Tariff Update: UK Tariffs Provide a Positive Model for Treatment of Aircraft Parts

Tariffs continue to be a hot topic in the news, and for aviation businesses. Recent tariff decisions suggest that aviation may see some relief from tariffs in the near future.

The Japan and EU agreements have both been reported in the press, but neither is yet available to the public. The EU agreement is particularly important because it will likely affect tariffs applicable to Airbus parts that are imported into the United States. While the EU agreement is not yet available, the UK agreement may shed some light on what we can expect from the EU agreement.

The recent UK agreement has been reflected in revision 16 to the 2025 HTSUS, and this provides us with some idea about how aviation is likely to be treated in the new tariff agreements (but it is no guarantee that other arrangements will include the same language). Under the UK agreement, civil aircraft parts will enjoy duty-free treatment and will be excepted from the chapter 99 country-based tariffs (currently found in HTSUS 9903.01.25 for products of the United Kingdom). This agreement will be limited to aircraft parts that are the product of the UK, but we are hopeful that ASA’s efforts will lead to a more general duty-free approach for most aircraft parts.

ASA filed formal comments with the United States earlier this summer, in which we explained that tariffs on aviation were a bad policy idea, and they were also a violation of U.S. law and U.S. treaty obligations. That concept has been endorsed in the UK agreement, and we are hoping that it will be endorsed in other agreements as well.

Aircraft parts that are products of the United Kingdom and that are entered on or after June 30, 2025 may be entered under HTSUS Subheading 9903.96.01 (in addition to the base tariff that applies to the underlying goods). This subheading allows for duty-free treatment of civil aircraft and their parts:

9903.96.01: Effective with respect to entries on or after [June 30, 2025], articles of civil aircraft (all aircraft other than military aircraft); their engines, parts, and components; their other parts, components, and subassemblies; and ground flight simulators and their parts and components of the United Kingdom, classified in the subheadings enumerated in subdivision (a) of U.S. note 35 to this subchapter.

This clause specifically exempts aircraft parts from the additional duties imposed by HTSUS subheadings 9903.01.25, 9903.81.94, 9903.81.96, 9903.81.97, 9903.81.98, , 9903.85.12, 9903.85.13, 9903.85.14, and 9903.85.15. This means that both the UK country-based 10% tariff and the UK steel and aluminum derivative tariffs appear to be excluded for aircraft parts. This is a positive sign for the aviation industry.

There is a list of the HTSUS subheadings that are affected by this exception, so please make sure your base tariff code is within the scope of the aircraft parts exception (the list is found in Chapter 99: U.S. Note 35(a)). Note that while this list includes many tariff subheadings typically associated with aircraft parts, you should identify your specific tariff codes to make sure that they are included before assuming that the exception applies to your imports.