Latest edition of EY Belgium’s customs and excise update

Key Takeaways:

• EU updates tariff quota and suspension rules: Russia and Belarus excluded from duty suspensions as of 1 July 2025 
• New EU tariffs on Russian goods: 50% duty on agricultural imports and rising fertilizer tariffs up to €430/ton by 2028 
• Omnibus package provisional agreement reached: CBAM, CSRD, and CSDDD simplifications include SME exemptions and reduced reporting 
• Trade defense actions on China: Anti-dumping duties imposed on plywood, screws, choline chloride, and more 
• Syria sanctions shift: Economic sanctions lifted, but human rights measures and Assad-linked sanctions extended 
• Sanctions & Incoterms factsheet: Commission clarifies sanctions apply regardless of Incoterm used 
• EU–UAE FTA negotiations launched: Talks focus on trade, investment, and strategic sectors like green hydrogen 
• US tariff escalation: Country-specific reciprocal tariffs announced by the US administration
   

Update on autonomous tariff quotas and customs duty suspensions

On 23 June 2025, the EU adopted two regulations amending existing frameworks for autonomous tariff quotas and customs duty suspensions, effective from 1 July 2025.

Council Regulation (EU) 2025/1292 amends Regulation (EU) 2021/2283, which manages autonomous tariff quotas for certain agricultural and industrial products. Notably, the regulation specifies that the suspension of duties does not apply to products originating in Russia or Belarus. As a result, imports from these countries will again be subject to EU import duties as of 1 July 2025.

Council Regulation (EU) 2025/1303 amends Regulation (EU) 2021/2278, which suspends Common Customs Tariff duties on certain agricultural and industrial products. This regulation also excludes products originating in Belarus and Russia, with specific exceptions for certain TARIC codes.
 

EU adopts new restrictive tariffs on Russian and Belarusian agricultural goods and fertilizers

On 20 June, the EU published Regulation (EU) 2025/1227 on the modification of customs duties applicable to imports of certain goods originating in or exported from Russia and Belarus. The regulation introduces an additional 50% ad valorem duty on all remaining Russian agricultural imports, ensuring that all such goods face EU tariffs. This means that these imports will be subject to an additional 50 % ad valorem customs duty that is to apply on top of the applicable Common Customs Tariff rate.For certain nitrogen-based fertilizers, a 6,5% tariff will be applied, supplemented by fixed duties starting at €40 to €45 per ton during the 2025–2026 period, increasing to up to €430 per ton by 2028.  

The regulation will enter into force on 20 July 2025, and also covers products such as sugar, vinegar, flour, and animal feed. This reflects the EU's commitment to enhancing food security and reducing reliance on imports from Russia and Belarus.
 

Omnibus package update: Council and EU Parliament reached provisional agreement

On 18 June 2025, the Council of the EU announced a provisional agreement with the European Parliament on the simplification of the Carbon Border Adjustment Mechanism (CBAM) as part of the 'Omnibus I' legislative package. This agreement aims to reduce regulatory and administrative burdens for EU companies, particularly SMEs, and includes a broader 'de minimis' exemption for importers of up to 50 tons of goods per year. 

Subsequently, on 23 June, the Council agreed to simplify sustainability reporting and due diligence requirements under both the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). This proposal is intended to ease the reporting burden on companies and provide greater legal certainty regarding their obligations. 

Both provisional agreements must now be formally endorsed by the Council and the European Parliament, with adoption expected by September 2025.
 

EU Commission imposes new trade defence measures targeting imports from China

The European Commission has adopted several new trade defence measures against imports from the People’s Republic of China, aimed at addressing unfair pricing practices and protecting EU industry competitiveness.

• Under Commission Implementing Regulation (EU) 2025/1041 of 27 May 2025, customs authorities are instructed to register imports of adipic acid (hexanedioic acid) originating in China. The registration will remain in effect for 9 months from the regulation’s entry into force.
  
  
• A provisional anti-dumping duty has been imposed on imports of hardwood plywood from China, under Commission Implementing Regulation (EU) 2025/1139 of 6 June 2025. The measure targets plywood made of sheets of wood with at least one outer ply of tropical or non-coniferous wood. Duty rates range from 25,1% to 62,4%.
  
  
• Under Commission Implementing Regulation (EU) 2025/1189 of 13 June 2025, a provisional anti-dumping duty has been imposed on imports of screws without heads made of iron or steel (excluding stainless steel) from China. Duty rates range from 62,3% to 80,7%. The regulation took effect immediately.
  
