
Judgment in the Cloud: The future of risk and regulation with James Lord, Google Cloud
The Economic Prosperity Deal agreed between the UK and the U.S. sets out high level trade commitments and areas for further negotiation between the two countries. A series of implementing measures are described in Executive Order 14309 dated 16 June 2025 “Implementing the General Terms of the United States of America-United Kingdom Economic Prosperity Deal”. On 30 June 2025, various aspects of the trade deal came into force.
Timeline of UK and U.S. Trade Deal
On 8 May, the U.S. and UK announced their agreement to the general terms of a trade deal. This was published as the “General Terms for the United States of America and the United Kingdom of Great Britain and Northern Ireland Economic Prosperity Deal” (the “General Terms”). The General Terms did not include any broad change in the U.S.’s 10% baseline tariff on imports from the UK, in effect since 5 April 2025.
On 16 June, the White House issued Executive Order (“EO”) “Implementing the General Terms of the United States of America – United Kingdom Economic Prosperity Deal,” and an associated Fact Sheet. The EO enumerates a series of actions to implement the General Terms previously agreed upon by the two countries.
On 30 June 2025, various measures agreed upon in the General Terms came into effect. This includes UK motor manufacturers being able to sell up to 100,000 vehicles per year on the US market at a reduced tariff rate of 10%, (otherwise at 27.5%), and the removal of a 10% tariff on UK aerospace goods imports into the U.S.
Below we set out our key takeaways on the deal to date.
As agreed in the General Terms, on 30 June 2025 the UK removed its 20% tariff on imports of U.S. beef within a 13,000 metric ton (mt) quota (previously imports were subject to a 20% tariff within a quota of 1000 mt).1 In return, the U.S. has agreed to reallocate 13,000 mt of its existing “Other Countries” tariff rate quota for beef to the UK. Notably, the UK has not yet made any concessions on food safety and standards, reflecting a red line set out by the UK Government.2
As agreed in the General Terms, on 30 June 2025 the UK set a duty-free quota of 1.4bn litres for imports of U.S. ethanol.3 Previously, ethanol imported from the U.S. was subject to import duties of £8.50/100 litres.4
As of 30 June 2025, the U.S. has lowered tariffs on automotive imports, including automobiles and certain parts, from the UK. This is a reduction from the additional 25% across-the-board tariff that the U.S. imposed on automotives and auto parts in April this year.
The U.S. has established a quota of 100,000 vehicles as classified in heading 8703 of the Harmonized Tariff Schedule of the United States (“HTSUS”) which shall now be subject to a 10% tariff.
In addition, imports from the UK of certain automotive parts (those specified in note 33(g) to subchapter III of chapter 99 of the HTSUS) that would otherwise be subject to a 25% tariff are now subject to a 10% tariff. This applies provided that such parts are for use in automobiles that are products of the UK.5
Within the General Terms the U.S. committed to establishing a tariff rate quota for imports of aluminium and steel, as well as derivative steel and aluminium products, from the UK. The EO issued on 16 June 2025 states that the US Secretary of Commerce “shall design and establish a tariff-rate quota for steel articles and derivative steel articles that are products of the United Kingdom, consistent with the General Terms and the purpose of this order.” As of 4 July 2025, the details of this tariff rate quota are yet to be determined, however, leaders of both countries have confirmed they are “progressing towards 0% tariffs on core steel products”.6
On 3 June 2025, President Trump issued an EO imposing an additional 25% duty on steel and aluminium imports into the U.S. (bringing the overall rate to 50%). The UK was exempted from this additional rate. However, the EO provides that from 9 July 2025 onward, the U.S. may increase the tariff rate on steel and aluminium imports from the UK to 50%, if the UK “has not complied with relevant aspects of the [Economic Prosperity Deal].” This has been interpreted primarily as a concession to limit Chinese involvement in the production of steel and aluminium in the UK, and has been criticised by China’s foreign ministry.7
The General Terms state that both countries “intend to promptly negotiate significantly preferential treatment outcomes on pharmaceuticals and pharmaceutical ingredients.” However, this is expressed to be contingent on the UK’s compliance with supply chain “security requirements,” as well as the findings of the U.S. Section 232 investigation into the effects on U.S. national security of imports of pharmaceuticals and pharmaceutical ingredients (a power under the Trade Expansion Act of 1962, which may result in increased tariffs on imports of such products). The EO issued on 16 June 2025 reiterates this but does not provide any further details.
From 30 June 2025, subject to the EO issued on 16 June 2025, the U.S. has removed a 10% tariff on certain aerospace imports from the UK, such as aircraft engines and parts.
The UK and U.S. have agreed to cooperate in enhancing agricultural market access and supporting bilateral agricultural trade. Notably, within the General Terms, the two parties affirmed that “imported food and agricultural goods must comply with the importing country’s sanitary and phytosanitary standards [(“SPS”)] and other mutually agreed standards.” This in effect meant that the U.S. agreed to respect the more stringent SPS standards of the UK.
Furthermore, the UK and U.S. have each confirmed their intention to treat each other's conformity assessment bodies equally, with regards to procedures, standards (including the SPS), fees, and other requirements, as well as expanding the current Mutual Recognition Agreements (“MRAs”) by negotiating additional agreements.
The countries will also potentially discuss recognising specific sectoral standards as international standards.
Aside from the details set out in the text of the General Terms and subsequent actions, there have been additional announcements covering other sectors that could fall within the scope of future agreements, including:
In addition, the UK’s ambassador to Washington has confirmed that the UK is still seeking to negotiate down the 10% baseline tariff on U.S. imports from the UK.
Since the announcement of the General Terms, criticism has been raised that the Economic Prosperity Deal is not compatible with the UK and U.S.’s commitments under WTO rules.11 Under WTO rules, if a member country lowers tariffs for another WTO member country, it must do the same for all other WTO members. This is a core tenet of the WTO’s Most Favoured Nation (MFN) principle, since lowering tariffs only for one country would discriminate against others.
Under WTO rules, countries may offer preferential tariffs for individual partner countries, if such an agreement covers substantially all trade (i.e. a full free trade agreement). Whether the Economic Prosperity Deal is expanded to a comprehensive free trade agreement during negotiations will therefore determine the WTO legal compatibility of the deal.
Looking ahead, key aspects of the original agreement are still yet to be finalised, including the tariff rate quota system for UK steel and aluminium exports to the U.S. There is also a possibility that, subject to further agreements, the U.S. could raise the tariff on UK steel and aluminium to 50% from 9 July 2025.
The UK is also actively pursuing trade agreements with other partners, such as Turkey.12 Following the UK-EU Summit in May 2025, the UK has also agreed steps towards improving trade relations with the EU, notably on fishing rights, food exports and defence.13 These efforts signal a broader strategy to diversify the UK's global trade relationships post-Brexit.
Authored by Aline Doussin, Jonathan Stoel, Mike Jacobson, Josh Gelula, Chris James, Timothy Waitt, Mark Ye and Laurianne Strang.
Please reach out to any of the listed contacts should you require any advice on these trade agreements or any other international trade matters.
References
US UK EPD_050825_FINAL rev v2.pdf 4.(a)-(d)
See oral evidence of Professor Michael Gasiorek and Dmitry Grozoubinski at 14 May 2025 House of Lords International Relations and Defence Committee, https://committees.parliament.uk/oralevidence/15907/html/
https://www.gov.uk/government/news/update-on-uk-turkey-trade-talks
https://www.consilium.europa.eu/en/meetings/international-summit/2025/05/19/