New US Tariffs: What UK Exporters Need to Know

US Trade Policy · Regulatory Update

New US Tariffs Just Landed — Here's Why It's Not the Emergency the Headlines Make It Sound Like

If your inbox this morning had three different "BREAKING: Trump slaps new tariffs" emails in it, you're not alone, and you don't need to reply to any of them yet. For almost everyone reading this, the actual number you deal with hasn't moved. What's changed is the law behind it — which affects how long the tariff can survive a legal challenge, not what you pay on Monday. There are two things genuinely worth ten minutes of your time, and they're below.

What Happened

Just after midnight US time, the Trump administration replaced its temporary global tariff with a new set of tariffs on 60 trading partners, covering nearly everything the US imports. The official justification is forced labour enforcement: USTR concluded that none of the 60 economies it investigated has an effective ban on importing goods made with forced labour, and has added a tariff on top of whatever each country already pays as a result.

How We Got Here

This is the third distinct version of Trump's tariff regime this year, not an isolated announcement:

2026 Timeline

  • February 2026 — the Supreme Court rules that Trump's original global tariffs, imposed under emergency-powers legislation (IEEPA), exceeded his legal authority.
  • Same day — the administration imposes a temporary 10% global tariff under a different law, Section 122 of the Trade Act 1974, capped at 150 days.
  • March 2026 — USTR opens two Section 301 investigations: one into forced labour enforcement across 60 economies, another into manufacturing overcapacity across 16.
  • June–July 2026 — findings are published, rates proposed, and public hearings held.
  • Today — the Section 122 tariff hits its 150-day limit and expires. The new Section 301 forced-labour tariffs take effect in its place.

So: the original IEEPA tariffs, the Section 122 stopgap, and now this — three regimes in five months. This one is built on a statute that's harder to challenge in court than the first was, which is the real headline for anyone tracking durability rather than the day's number.

The headline point for UK businesses: the UK rate stays at 10%, exactly where it's been since February. The tariff hasn't gone up. It's standing on sturdier legal ground.

The Rates, By Country

Rate Who Basis
10% UK, Canada, Mexico, India, Argentina, Bangladesh, Cambodia, Ecuador, El Salvador, Guatemala, Honduras, Indonesia, Jordan, Malaysia, Pakistan, Sri Lanka, Trinidad & Tobago Have a forced-labour import ban, have committed to one via a Reciprocal Trade Agreement, or enforce a partial regime
10–12.5%* EU, Japan, South Korea, Switzerland, Taiwan Calculated against each product's existing US tariff rate, not a flat figure
12.5% The remaining 38 economies investigated No forced-labour import prohibition in place

*The EU/Japan/Korea/Switzerland/Taiwan figure moves by product — don't quote a single number for these five without checking the specific goods.

Who Actually Pays For This

Import tariffs are collected from whoever imports the goods, at the point they cross the border. On a standard UK-to-US sale, that's your customer: under most Incoterms — FOB, FCA, CIF, DAP, and the rest — the buyer takes on import clearance and any duties once the goods land. You've quoted your price, the goods have left, and this tariff is a conversation between your buyer and US customs, not you.

The exception is DDP.

How DDP Works, and Why It Changes the Calculation

Delivered Duty Paid flips the standard arrangement. As the seller, you agree to get the goods all the way to the buyer already cleared through import — which means the import duties, this tariff, and import VAT all sit with you rather than the buyer.

Worth heading off directly: DDP does not automatically make you responsible for unloading at the final destination. That stays with the buyer by default unless your contract states otherwise.

There are good commercial reasons to quote DDP — it's a smoother experience for the buyer, it can be a genuine differentiator, and some buyers won't agree to anything else. It also carries two costs worth naming plainly. First, exactly the exposure today's news creates: if a tariff rate moves and you're on DDP, your margin absorbs it unless you've priced in room for that. Second, a practical requirement specific to DDP into the US — non-US entities generally can't act as their own importer of record without a US presence, so you need a customs broker or agent already positioned to handle that on your behalf. If you're quoting DDP to American buyers without that arrangement confirmed, that's worth fixing regardless of what happens with tariffs.

What to do: if any live contracts are on DDP terms into the US, update your landed-cost figures to reflect the current rate, and confirm your import-of-record arrangement is actually in place.

Where This Actually Changes Something: Origin, Not Export Country

US tariffs are assessed on where a good was made, not where it was shipped from. Goods genuinely made in the UK get the UK's 10%, without qualification. But if you're reselling something manufactured elsewhere, repackaging or relabelling it in the UK does not change where US customs considers it "from."

Worked Example: Anglia Fittings Ltd

Anglia Fittings sources precision-machined brackets from a manufacturer in Germany. The goods are repackaged and relabelled at Anglia's own UK warehouse before a $50,000 order ships to a US customer on DDP terms.

  • The assumption: because the goods left the UK, the 10% UK rate applies. Tariff at that rate: $5,000.
  • The reality: repackaging and relabelling do not meet the "substantial transformation" test that changes a good's country of origin for customs purposes. The brackets remain German-origin, placing them in the EU band rather than the UK's.
  • The correct figure: at 12.5% for this product, the tariff is $6,250.
  • The gap: $1,250 that didn't appear in Anglia Fittings' original costing — invisible until someone checks the origin paperwork instead of assuming that shipping from the UK means paying the UK rate.

Repeated across a year of similar orders, that gap becomes a material cost, and an entirely avoidable one.

Does This Stack With the Steel Tariffs We Covered Earlier This Year?

If you already handle steel or aluminium under Section 232 tariffs, you're not paying twice: USTR's notice explicitly exempts Section 232 goods from this new tariff. Oil, gas, fertiliser, and goods qualifying for USMCA duty-free treatment (Canada/Mexico) are excluded as well.

FAQs

Do I need to reissue invoices?

No, unless you're on DDP and adjusting pricing to reflect it. This is collected at the US border, not something that touches your commercial invoice.

What about goods already in transit?

USTR's notice does not specify a grace period for shipments already on the water. If you have stock heading to the US right now, confirm the position with your broker or carrier rather than assuming either way.

Does this affect UK-EU trade?

No. This is a US import measure with no bearing on UK-EU trade under the TCA, and it's unrelated to the EU's low-value parcel duty or the steel safeguard quotas covered here in June and July.

What You Actually Need to Do

For most UK exporters selling UK-made goods on ordinary Incoterms: nothing, today. Two situations do need ten minutes of attention — DDP contracts with US customers, and any product lines where the goods aren't genuinely UK-origin. The excess-capacity investigation into 16 economies referenced above is still unresolved, so treat this as an update rather than the final word; we'll cover the next stage once USTR concludes it.

Full official detail: USTR's Section 301 forced labour fact sheet.

Selling to the US? Make Sure Your Tariffs and Your Terms Line Up

Today's changes sit at the exact intersection of two things worth getting right before your next US shipment: how US tariffs and origin rules actually work, and which Incoterm decides who pays them. Our half-day courses cover both.

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