions with the aim of achieving zero-for-zero tariff levels. Ibec acknowledges that countermeasures are necessary if no negotiated solution can be reached but maintains that any escalation of trade tensions will not be beneficial for Irish business.

This is not yet clear. European Commission President Ursula von der Leyen responded to the US announcement of new tariffs, emphasising that the EU would take all necessary steps to protect its interests. The EU is preparing itself to retaliate vis-a-vis countermeasures if no negotiated solution is reached. Von der Leyen’s statement emphasised that the EU will actively monitor global overcapacities and product dumping. Considering that the majority of EU trade occurs under WTO rules, we expect EU countermeasures to be WTO compatible.

With exports of US goods making up over 24% of Ireland's national income, tariffs will have wide-reaching effects on Irish business. The pharmaceutical industry is currently exempt from tariffs, reducing the possible detrimental impacts, but may still be subject to tariffs in the future. The inclusion of other sectors such as Medtech and food and drink under the scope of tariffs will detrimentally affect Irish business. Ibec has a dedicated tariff hub on its website to track and evaluate the impact of the US tariffs, here a dedicated sectoral exposure slide deck outlines the most and least exposed Irish sectors and to what degree.

Pharmaceuticals are currently exempt from tariffs however, following remarks made by President Trump at the National Republican Congressional Dinner on April 8, there is much speculation that tariffs could be introduced on pharmaceuticals in the future. Ibec is following developments in this area and will duly inform members of relevant updates.

MedTech and medical devices are not covered by the pharmaceutical exemption, so are subject to tariffs. Find the full list of exemptions here.

Food exports and dairy products are not included in the list of exemptions, so are subject to tariffs. Find the full list of exemptions here.

Alcoholic beverages are not included in the list of exemptions, so are subject to tariffs. Find the full list of exemptions here.

Early evidence suggests the tourism figures from the US may be down on previous years, reflecting the fall in US consumer sentiment off the back of increased tariffs.

Retaliatory EU tariffs on US imports, particularly in steel and aluminium, will increase the cost of certain construction materials. It remains vital for companies in the housing sector to consider volatilities in cost and materials as well as potential customs delays. The sector might see a drop-off in demand from the United States in the face of higher internal prices. Ibec continues to advocate for improved housing delivery by urging the government to accelerate planning reforms and increase investment in housing infrastructure. This is critical to maintaining Ireland’s economic competitiveness and attracting talent.

The vast majority of Irish SMEs do not export into the US, thus the final product for the majority of Irish SMEs will not be liable for the 10% tariff. However, given how integrated Irish SMEs are into the supply chain of MNCs exporting to the United States, they may see a drop in demand from wholesale customers. Domestic retail is unlikely to see any major first round effects from tariffs. Any tariff-related slump in domestic retail trade would come as a consequence of the overall impact of tariffs on the Irish economy.

This matter is being closely followed by Aircraft Leasing Ireland's tax committee which will update members when further information becomes available. While aircraft do fall under the tariffs, rentals are excluded. The airline not the lessor will pay the tariff. However, there is concern that later in the year the US could introduce a change to Ireland’s DTA with the US that currently has a 0% withholding tax.

It is our current interpretation that repairs, categorised as services, will not be subject to tariffs. However, replacement parts of non-US origin used for such repairs may be subject to the base-line tariff rate of 10%. How exactly these tariffs will be applied in practice remains unclear. No information has come from U.S customs. Ibec is in the process of seeking clarifications vis-à-vis Irish Revenue Commissioners.