Author: BCB Canada

On August 23, 2024, the CBSA issued Customs Notice 24-27: CARM October Implementation – Transition Measures, which outlined a number of transition measures to support trade chain partners in the adoption of the CBSA’s Assessment and Revenue Management (CARM).

On October 21, 2024, Regulations Amending Certain Regulations Administered and Enforced by the Canada Border Services Agency came into force providing importers release prior to payment of duties without having to give security for a period of 180-days following CARM implementation.

On March 23, 2025, Regulations Amending Certain Regulations Administered and Enforced by the Canada Border Services Agency, specifically subsection 69(2), were extended by 30 days, effectively bringing RPP transition end date to May 20, 2025 at 3:00:01am EDT.

This measure provided a period of time to secure financial security in order to continue to benefit from Release Prior to Payment following the end of the transition period.

Clarity of end of transition period for importer program accounts

Importer program accounts (BN15) enrolled in RPP, as part of transition plan or post-October 21, 2024, that have provided the required financial security will maintain RPP privileges post May 20, 3:00:01am EDT and will not be impacted by the end of the transition period. No further action is required at this time.

Importer program accounts (BN15) enrolled in RPP and have transacted (imported goods) since October 21, 2024, if all transactions on the account are not subject to duties and taxes (for example zero-rated goods such as produce) will still benefit from RPP post May 20 at 3:00:01am EDT as there is no principal to secure on these transactions. If goods imported in the future are subject to duties and taxes, the financial security requirement would be required for the goods to be released prior to payment.

Importer program accounts (BN15) enrolled in RPP as part of transition period or post-October 21, 2024, that have dutiable and taxable importations (transactions) and have not taken action to satisfy financial security requirement, will be removed from RPP on May 20, 3:00:01am EDT. Future enrolment in RPP with the provision of the required financial security is possible.

Importer program accounts (BN15) enrolled in RPP as part of transition period, but that show no importations (no transactions) since October 21, 2024, and have subsequently not provided financial security, will be removed from RPP on May 20 at 3:00:01am EDT. Future enrolment in RPP with the provision of the required financial security is possible.

Importers not eligible for RPP come May 20, 2025 will need to submit a CAD C-Type and pay applicable duties and taxes at time of release.

Additional information

• Customs Notice 24-27: CARM October Implementation – Transition Measures outlines transition measures that remain in effect to support trade chain partners in the adoption of the CBSA’s Assessment and Revenue Management (CARM).
• Memorandum D17-1-8 provides detailed instructions for TCPs to follow in enrolling Release Prior to Payment program.
• If you have any questions about the transition measures, please contact CBSA through the Client support contact form.

As of October 21, 2024, importers who are maintaining records outside of Canada or not at their place of business in Canada will not be issued an importer account (RM) unless the BSF900: Agreement to maintain records elsewhere than the place of business in Canada has been completed and submitted in the CARM portal (for more details please refer to Memorandum D17-1-21: Maintenance of Records in Canada by Importers). Please note that records must be kept in Canada, the USA or Mexico.

If an importer has an existing BN15, please follow User Guide – Update your CBSA information at the program level.

If a new RM account is needed, please follow User Guide – Enrol in the Importer program

If an importer has as an existing RM account that is inactive, it can be reactivated by contacting CARM Helpdesk.

To ensure your application is processed in a timely manner, please ensure your BSF900 is fully completed and uploaded to CARM.  Please see below for some instances that may delay your application process:

• If a third party is to maintain Books & Records on your behalf; CBSA requires a confirmation letter signed by the third party that they are holding your Books & Records at the address indicated in the BSF900.
• Addresses listed on the BSF900 need to match the addresses listed in CARM. If there’s an error in the address or if the importer moves, please contact the Canada Revenue Agency (CRA) to update the address related to the BN9.
• If importers are renting an office suite from a coworking/shared office space, then a valid lease/rental agreement should be uploaded to the CARM enrolment/program update case to ensure we can validate the Books & Records address.
• If you are a non-resident importer, please make sure to fill out the for “Non-Resident Importers” section on the 2nd page of the BSF900 and provide the supporting documents (e.g.: articles of formation/incorporation, proof of paid annual registration fees for the current year, etc…).