  
• A provisional anti-dumping duty has also been imposed on imports of choline chloride from China, effective 27 June 2025. The measure applies to all forms and purities of choline chloride with a minimum content of 30% by weight, excluding calcium phosphoryl choline chloride tetrahydrate. Duty rates range from 95,4% to 120,8%.
   

To benefit from individual duty rates under the provisional measures, importers must present a valid commercial invoice with a signed declaration. A security deposit equivalent to the provisional duty amount is required for release into the EU.
 

EU adopts legal acts to lift economic sanctions on Syria, enacting recent political agreement 

The Council of the EU has adopted legal acts lifting all economic sanctions on Syria, except those based on security grounds. This follows the political decision announced on 20 May 2025, and aims to support Syria’s transition toward a peaceful, inclusive, and pluralistic future. As part of this shift, 24 entities have been removed from the EU’s asset freeze list. These include banks, such as the Central Bank of Syria, and companies active in oil production, cotton, and telecommunications. Several media outlets have also been delisted. 

While economic sanctions are being lifted, the Council has extended sanctions on individuals and entities linked to the Assad regime until 1 June 2026. In response to the March 2025 violence in Syria’s coastal region, new restrictive measures have been introduced under the EU Global Human Rights Sanctions Regime, targeting 2 individuals and 3 entities for serious human rights abuses.
 

Factsheet on sanctions & Incoterms published

The Commission has published a factsheet on Incoterms and sanctions. The document serves as a clarification and does not introduce any new legislation. It emphasizes to operators the importance of adhering to sanction measures at all times, regardless of the Incoterm being utilized.
 

EU and UAE launch FTA negotiations 

The EU and the United Arab Emirates (“UAE”) officially launched negotiations for a bilateral free trade agreement (FTA) on 28 May 2025. The first round of substantive discussions began in late June 2025, focusing on goods tariffs, services, digital trade, and investment flows. The objective is to reduce trade barriers, promote investment and digital trade, and strengthen cooperation in strategic sectors such as renewable energy, green hydrogen, critical raw materials, and digital technologies. 

If concluded, it will be the first comprehensive free trade agreement between the EU and a member state of the Gulf Cooperation Council (“GCC”).
 

US-EU Trade update: US announces new country-specific reciprocal tariff rates and tariffs on copper, effective 1 August

The United States has formally notified various trading partners of its intention to introduce new country-specific reciprocal tariffs, effective from 1 August, unless a bilateral trade deal is reached beforehand. This marks a significant escalation in President Trump’s push for what he calls “balanced and fair trade.” The announcement follows the expiration of the 90-day pause on tariff changes on 9 July. Until 1 August, the White House has extended the pause on country-specific tariffs, maintaining the current 10% reciprocal tariff for all countries (with exceptions for Canada and Mexico).

From 1 August, the US will implement differentiated tariff rates based on each country’s perceived trade reciprocity. While some nations will face increased duties, others may benefit from reductions. Notable examples include:

• The EU will face a 30% additional tariff.
• Japan and South Korea will each face 25% additional tariffs.
• Cambodia and Laos face among the highest rates, at 36% and 40%, respectively.
• Brazil will be hit with a 50% additional tariff, with the US citing political instability following the prosecution of former President Bolsonaro as the reason for the increase.

The Trump administration has warned that any retaliatory measures by partner countries will be met with further tariff adjustments.

So far, the US has concluded trade deals with the UK, Vietnam, and China. It remains the US’s intention to finalize trade agreements with additional partners before 1 August.

EU Trade Commissioner Šefčovič maintains that the EU is committed to concluding a preliminary trade deal with the US prior to 1 August but has stated that President Trump’s letter informing the EU of the tariff increase from 20% to 30% has not been well received. He added that the EU should prepare for all possible outcomes, including a no-deal scenario with countermeasures.

Following Trump’s letter, EU Member States are discussing potential countermeasures. Key US exports that may be targeted include:

• Aircraft and parts
• Alcoholic beverages
• Agricultural goods
• Machinery
• Cars and car parts
• Chemicals and plastics
• Medical devices
• Electrical equipment
• Other industrial products

However, the EU has not yet officially communicated the list of HS codes that may be subject to countermeasures.

In addition to the country-specific reciprocal tariffs, the White House has announced a 50% tariff on copper imports. The official legislation detailing the specific conditions and any applicable exemptions has not yet been published.

Businesses engaged in cross-border trade are advised to closely monitor country-specific tariff schedules and ensure that supply chains and compliance systems are aligned with the upcoming changes. Further developments are expected in the coming weeks.