The European Union has established a new tariff regime for certain goods originating in the United States. Regulation (EU) 2026/1455, published on 30 June and applicable from 1 July 2026, introduces adjusted import duties and new tariff quotas for certain US products.
At Manuel Samper, we summarise the main measures and, in particular, the requirements that importers must take into account in order to prove US non-preferential origin and benefit from the new tariff measures.
What measures does Regulation (EU) 2026/1455 introduce?
The Regulation establishes different treatments depending on the goods included in its annexes:
Annex I: establishes a 0% import duty for a wide range of products and chapters of the Common Customs Tariff.
Annex II: provides that the ad valorem component of the Common Customs Tariff will not apply to imports of goods classified under the Combined Nomenclature (CN) codes listed in that Annex.
Annex III: opens tariff quotas at a 0% duty rate for certain agricultural goods and processed agricultural products, in accordance with the conditions laid down in the Regulation.
Proof of US origin: a key requirement
In order to benefit from these measures, it will be necessary to prove that the goods have US non-preferential origin. For the application of these duties, the European Commission has established the following document:
U190 - Proof of origin established in accordance with Article 6 of Regulation (EU) 2026/1455.
One of the most important aspects is that no standardised certificate or declaration of origin is required. The new Article 59a of Implementing Regulation (EU) 2015/2447, introduced by Implementing Regulation (EU) 2026/1422, maintains the principle of freedom of proof for establishing non-preferential origin.
According to the clarifications published by the European Commission, origin may be demonstrated by official documents issued by US authorities, declarations issued by the exporter, or declarations issued by other official bodies, provided that the documentation supplied makes it possible to verify the actual origin of the goods.
The Annex 22-14 certificate does not apply
It is important to note that the certificate of origin provided for in Article 57 and Annex 22-14 of the Implementing Regulation of the Union Customs Code cannot be used to claim the adjusted duties applicable to US goods.
This certificate is reserved for measures that specifically refer to Article 57, which is not the case with Regulation (EU) 2026/1455.
Stating “Made in the USA” is not sufficient
An indication such as “Made in the USA”, a statement of origin included on an invoice, or certain certificates issued by third parties does not, on its own, constitute sufficient proof of non-preferential origin.
The EU importer, as the declarant, must have sufficient evidence to establish the US origin of the goods and must also demonstrate that they:
• have been transported directly from the United States to the European Union; or
• have remained under customs supervision while in transit through third countries; or
• if they have been stored, divided or split during transit, have not undergone any processing other than that necessary to preserve them in good condition, or operations such as the affixing of marks, labels, seals or other documentation required to comply with the applicable requirements.
These rules will apply until the corresponding preferential rules of origin have been adopted.
For this reason, EU importers are advised to request the necessary documentation from their US suppliers in advance in order to properly demonstrate origin. Where sufficient evidence cannot be provided, it will not be possible to claim the application of these adjusted tariff measures.
Origin documentation becomes particularly important
The new regime may result in a significant reduction in import duties for numerous goods originating in the United States. However, its application is subject to compliance with the established requirements and, in particular, to having sufficient documentation to prove the origin of the products.
Before carrying out an import operation, it is advisable to check the tariff classification of the goods, verify whether they are included in any of the Annexes to the Regulation, and review the available proof of origin.
At Manuel Samper, we can advise you on the application of Regulation (EU) 2026/1455, tariff classification of goods, origin requirements, and the correct processing of your import operations from the United States.