This notice provides information on the application of the United States Surtax Remission Order (2025) which is intended to minimize the negative effects of the surtaxes on Canadian companies and entities by providing relief for goods that are used in Canadian manufacturing, processing and food and beverage packaging, and for those used to support public health, health care, public safety, and national security objectives.

The Remission Order allows the relief of surtaxes paid or payable by the United States Surtax Order (2025-1), the United States Surtax Order (Steel and Aluminum 2025) or the United States Surtax Order (Motor Vehicles 2025) (Surtax Order) in respect of eligible goods.

The administration of this Remission Order is the responsibility of the Canada Border Services Agency (CBSA).

Application

Remission is granted for public health, public safety and national security purposes, per section 1 and section 5 of the United States Surtax Remission Order (2025), of surtaxes paid or payable under the United States Surtax Order (2025-1), the United States Surtax Order (Steel and Aluminum 2025) or the United States Surtax Order (Motor Vehicles 2025) in respect of goods imported by or on behalf of:

• a government health research organization or clinical health research organization;
• an organization that produces or stores medical countermeasures, including pharmaceuticals or medical devices;
• an organization that provides ambulance or other emergency response services;
• a firefighting service;
• a law enforcement agency;
• a federal or provincial correctional service;
• the Department of National Defence;
• the Canadian Forces; or
• the Canadian Security Intelligence Service.

Remission is granted for health care purposes per section 2 and section 5 of the United States Surtax Remission Order (2025), of surtaxes paid or payable under the United States Surtax Order (2025-1), the United States Surtax Order (Steel and Aluminum 2025) or the United States Surtax Order (Motor Vehicles 2025) in respect of goods imported:

• for the use in the provisions of medically necessary health care services. including services provided at:
• a hospital,
• a health care or dental clinic,
• a medical, dental or diagnostic laboratory, or
• a long-term care facility; or
• by or on behalf of
• an entity that provides products or services related to blood, cells, tissues or organs for medically necessary health care, or
• a federal, provincial, local or Indigenous health authority

Remission is granted for manufacture, processing or packaging purposes per section 3 and section 5 of the United States Surtax Remission Order (2025), of surtaxes paid or payable under the United States Surtax Order (2025-1) or the United States Surtax Order (Steel and Aluminum 2025) in respect of goods imported for use, in Canada, in the manufacture or processing of any good or the packaging of a food or beverage, where, under the Customs Tariff, processing and manufacturing, in respect of goods, includes the adjustment, assembly, or modification of the goods.

Remission is granted for goods referred to in the schedule of the United States Surtax Remission Order (2025) per section 4 and section 5, of surtaxes paid or payable under the United States Surtax Order (2025-1) in respect of goods referred to in column 1 of the schedule of the Remission Order that are classified under a tariff classification number set out in column 2 of the schedule of the Remission Order.

Conditions of relief

All claims for relief of surtax under the Remission Order for these goods must also be supported by all relevant documents (e.g., Commercial Accounting Document (CAD), purchase order, commercial invoice, Canada customs invoice, bill of lading, way bill) that demonstrate that they meet the following conditions of relief set out in the Remission Order:

• the good was imported into Canada before October 16, 2025;
• no other claim for relief of the surtax has been granted under the Customs Tariff in respect of the good; and
• the importer makes a claim for remission to the Minister of Public Safety and Emergency Preparedness within two years after the date of importation

The Department of Finance

The Department of Finance has provided the following, based on an inquiry sent to the mailbox remissions-remises@fin.gc.ca:

“As announced by the Minister of Finance, the United States Remission Order (2025), entered into force on April 16. This Order provides time-limited relief from tariffs on U.S. goods:

• imported by or on behalf of listed Canadian public or private entities in the public health, health care, public safety, and national security sectors;
• identified as necessary for public health or health care;
• for use in Canadian manufacturing;
• for processing in Canada; or
• for food and beverage packaging in Canada.

This action provides immediate relief to a broad cross-section of Canadian businesses that rely on U.S. inputs to support their competitiveness as well as to entities integral to Canadians’ health and safety, such as hospitals, long-term care facilities and fire departments. The remission is provided on a time-limited basis to provide businesses and entities with additional time to adjust their supply chains and prioritize domestic sources of supply if available.

The Order provides relief for goods imported into Canada for a six-month period from April 16 to October 15, 2025, and retroactively for goods imports since March 4. Remission can be claimed to waive the payment of tariffs at the time of importation, and importers may seek a refund for tariffs already paid.”

