Updated for the EU-US deal effective July 1, 2026: most EU goods now pay a 15% all-inclusive ceiling instead of MFN + 10% Section 122. Run your EU landed cost →
The duty math on EU-origin goods changed on **July 1, 2026**, when the EU-US trade deal took effect. The old stack — MFN plus a 10% Section 122 surcharge — is gone for the EU. In its place: a **15% all-inclusive ceiling** on most goods (MFN included, no stacking; if your MFN rate is 15% or higher you pay MFN only), plus the usual 0.3464% MPF and 0.125% HMF on ocean arrivals. Steel, aluminum, and copper still carry the 50% Section 232 layer. And because the deal rate replaced Section 122 for the bloc, the July 24 Section 122 expiry doesn't touch EU imports. Below is the exact cost math on real shipments, not a rates overview.
What Actually Lands in Your Duty Bill
Three components on most EU shipments since July 1, 2026. First: the deal tariff — a 15% all-inclusive ceiling that covers the MFN base. If your product's MFN rate is below 15%, you pay a total of 15%; if MFN is 15% or higher, you pay MFN only, with no surcharge. Second: MPF at 0.3464% of entered value, minimum $31.67, maximum $614.35 per entry. Third: HMF at 0.125% on ocean arrivals only — air shipments skip it. Steel, aluminum, and copper are outside the ceiling and carry Section 232 at 50% instead. There's still no FTA-style preference claim that zeroes duty the way KORUS or USMCA does — the 15% ceiling is the deal rate, not a preference program — but from September 1, 2026, aircraft and parts, cork and other unavailable natural resources, and generic pharmaceuticals from the EU go to MFN-only treatment (typically 0%).
MFN Base Rates: Pull the 10-Digit HTS First
You can't quote duty on EU goods without the full HTS classification — chapter-level estimates will burn you. A German transmission housing at HTS 8708.40.1150 pays 2.5% MFN. The same chapter covers gearbox subassemblies at 8708.40.7580 which pay 2.5% too, but steering columns at 8708.94 pay 2.5% while airbags at 8708.95 pay 2.5% — all look similar, but misclassification triggers CBP reliquidation and penalty exposure. Italian leather handbags at HTS 4202.21 pay 9% MFN. French perfume at 3303.00.30 pays 0%. Get the ruling in writing from your customs broker or file a CBP ruling request for high-volume SKUs.
Worked Example: $30,000 French Wine Shipment
Take a $30,000 CIF container of French still wine under HTS 2204.21.50 — 750ml bottles, 15,000 liters total. Under the deal's 15% all-inclusive ceiling: $4,500 (the 6.3¢/L specific MFN duty is folded into the ceiling, not added on top). MPF at 0.3464% = $103.92 (above the $31.67 minimum, below the $614.35 cap). HMF at 0.125% = $37.50. Total duty: $4,641.42 — effective rate 15.5%. One caveat specific to this category: alcoholic beverages are one of the lines the deal leaves subject to further negotiation, so watch for a carve-out announcement. For comparison, the pre-July stack (MFN $945 + 10% Section 122 $3,000 + fees) came to $4,086.42 (13.6%), and the old 20% IEEPA regime cost $7,086.42 (23.6%). Always price to your specific product, not a generic rate — and if your MFN rate is 15% or higher, you pay MFN only under the deal.
MPF and HMF — Small Fees Everyone Forgets
MPF and HMF are not tariffs, but they hit every entry and they add up on big shipments. MPF is 0.3464% of entered value on formal entries, capped at $614.35 — so any shipment over about $177,345 caps out. Below $11,665 you pay the $31.67 minimum. HMF is 0.125% of entered value with no cap and no minimum, ocean arrivals only. Air freight skips HMF entirely, which matters for pharma and high-value electronics that ship by air. USMCA and KORUS preference goods still pay both fees — only a few specific programs (GSP historically, some Caribbean origin) carve them out. Budget MPF + HMF at roughly 0.47% of CIF value on ocean shipments.
Steel, Aluminum, and Copper — The 50% Outlier
Section 232 tariffs are legally separate from the deal — metals are explicitly left subject to further negotiation, so the 15% ceiling does not apply. EU steel and aluminum sit at 50% — doubled from 25% under Proclamation 10896 in June 2025. Copper was added at 50% in 2026. On $40,000 of Italian stainless steel tube under HTS 7304: MFN is 0% (steel is MFN-free), Section 232 steel is 50% ($20,000) — and nothing stacks on the metal content, so the article pays 50%, not more. Add MPF $138.56 and HMF $50 = $20,188.56 total duty, 50.5% effective rate. Derivative steel articles pay the 25% Section 232 tier on full customs value. Only the UK cut a carveout (25% under the Economic Prosperity Deal signed May 2025). Every EU member pays 50%. If you import metals from the EU, model the math before signing any 2026 PO.
The July 24, 2026 Section 122 Expiry — Why EU Buyers Can Ignore It
Section 122's 150-day statutory limit runs out July 24, 2026, and USTR's proposed replacement — 12.5% Section 301 duties on 46 countries — is due by July 20. If you buy from Asia, that's your rate cliff. If you buy from the EU, it isn't: the deal's 15% ceiling replaced Section 122 for EU-origin goods on July 1 and runs on its own framework with no expiration date. What EU buyers should watch instead: September 1, 2026, when aircraft and parts, cork, and generic pharmaceuticals from the EU drop to MFN-only (near 0% for most lines) — worth delaying non-urgent shipments in those categories — plus the still-open metals and alcohol negotiations. Any 6-month+ EU supply contract should carry a duty adjustment clause for those open categories. Price the scenarios in the scenario simulator before you lock in terms.
Claiming Refunds on Old IEEPA Duty
If you imported from the EU between April 2025 and February 24, 2026, you paid the 20% IEEPA reciprocal rate that SCOTUS struck down. You have a refund claim on the 20 points — and you generally don't need to litigate for it. Contrary to early predictions of a multi-year fight, CBP built the CAPE administrative refund process, live in the ACE Portal since April 20, 2026, with first ACH refunds around May 11-12, 2026. File a CAPE Declaration and preserve your CBP Form 7501s, ACE payment records, and commercial invoices for every entry; watch your liquidation deadlines. On $2M of annual EU imports at 20%, the refund exposure is $400,000 (plus statutory interest). Even a partial recovery is worth the effort.
Key Takeaway
EU import duty in 2026 is no longer a stack — it's a ceiling: 15% all-inclusive on most goods under the deal effective July 1, plus 0.47% combined MPF/HMF on ocean, with 50% Section 232 if it's steel, aluminum, or copper. If your MFN rate is 15% or higher you pay MFN only, and from September 1 aircraft, cork, and generic pharma go MFN-only entirely. The July 24 Section 122 expiry that's upending everyone else's math doesn't touch EU goods. Run your specific HTS through the landed cost calculator, keep IEEPA refund documentation, and re-check any entry filed since July 1 for the correct deal rate.
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