15 December 2025

Trade Talking Points | Latest insights from EY's Trade Strategy team (12 December 2025)

Executive summary

This edition of Trade Talking Points provides updates on trade policy announcements from the United States (US) and European Union (EU), as well as the United Kingdom (UK) Government's 2025—2026 tariff suspension window.

Latest US trade policy announcements

UK-US pharmaceutical deal

On 1 December 2025, a UK Government press release announced that the United States had agreed to exempt UK-origin pharmaceuticals, pharmaceutical ingredients and medical technology from potential tariffs levied under Section 232 of the Trade Expansion Act.

The US also committed not to target UK pharmaceutical pricing practices in any potential Section 301 Trade Act investigation into unfair trade practices for the duration of President Trump's term.

Further operational details of the deal remains outstanding.

Operational detail of the US-Korea Strategic Trade and Investment Deal

On 3 December 2025, a US Federal Register notice was released outlining "Certain Tariff-Related Elements of the US-Korea Strategic Trade and Investment Deal."

The notice outlines the operational amendments made to the Harmonized Tariff Schedule of the United States (HTSUS). Key components include:

  • South Korean products with an HTSUS most-favored nation (MFN) duty rate greater than or equal to 15% ad valorem will have an additional tariff rate of 0%
  • South Korean products with an HTSUS MFN duty rate of less than 15% ad valorem will have a combined HTSUS + tariff rate of 15%
  • All existing exemptions from tariffs on South Korean products, as outlined in International Emergency Economic Powers Act (IEEPA) Annex II, will remain in effect

US Investigation into alleged security risks from price fixing and anti-competitive behavior in the food supply chain

On 6 December 2025, the US Trump Administration introduced an Executive Order (EO) authorizing the creation of two "Food Supply Chain Security Task Forces," led by the Department of Justice and the Federal Trade Commission.

Both task forces will investigate food-related industries to determine whether corporations or foreign countries are undertaking anti-competitive behavior to increase the cost of food products in the US or create broader national or economic security threats.

The EO states that both investigations are required due to an increase in civil litigation linked to anti-competitive practices across the domestic meat processing, seed, fertilizer and equipment sectors.

The task forces will be required to brief Trump Administration leadership within 180 days of the EO's release (by 4 June 2026) regarding their findings and proposed recommendations.

Latest EU trade policy announcements

Agreement to revise the EU Generalized Scheme of Preferences (GSP)

On 1 December 2025, the European Commission, European Council and the European Parliament announced the bloc's intention to revise the Generalized Scheme of Preferences (GSP), which removes import duties from products entering the EU market from developing countries.

The GSP will continue to support sustainable trade and development of 65 GSP beneficiary countries; however, it will now place a greater emphasis on other emerging economic development needs for countries such as social, labor, environmental, migration and climate requirements.

Potential revisions to the GSP would:

  • Establish a clear transition pathway for GSP beneficiary countries that are progressing their development status — permitting them to retain preferential EU market access where they meet set sustainability standards
  • Create more commercial opportunities for low-income countries by lowering product graduation thresholds
  • Promote stronger human rights and labor standards by adding new conventions to the list of required compliance
  • Introduce the ability to withdraw benefits for environmental and climate breaches
  • Improve monitoring, transparency and civil society involvement, and introduce an urgent withdrawal procedure
  • Make beneficiary countries responsible for readmitting their own nationals in case of illegal migration issues

Implementation details are expected to be introduced shortly.

European Commission joint communication on strengthening economic security

On 3 December 2025, the European Commission and the High Representative released a joint communication on the framework to mitigate risks to the EU's ongoing economic security.

The communication outlines six priority high-risk areas:

  1. Reducing strategic dependencies for goods and services
  2. Attracting safe investment into the EU
  3. Supporting a vibrant European defense and space industry, and other critical industrial sectors
  4. Securing EU leadership across critical technologies
  5. Protecting sensitive information and data
  6. Shielding Europe's critical infrastructure

The communication expands on the 2023 Economic Security Strategy, which established the EU's overarching economic security objectives, including promoting industrial strengths, protecting EU interests and partnering with like-minded countries.

Latest UK trade policy announcements

UK closing duty suspension/autonomous tariff quota window in early 2026, also seeking input on allowing extensions through 2028

The UK Government, on 4 February 2026, will close the application window for businesses seeking temporary duty suspensions and autonomous tariff quotas (ATQs) for goods imported into the UK.

Duty suspensions allow in-scope goods to be imported into the UK at a reduced tariff rate. ATQs allow set quantities of in-scope goods to be imported at a reduced rate.

To apply for a new suspension, businesses should complete the UK Government's application form — 2025-26 Application Form for New Duty Suspensions.

In parallel, the UK Government is also soliciting views from businesses on whether active duty suspensions and ATQs set to expire on 31 December 2026 should be extended until 31 December 2028. According to the UK Government, approximately 290 suspensions implemented during the 2021 and 2023 application windows are due to expire on 31 December 2026.

To review the status of a suspension or ATQ, businesses should access the Trade Tariff Tool and review the current statutory guidance. To request an extension, businesses should complete the UK Government's feedback form: Extension feedback form on duty suspensions due to expire in 2026.

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Contact Information

For additional information concerning this Alert, please contact:

Ernst & Young LLP (United Kingdom), London

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2025-2510