The significant tariffs introduced by the Trump administration on 2 April 2025 have caused unprecedented disruption to the global economy. US imports of most UK goods will now be subject to an additional 10% tariff, with the EU sustaining 20% and China 34%. There are a variety of responses from the targeted countries, ranging from China's introduction of 34% counter tariffs on US imports; EU Member States convening to consider their own retaliatory measures; to Japan securing priority tariff negotiations with the US administration.

Moving at perhaps a more considered (or slower) pace, the UK Government is also considering its options, including counter-tariffs. To that end, the UK Department for Business & Trade has launched a consultation for businesses which import or consume US-origin goods to provide evidence on the impact that additional tariffs would have on UK businesses, consumers and economy.[1]

The Consultation includes a list of US products that are most likely to be subject to tariffs, but which are designed to cause a limited impact on the UK economy. The UK Government is also engaging separately with industries and stakeholders on the impacts of US tariffs.

The Consultation will run for a period of four weeks and will close on 1 May 2025.  

1. Why has the UK government launched the consultation?

1.1 On 2 April 2025, President Donald Trump issued an Executive Order introducing 'reciprocal' tariffs on all of the US' trading partners. For the UK, this means that importers of almost all UK goods[2] into the US will be required to pay an additional 10% tariff on the value of these goods.  The new tariffs entered into force on 5 April 2025.

1.2 These tariffs are in addition to other US tariff measures introduced in March 2025, including:

  1. 25% tariffs on steel and aluminium imports from the UK, which were reintroduced on 12 March 2025; and
  2. 25% tariffs on imports of automotives and automotive parts, which were introduced on 12 March 2025.  

1.3 The UK Government has stressed that its preference is to negotiate a solution with the US, including through an "economic deal" between the two countries.  However, the Government is continuing to explore all its options in responding to the reciprocal tariffs, including retaliatory measures in the form of additional tariffs on imports of US goods into the UK. The Consultation seeks input from businesses on the possible impact of such retaliatory measures.

2. What is covered by the consultation?

2.1 The Government is seeking comments as to the impact of additional tariffs on all US-origin goods. The Government has also published an 'Indicative Long List' of US products which are most likely to be subject to any such tariffs.[3]

2.2 Products included on the Indicative Long List are listed by reference to their commodity code, and include, for example:

  1. agricultural produce, including animal and vegetable products and prepared foodstuffs;
  2. mineral products;
  3. plastics;
  4. textiles and articles of clothing;
  5. metals, including iron and steel products;
  6. machinery and mechanical appliances; and
  7. automotives and associated parts.

2.3 The Government considers that the products identified in the Indicative Long List comprise approximately 27% of UK imports of US-origin goods and will have a "more limited impact on the UK" if they were subject to additional tariffs.    

3. How should businesses respond to the consultation?

3.1 The deadline for businesses to respond to the Consultation is 23:49 on 1 May 2025.

3.2 The Government has stated that it will welcome responses from all stakeholders who import or consume US products and who may be affected by the application of potential UK tariff measures. In responding to the Consultation, businesses should provide evidence on the possible impacts, including costs and benefits, of any tariffs imposed by the UK on imports of UK goods. This evidence should cover the impact on: (i) businesses; (ii) consumers; and (iii) the economy.

If you have any questions about the topics raised in this alert, including in relation to responding to the Consultation, or on how tariffs may affect your business more generally, please contact Gowling WLG's International Trade and Customs Team.

Footnotes

[1] The Consultation is available at: How to input on potential UK tariff measures in response to US tariffs - Request for input description.
[2] The Executive Order excludes certain categories of goods from the reciprocal tariffs, including copper, pharmaceuticals, semiconductors, lumber, certain critical minerals and energy and energy products.
[3] The 'Indicative Long List' is available at: How to input on potential UK tariff measures in response to US tariffs - Indicative product list documents.