US trade policy update: What you need to know after the summer break

Webinar

To help Swedish companies navigate these evolving requirements and enforcement risks, Business Sweden is hosting a webinar on 8 September at 2pm CET (8am ET). 

Register here. 

New Section 301 tariffs: EU goods capped at 10 per cent

New Section 301 tariffs linked to forced labour took effect on 24 July 2026, replacing the temporary Section 122 framework and introducing country-specific rates of 10 or 12.5 per cent. For EU-origin goods, the practical impact may be more limited. The combined Most Favoured Nation (MFN) and Section 301 rate is typically capped at 10 per cent. Where the MFN tariff is below 10 per cent, the Section 301 duty acts as a top-up to reach that ceiling. Where the MFN tariff is already 10 per cent or higher, no additional Section 301 duty applies.

Importantly, not all EU goods are subject to the new tariffs. The Office of the United States Trade Representative (USTR) has established a range of product-specific exemptions, including certain raw materials and products where tariffs could disrupt US supply, such as critical minerals and agricultural goods. Products already subject to Section 232 tariffs are also exempt from the new forced-labour Section 301 duties. In these cases, the applicable Section 232 framework determines the additional tariff treatment.

Swedish companies should review whether their products are covered by the new measures, assess applicable exemptions, and understand how the Section 301 and Section 232 frameworks interact.

Section 301 stacking rules – examples for an EU-origin metal derivative product

New Section 232 tariffs: Polysilicon and unmanned aircraft systems

On 6 August 2026, the US announced new Section 232 measures covering polysilicon and downstream products used in semiconductor and solar supply chains. From 4 December, covered imports will face product-specific minimum import prices, with certain polysilicon derivatives also subject to a 15 per cent tariff. The administration also introduced Section 232 tariffs on unmanned aircraft systems (UAS), or drones, and selected components. Most measures will take effect on 3 September 2026, with a separate tariff on other specific components following in February 2027.

For EU-origin products in these scopes, the combined MFN and Section 232 rate is capped at 15 per cent, consistent with the EU-US trade framework.

With several investigations still ongoing, the immediate impact is concentrated in specific industries. However, the broader trend suggests that Section 232 is increasingly being used as a wide-ranging trade policy tool. Swedish companies in affected sectors should review their product classifications, origin, and tariff exposure, and monitor ongoing investigations that may further expand the scope of Section 232.

USMCA renewal and tensions: Canadian sourcing is no longer a low-risk assumption

US-Canada trade tensions intensified following the July 2026 review of the United States-Mexico-Canada Agreement (USMCA), when the US declined a new 16-year extension and opted to continue negotiations. After the two sides failed to reach an agreement, 50 per cent Section 338 tariffs on approximately 5 per cent of Canadian goods took effect on 22 August, including some USMCA-qualifying products. Section 232-covered goods remain excluded, along with certain categories such as energy and potash. Canada has since suspended further trade negotiations and announced retaliatory tariffs on US goods, effective 8 September, further increasing uncertainty around North American trade.

For Swedish companies, the immediate impact is concentrated in a narrower set of Canadian imports, but the broader policy direction remains uncertain. Companies with supply chains routed through Canada should verify their exposure to the new duties, monitor further developments, and prepare for potential escalation or de-escalation. 

US steps up enforcement against tariff circumvention

The White House released The Great Transshipment Scam on 13 August 2026, increasing scrutiny of Chinese-origin goods routed through third countries. The report highlights practices such as minor processing, repackaging, or relabelling used to evade higher US tariffs. It identifies more than 40 lower-tariff jurisdictions with potential exposure and highlights Mexico, India, and Vietnam among the largest transshipment hubs. The EU is also identified as having significant China-linked trade, although it is not among the report’s largest hubs.

The report builds on the administration’s broader push to strengthen customs enforcement, including the 3 June Executive Order. To combat tariff circumvention and detect fraud, the administration proposes AI screening tools for use by CBP. For Swedish companies, this means greater focus on country-of-origin verification and supply chain transparency. Supporting documentation will be particularly important where goods or components move through multiple jurisdictions before entering the US.

If a shipment is flagged, even incorrectly, importers should be prepared to substantiate the declared origin and supply chain structure with complete and readily available documentation. Exporters with transparent and well-documented supply chains may be able to use this as a competitive advantage in customer dialogues.

Monitor:

• Ongoing Section 301 investigations, including excess capacity across 16 economies, Vietnam-related IP concerns, and German pharmaceutical pricing
• Proposed expansion of Section 232 metal derivative measures, potentially leading to tariffs on 14 new product categories (find the public comment page here, due 27 August)
• Potential Section 232 measures on commercial aircraft, jet engines, and related parts, as the US is pursuing negotiations with trading partners and could impose tariffs or other import restrictions
• Implementation of the Section 338 tariffs and potential Canadian retaliation
• New CBP enforcement initiatives, especially those related to origin verification, transshipment enforcement, and supply chain documentation requirements

Plan and act:

• Strengthen import documentation, supplier declarations, and traceability processes to prepare for increased scrutiny of origin claims and supply chains
• Engage key suppliers to confirm origin substantiation, production capacity, and supporting documentation in preparation for increased CBP enforcement
• Verify Harmonized Tariff Schedule (HTS) classifications and Section 232 applicability for key products to identify where existing or expanded tariff measures may apply
• Conduct scenario planning for supply chains exposed to ongoing Section 301 and Section 232 investigations to assess potential future duty exposure
• Develop contingency plans for tariff increases and enforcement actions, including alternative sourcing strategies, contract reviews, pricing adjustments, and customs compliance procedures

Get in touch

To broaden support, Business Sweden launched the US-Sweden Tariff Intelligence and Advisory together with the Embassy of Sweden in the US in 2025. The platform includes:

• Tracking tariff developments and providing implementation tools
• Enabling peer learning through virtual sessions and expert-led seminars
• Connecting companies with vetted customs brokers and third-party logistics partners

Business Sweden has extensive experience in tariff scenario analysis, localisation strategies, and supplier evaluations. If you need support assessing your supply chain, navigating the impact of these tariffs on your US operations, or joining the US-Sweden Tariff Intelligence and Advisory, please contact Johan Karlberg or Felicia Stéen. 

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