New US and EU tariffs tied to Iran and Greenland: what’s real and what’s not (yet)

Over the past several days, headlines, social posts, and public statements have circulated claims about sweeping new US and EU tariffs; specifically; tariffs tied to Iran and Greenland. These reports have included references to new US tariffs on countries trading with Iran, new US “Greenland” tariffs on EU goods, and EU retaliatory tariffs in response. And all of this is in the midst of EU removing it’s de minimis exemption alongside the UK discussion of  de minimis removal.

At this point, none of these measures are officially enacted or live. There has been no formal publication by the relevant US or EU authorities that would make these tariffs enforceable.

This update is intended as a factual checkpoint on where things stand today.

Are new US tariffs related to Iran or Greenland currently in effect?

No. Despite widespread reporting, no new US tariffs related to Iran or Greenland are currently enforceable.

For US tariffs to become active, a formal legal process must occur. This includes either an Executive Order issued by the White House or legislation passed by Congress, followed by publication in the Federal Register. Only after that step do regulatory agencies, including U.S. Customs and Border Protection, issue operational guidance.

CBP communicates tariff implementation details through Cargo Systems Messaging Service (CSMS) notices, which explain how new measures will be interpreted and enforced at the border. As of today, no CSMS notices have been issued related to:

• A proposed 25% US tariff on countries trading with Iran

• Proposed US tariffs tied to Greenland

Without these steps, these tariffs remain proposed or discussed concepts only, not enforceable trade actions.

What about reports of US “Greenland” tariffs starting February 1?

Recent reporting suggests the US may introduce a 10% tariff on EU goods linked to Greenland starting February 1, with a potential increase to 25% the following month. While this scenario has been publicly discussed, it has not yet been formalized through any published Executive Order or CBP guidance.

Until such measures are legally issued and operationalized through CBP, they do not apply at import.

Is the EU implementing retaliatory tariffs in response?

Not yet.

In the EU, trade policy must be formally adopted by the European Parliament and the European Council, followed by official publication and enforcement guidance. That process has not been completed in response to US tariff threats tied to Greenland.

That said, the EU has confirmed it is reassessing previously suspended countermeasures on US goods.

What’s happening with the EU–US trade deal and suspended tariffs?

In July, the EU and US reached a framework agreement that paused EU retaliatory tariffs on approximately $109B of US goods while negotiations continued. The official suspension is documented in Commission Implementing Regulation (EU) 2025/1727

Unless the pause is extended or a final trade agreement is approved, those suspended tariffs would automatically come back into force on February 7, 2026. Additional EU guidance confirms:

• Existing countermeasures from 2018 and 2020 would resume

• Negotiations are underway to potentially expand measures in response to US steel and aluminum tariffs

The EU has also reiterated that no finalized US–EU trade deal currently exists, only a framework. And there is talks of announcing a suspension the trade deal on Wednesday January, 21st 2026.

Could the EU use non-tariff measures instead?

In parallel with tariff discussions, EU officials have raised the possibility of invoking the Anti-Coercion Instrument (ACI), established under Regulation (EU) 2023/2675.

The ACI, which entered into force on December 27, 2023, is designed to respond when a non-EU country attempts to economically coerce the EU or a member state. While it has never been used, the framework allows the EU to escalate responses if coercion is formally determined and international resolution fails.

Potential response measures could include tariffs, import or export restrictions, limits on access to public programs or financial markets, intellectual property measures, or foreign direct investment controls. Any use of the ACI would be without precedent.

Bottom line

Despite significant media attention, no new US or EU tariffs related to Iran or Greenland are currently live. No Executive Orders, Federal Register notices, CBP CSMS messages, or EU implementing regulations have been published to activate them.

Tariffs only become enforceable once they move from public statements into formal legal and regulatory channels. We’re continuing to monitor official publications and will share updates as soon as anything is formally enacted.

FAQ

Are there any new US tariffs I need to account for today?

No. There are currently no new US tariffs related to Iran or Greenland in effect. Existing tariff structures remain unchanged.

Do social media announcements or political statements trigger tariffs?

No. Tariffs only apply after formal legal steps are completed and published, followed by regulatory guidance from enforcement agencies.

Will EU retaliatory tariffs automatically apply if talks fail?

Only if the EU allows suspended measures to resume and publishes final product lists and enforcement guidance. Until then, they are not enforceable.

What is the Anti-Coercion Instrument (ACI)?

The ACI is a legal framework that allows the EU to respond to economic coercion using tariffs or non-tariff measures. It exists as a tool but has never been used.

How will we know when anything becomes official?

Official action will be signaled through published Executive Orders, Federal Register notices, CBP CSMS messages, or EU implementing regulations. Those publications are the trigger points for enforcement.