BCB Canada is requesting that qualifying importers affected by the Surtax Orders compile a comprehensive list of all affected closed transactions to facilitate the processing of adjustments and corrections. Additionally, we require importers to provide an affidavit for all import scenarios involving products covered under these orders. Please submit this documentation at your earliest convenience to expedite the adjustment process.

Associated Links

• Customs Notice 25-19: United States Surtax Remission Order (2025)
• Orders-In-Council United States Surtax Remission Order – PC Number 2025-0466
• United States Surtax Order (2025-1)
• United States Surtax Order (Steel and Aluminum 2025)
• United States Surtax Order (Motor Vehicles 2025)

Effective April 9, 2025, motor vehicles originating in the U.S. and imported into Canada are subject to a surtax in the amount of 25% of the value for duty in accordance with the United States Surtax Order (Motor Vehicles 2025). The value for duty is determined in accordance with sections 47 to 55 of the Customs Act. Schedules 1 and 2 to the United States Surtax Order (Motor Vehicles 2025) contain a complete list of goods subject to the surtax.

Both new and used motor vehicles are subject to the surtax, including motor vehicles with electric motors and motor vehicles with internal combustion piston engines. Motor vehicles subject to the surtax may include the following:

• Motor cars and other motor vehicles principally designed for the transport of less than ten persons, including the driver. Examples of subject goods include passenger cars, including racing cars and stations wagons; other cars, including crossovers, sport utility vehicles and passenger vans; motorhomes; and ambulances, hearses or prison vans.
• Motor vehicles for the transport of goods with a gross vehicle weight not exceeding 5 tonnes, other than those for conversion to ambulances, and motor vehicles for the transport of goods with only electric motor for propulsion.

For clarity, motor vehicles not subject to the surtax include, but are not limited to, vehicles specifically designed for travelling on snow, golf cars and similar vehicles (goods of Tariff Item No. 8703.10); and motor vehicles with only spark-ignition internal combustion piston engine of a cylinder capacity not exceeding 1,000 cc (goods of Tariff Item No. 8703.21).

The surtax applies even if the motor vehicle qualifies for preferential tariff treatment under the Canada–United States–Mexico Agreement (CUSMA).

1. If a motor vehicle is entitled to the United States Tariff (the CUSMA preferential tariff treatment duty rate), the value of all goods that originate in Canada or Mexico that are used in the production of the motor vehicle are excluded from the value for duty of the motor vehicle for the purposes of calculating the surtax.
2. As a means to account for the assumed value of all goods that originate in Canada or Mexico that are used in the production of the motor vehicle, 15% of the value for duty of the motor vehicle will be excluded from the value for duty for the purposes of calculating the surtax (i.e., the value for duty for the surtax is calculated at 85% of the total value for duty of the goods).
3. To claim a higher exclusion amount, the importer should obtain evidence of the value of goods that originate in Canada or Mexico used in the production of the motor vehicle and provide it to a CBSA official upon request. In such cases, importers are expected to obtain sufficient supporting information (e.g. a valid CUSMA certification of origin, records substantiating compliance with Regional Value Content (RVC), core parts, steel/aluminum and Labour Value Content (LVC), value for duty documentation, and documentation of Canadian/Mexican parts used). Importers electing to obtain and retain such evidence are encouraged to use the Release Prior to Payment (RPP) program.

Where goods have been accounted for and the surtax has been calculated as described in paragraph 6c, the CBSA may conduct a verification to ensure that the value for duty used for the purposes of calculating the surtax does in fact qualify as originating in the corresponding territory and in the corresponding amounts claimed. In certain circumstances, such as where the origin of the good is changed because a material used in the production of the good is determined to be non-originating or where the CBSA is denied access to records, the CBSA may re-calculate the amount of surtax owing based on the 15% content amount described in paragraph 6b. Refer to Memorandum D11-4-20: Procedures for verifications of origin under a free trade agreement with non-European countries for details.

The surtax only applies to motor vehicles that originate in the U.S. The determination of whether goods originate in Canada, the United States or Mexico is to be made in accordance with sections 2, 4 to 8 and 10 to 13 of the Determination of Country of Origin for the Purpose of Marking Goods (CUSMA Countries) Regulations. The surtax does not apply to goods eligible to be marked as originating from Puerto Rico, Guam, the Northern Mariana Islands, American Samoa or the U.S. Virgin Islands.

