Early EU and UK Responses to President Trump’s Announcement of Tariffs Linked to Greenland and Potential Paths Forward

That said, if the tariffs go into effect, President Trump will likely rely once more on the International Emergency Economic Powers Act (IEEPA), the statute the Administration has employed for reciprocal tariffs, fentanyl tariffs and other foreign-policy related measures. The new threatened tariffs on these eight countries are likely designed to “stack” with existing reciprocal tariffs of 15% on EU Member States and Norway, and 10% on the UK. However, if new IEEPA tariffs do take effect on February 1, they may carry over the same exclusions applicable to the reciprocal tariffs, i.e., the products listed by HTSUS in Annex II to Executive Order 14257. The U.S. Supreme Court will rule sometime between now and July on the legality of President Trump’s use of IEEPA to impose tariffs. While this ruling will not specifically address the threatened 10% tariffs on European countries over Greenland, the Court’s holding may have broader implications for the legality of any IEEPA-based tariffs.

EU and UK Initial Response and Potential Trade Retaliatory Measures
Initial reactions across the EU and UK have been firm at a political level. EU institutions and Member States have publicly reiterated their support for Denmark and Greenland and criticized the use of tariffs as a tool of political pressure. A joint statement by the affected European countries cautioned that tariff threats risk undermining transatlantic relations while reaffirming openness to dialogue.

The renewed threat of tariffs also complicates ongoing implementation of the U.S.-EU trade framework agreement announced in July 2025. The tariff decreases that the EU agreed to impose under the deal are subject to parliamentary and member state approval. The EU has convened an extraordinary meeting of EU diplomats to coordinate its response, with public signalling from the largest political bloc in the European Parliament that elements of the framework agreement could be frozen if the dispute escalates. If the EU does not implement its part of the deal, the United States may revert to a pre-deal tariff posture with a rate of 20–30%. The UK has similarly criticized the U.S. approach and called for a negotiated solution, while stopping short of announcing any immediate potential retaliatory trade measures.

If negotiations fail and the dispute escalates, the EU has two principal trade response pathways available.

Option 1: Reintroduction of Retaliatory Tariffs 
First, the EU could reintroduce retaliatory tariffs that were previously adopted in response to earlier U.S. actions (including Section 232 duties on steel and aluminum and subsequent “reciprocal” tariffs) but later suspended following the EU-U.S. trade framework agreement. These measures collectively cover up to €93 billion of U.S.-origin goods across agricultural, food and beverage, industrial, manufacturing and consumer sectors, with tariff rates typically in the 10–25% range. Impacted products include, among others, steel and aluminum, alcoholic beverages, metals and minerals, batteries, medical and optical products, textiles, leather goods, plastics, wood products, poultry, beef, seafood, nuts, dairy, sugar and vegetables.

This option is relatively straightforward to implement. The potential retaliatory measures have already been adopted under the EU Enforcement Regulation, and the current suspension of those measures is scheduled to expire on February 6, 2026, at which point tariffs could automatically enter into force. This remains the most likely EU trade response should the dispute escalate in the near term.

Option 2: Anti-Coercion Instrument
The EU also could deploy its Anti-Coercion Instrument (ACI), a newer and significantly more far-reaching tool designed to address situations in which a third country seeks to coerce the EU or a Member State into changing a sovereign policy choice. If activated, the ACI would allow the EU to go well beyond traditional retaliatory tariffs and adopt a broader range of countermeasures, including restrictions affecting services, public procurement access, investment, intellectual property protection and regulatory approvals. In practice, this could permit the EU to target areas where the United States is particularly exposed, including the U.S. digital and technology sector (for example, through digital services-related measures or taxes), as well as financial services and investment flows.

However, use of the ACI would require a formal European Commission examination followed by Member State political approval, a considerably longer timetable than reintroducing the tariffs described above. Based on current Member State positions, activation of the ACI seems less likely in the short term. Nevertheless, several Member States and EU institutions have emphasized that the ACI remains firmly on the table as part of the EU’s broader trade defense toolkit.

At this stage, we consider it unlikely that the UK would respond with strong trade retaliatory measures in the short term, absent material escalation. The UK has emphasized dialogue and coordination with European partners while maintaining contingency planning.

While the new “Greenland” tariffs must be situated in the political context of the status of the transatlantic alliance and Arctic security, they could have significant ramifications for the EU-U.S. and UK-U.S. trade relationships. Companies should closely monitor how rapidly evolving developments can impact the trade framework agreements negotiated last year, tariff levels between the United States and European trading partners, and other trade dynamics implicated by potential EU retaliatory measures.