Every US buyer of EU-origin goods pays the same four line items at entry — 10% Section 122, the MFN base rate tied to the 10-digit HTS, 0.3464% MPF, and 0.125% HMF if it arrives by ocean. Steel, aluminum, and copper add a 50% Section 232 layer on top. The 10% Section 122 number replaced the 20% IEEPA rate after the Supreme Court ruling on February 20, 2026 — and it expires around July 24, 2026 unless Congress extends it. Below is the exact cost math on real shipments, not a rates overview.
What Actually Lands in Your Duty Bill
Four components, every time. First: the MFN base rate — set by Congress, tied to your product's 10-digit HTS, running 0% on most electronics to 6.3¢/L on still wine to 12% on some footwear. Second: 10% Section 122, flat on every country including the EU, on top of MFN. Third: MPF at 0.3464% of entered value, minimum $31.67, maximum $614.35 per entry. Fourth: HMF at 0.125% on ocean arrivals only — air shipments skip it. Steel, aluminum, and copper add Section 232 at 50%. No EU member has an FTA with the US, so there's no preference claim to erase the MFN base — unlike Korea (KORUS) or Canada/Mexico (USMCA).
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. MFN is specific, not ad valorem: 6.3¢ per liter = $945. Section 122 at 10% = $3,000. MPF at 0.3464% = $103.92 (above the $31.67 minimum, below the $614.35 cap). HMF at 0.125% = $37.50. Total duty: $4,086.42 — effective rate 13.6%. Under the old 20% IEEPA regime, the same container paid $7,086.42 (23.6%) — MFN $945 + IEEPA $6,000 + fees. The SCOTUS ruling saved this importer $3,000 per container. Run $30,000 of Spanish olive oil at HTS 1509.10 (3.4¢/kg + 10% Section 122) and the math shifts again — always price to your specific product, not a generic rate.
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 Section 122 and were not touched by the SCOTUS ruling. 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 122 is 10% ($4,000), Section 232 steel is 50% ($20,000), MPF $138.56, HMF $50 = $24,188.56 total duty, 60.5% effective rate. 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 Expiration
Section 122 of the Trade Act of 1974 has a 150-day statutory limit from its February 24, 2026 effective date. That's approximately July 24, 2026. Three scenarios. One: Congress lets it lapse — most EU goods drop to MFN only, typically 0-6% total duty, and that $30,000 French wine container pays $945 + fees = about $1,086 total instead of $4,086. Two: Congress extends at 10%. Three: Congress passes a higher permanent rate, likely tied to Section 301 investigations USTR opened March 11, 2026. Any 6-month+ EU supply contract signed in April 2026 needs a duty adjustment clause. Price all three 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 may have a refund claim on the 20 points. The administration has signaled it won't voluntarily refund — Trump said the question 'has to get litigated for the next two years.' Preserve your CBP Form 7501s, ACE payment records, and commercial invoices for every entry. File protests within 180 days of liquidation and consult a trade attorney about broader refund litigation. On $2M of annual EU imports at 20%, the refund exposure is $400,000. Even a partial recovery is worth the filing fee.
Key Takeaway
EU import duty in 2026 is a stack: 10% Section 122 + MFN for your HTS + 0.47% combined MPF/HMF on ocean + 50% Section 232 if it's steel, aluminum, or copper. No FTA exists between the US and EU, so there's no preference claim to zero the MFN base. The headline rate is meaningfully lower than it was in January 2026, but July 24 changes everything. Run your specific HTS through the landed cost calculator, keep IEEPA refund documentation, and price your 2026 contracts to handle the expiration.
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