The surtax applies to motor vehicles identified in Schedule 1 to the United States Surtax Order (Motor Vehicles 2025) that are imported for commercial and personal purposes, even when exported from a country other than the U.S. into Canada.

The surtax does not apply to goods eligible for classification in the tariff items of Chapter 98 of the Schedule to the Customs Tariff, other than goods eligible for classification under tariff items listed in Schedule 2 to the United States Surtax Order (Motor Vehicles 2025). Chapter 98 includes temporary importations under specific conditions, traveler exemptions and other such tariff items.

The surtax does not apply to goods eligible for classification in the tariff items of Chapter 99 of the Schedule to Canada’s Customs Tariff, with the exception of goods eligible for classification under 9966.00.00 (vehicles and parts manufactured more than 25 years before the date of importation), 9971.00.00 (temporary exports of vessels for repair or alteration), and 9989.00.00 (articles produced more than 50 years prior to the date of accounting, other than antiques of an age exceeding 100 years, spirits or wines). Chapter 99 includes tariff items that would allow goods to receive a duty free rate or reduced duty rate.

The surtax is remitted for goods (both casual and commercial) eligible for remission under the Akwesasne Residents Remission Order.

Canada’s Duties Relief and Duty Drawback Programs will be available for surtax paid or payable, subject to the provisions of the Canada-United States-Mexico Agreement (CUSMA).

 

Associated Links

• Customs Notice 25-15: United States Surtax Order (Motor Vehicles 2025)
• List of vehicle products from the United States subject to 25 per cent tariffs effective April 9, 2025

Yesterday, the United States administration announced a new series of tariffs that will significantly impact the international trading system. While key aspects of the Canada-U.S. trade relationship remain intact, new tariffs on automobiles have now taken effect. These additional measures come on top of previously implemented tariffs, including those on steel and aluminum, which continue to remain in force.

The Prime Minister of Canada, Mark Carney, today announced new countermeasures to protect Canadian workers and businesses and defend Canada’s economy. These countermeasures include:

• Twenty-five per cent tariffs on non-CUSMA compliant fully assembled vehicles imported into Canada from the United States.
• Twenty-five per cent tariffs on non-Canadian and non-Mexican content of CUSMA compliant fully assembled vehicles imported into Canada from the United States.

Quick Facts

• Canada and the United States have the world’s most comprehensive and dynamic trading relationship, which supports millions of jobs in both countries. US$2.5 billion worth of goods and services cross the border every day.
• On March 4, 2025, U.S. tariffs of 25 per cent on Canadian goods and 10 per cent on energy and potash exports from Canada to the U.S. came into effect. On March 12, 2025, the U.S. imposed tariffs of 25 per cent on Canadian steel and aluminum products.
• On April 3, U.S. tariffs of 25 per cent on Canadian automobiles came into effect, targeting the auto industry and the more than 500,000 Canadians this industry supports across the country.
  • • The U.S. also intends to apply 25 per cent tariffs on certain automobile parts before May 3. Under the U.S. tariffs certain exclusions linked to U.S. content may be available, specifically, the application of the 25 per cent tariff only to the value of the non-U.S. content in automobiles and auto parts that qualify for preferential tariff treatment under CUSMA.

•  

• Canada has responded to the U.S. imposition of tariffs on Canadian goods by introducing a suite of countermeasures designed to compel the U.S. to remove the tariffs as soon as possible. These countermeasures include:
  • • Imposing tariffs of 25 per cent on a valued $30 billion in goods imported from the U.S., effective March 4, 2025.
    • Launching a public comment period on potential counter tariffs on additional imports from the U.S.
    • Imposing, as of March 13, 2025, 25 per cent reciprocal tariffs on a list of steel products worth $12.6 billion and aluminum products worth $3 billion, as well as additional imported U.S. goods worth $14.2 billion, for a total of $29.8 billion to match U.S. tariffs on steel and aluminum dollar-for-dollar.

