EU Proposes Tariff Targets – Some (But Not All) Aircraft Parts Would be Affected

The European Union has published an updated list of proposed tariff targets. The title of this list is “List of the products originating in or from the United States which could be subject to possible commercial policy measures.” The link is to version 1.1 so be wary that the EU could further update this list.

The EU is seeking public comment on their proposed list of tariff targets. If the negotiations between the US and the EU do not yield an elimination of the duty imposed on all products of the EU, then the EU could implement these tariffs to impose a duty on products of the United States.

The proposed list is estimated to reflect imports from the US worth €95 billion.

The proposed list includes complete aircraft under headings 8802 (helicopters and airplanes) and 8806 (unmanned aircraft). Aircraft parts under heading 8807 are NOT included on the proposed list.

It is important to remember that many aircraft parts are NOT classified under heading 8807 because there is a more specific tariff heading that applies to them. Some aircraft parts would be affected by the proposed EU reciprocal tariffs. For example, the following aircraft parts classifications are included on the EU tariff proposal (this is a list of examples and is not meant to be exhaustive):

Tariff SubheadingDescription
40113000 new pneumatic tires, of rubber, of a kind used for aircraft
40121300 retreaded pneumatic tires, of rubber, of a kind used on aircraft
70071190toughened “tempered” safety glass, of size and shape suitable for incorporation in aircraft, spacecraft, vessels or other vehicles
85443000 ignition wiring sets and other wiring sets for vehicles, aircraft or ships
90142080 instruments and appliances for aeronautical or space navigation (excl. inertial navigation systems, compasses and radio navigational equipment)
91040000 instrument panel clocks and clocks of a similar type for vehicles, aircraft, vessels and other vehicles
94019110parts of seats used for aircraft, of wood, n.e.s
94019910 parts of seats used for aircraft, n.e.s.

The EU has explained its position in a press release.

About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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