The new measures are viewed as a "deterioration" in trade conditions. Analysts suggest that the only viable path forward is to lobby for these sectors to be included under the 15% "cap" established in the EU-US Framework Agreement of 21 August. Without such an adjustment, Italian components and machinery manufacturers risk losing significant market share in their most vital overseas market.
A new analysis of the US Section 232 tariff regime (Proclamation 11021) reveals a challenging landscape for Italian exporters. Following the implementation of the measures on 6 April, trade associations report widespread concern over increased costs, complex traceability requirements, and a fundamental shift in how customs duties are calculated.
The new framework affects 979 tariff lines, with 924 directly impacting Italian exports, representing 21% of the total export value to the United States. Key findings from the analysis include:
- Average Increases: Tariff hikes range from 2% to 50% across the affected categories.
- Weighted Average: The weighted average tariff has risen by 3.3%, climbing from 20.2% to 23.5%.
- Specific Impacts: The weighted duty for impacted lines has increased between 1% and 7%. Notably, "Torque converters" (HTSUS 84834050) – a vital export item – recorded a 7% weighted increase, reflecting a 20% jump from previous levels.
- Sector Peaks: Dramatic increases have hit consumer and industrial goods, such as non-stick pans (+25%), tableware and kitchenware (+34%), and turbochargers (+22.1%).
A major point of contention is the shift in the tax base. Duties are now calculated on the entire value of the product rather than just the incorporated metal content. This change is particularly damaging for machinery and complex equipment.
Exporters face a "commercial barrier" if they cannot prove the origin ("melt and pour" or "smelt and cast") of the metals used. Failure to provide this documentation can trigger punitive rates of up to 200%, especially for products containing aluminium.
Italian agricultural machinery, a hallmark of "Made in Italy," is facing a severe crisis. Because these machines typically contain more than 15% steel or aluminium, the 25% duty applies to the total machine value.
- Specialised Tractors: For tractors in the 20-100 HP range (orchard and vineyard types), the duty adds thousands of euros to the price tag, making them nearly unmarketable.
- Market Context: This comes after a difficult 2025, which saw a 10% drop in US tractor sales and a 31% collapse in Italian agricultural exports to the US, pushing the United States behind France and Germany in export rankings.
- Uncertainty: Significant confusion remains regarding the inclusion of transport, insurance, and packaging in the "customs value," as well as how "door-to-door" courier shipments for spare parts should be treated.
The business community has highlighted several operational "grey areas":
- Traceability: Many firms lack "melt and pour" data, and the lack of clear US Customs and Border Protection (CBP) guidelines exacerbates the risk of misapplication.
- Mixed Products: It remains unclear how duties are applied when a product contains multiple metals (steel, aluminium, copper) subject to different rates.
- US Content Restrictions: Reduced rates for US-sourced metals are difficult to access because the "metal content" must be entirely of US origin; any trace of foreign metal disqualifies the product.