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Associated Links

• Canada-United States relations
• Canada’s response to U.S. tariffs on Canadian goods
• The Canada-United States-Mexico Agreement (CUSMA)
• Prime Minister Carney meets with premiers to discuss Canada’s response to U.S. tariffs
• Prime Minister Carney speaks with President of the United States Donald J. Trump

Following up on a request made by a number of stakeholders, Treasury Board has approved a regulatory package for a 30-day extension to the period in which imported goods may be released prior to payment without giving financial security until May 20, 2025 at 3:00 am (EDT). An importer who does not meet the financial security requirement of Release Prior to Payment (RPP) by the end of the transition period will no longer be able to benefit from having their goods released at the border prior to making payment of the duties and taxes (Please refer to News Release).

Importers and trade chain partners (TCPs) are strongly encouraged to take immediate action by providing financial security in CARM, if they are already enrolled in RPP or by enrolling in the program before the end of the transition period. Importers choosing to participate in the RPP program will now have until 3:00 am (EDT) on May 20, 2025 to post their financial security in the CARM system. Commercial goods belonging of RPP participants will continue to be released prior to payment without a posted financial security until this date.

Importers who do not post financial security requirement by May 20, 2025 will no longer be able to benefit from having their goods released electronically at the border prior to making payment of the duties and taxes. Without RPP, importers will have to pay all duties and taxes at the time of arrival at a port of entry.

Memorandum D17-1-8 provides detailed instructions for TCPs to follow in enrolling Release Prior to Payment program.

Effective March 13, 2025, the Government of Canada is imposing 25 per cent tariffs on $29.8 billion in products imported from the United States (U.S.).

These tariffs only apply to goods originating from the U.S., which shall be considered as those goods eligible to be marked as a good of the U.S. in accordance with the Determination of Country of Origin for the Purpose of Marking Goods (CUSMA Countries) Regulations.

These countermeasures are effective as of 12:01 a.m., March 13, 2025, and will remain in place until the U.S. eliminates its tariffs against Canadian steel and aluminum products. Canada’s countermeasures do not apply to U.S. goods that are in transit to Canada on the day on which they come into force. Additional details on the administration of these tariffs are available on the Canada Border Services Agency website: Customs Notices (cbsa-asfc.gc.ca).

The list of products outlined at the tariff item level in the table below should be read in conjunction with the Schedule to Canada’s Customs Tariff.

Effective March 13, 2025, steel, aluminum and certain other goods imported into Canada and originating in the U.S. are subject to a surtax in the amount of 25% of the value for duty in accordance with the United States Surtax Order (Steel and Aluminum 2025). The value for duty is determined in accordance with sections 47 to 55 of the Customs Act. The Schedule to the United States Surtax Order (Steel and Aluminum 2025) contains a complete list of goods subject to the surtax.

The surtax will only apply to steel, aluminum and certain other goods that originate in the U.S., which shall be considered as those goods eligible to be marked as goods of the U.S. in accordance with the Determination of Country of Origin for the Purpose of Marking Goods (CUSMA Countries) Regulations.

The surtax will apply to steel, aluminum and certain other goods imported for commercial and personal purposes, even when exported from a country other than the U.S. into Canada.

The surtax does not apply to aluminum and other goods identified in Schedule 1 that are eligible for classification in the tariff items of Chapter 98 of the Schedule to Canada’s Customs Tariff, other than goods of 9804.30, 98.25, 98.26, 9897.00.00, 9898.00.00 and 9899.00.00.

The surtax does not apply to aluminum and other goods identified in Schedule 1 that are eligible for classification in the tariff items of Chapter 99 of the Schedule to Canada’s Customs Tariff – with the exception of goods classified in tariff items 9966.00.00, 9971.00.00, 9989.00.00. Goods in those tariff items are subject to the surtax – even though they are entitled to the Most-Favoured-Nation zero customs duty rate under Chapter 99.

The surtax applies to steel goods identified in Schedule 2 of the United States Surtax Order (Steel and Aluminum 2025) that are eligible for classification in the tariff items of Chapter 98 and 99 of the Schedule to Canada’s Customs Tariff, even though they are entitled to the Most-Favoured-Nation zero customs duty rate under Chapter 98 or 99.

The surtax applies to goods imported from the U.S., including those that may be eligible for the remission of customs duties, sales and/or excise taxes under the Postal Imports Remission Order or the Courier Imports Remission Order.

The surtax does not apply to goods (both casual and commercial) eligible for remission under the Akwesasne Residents Remission Order.

Effective March 4, 2025, the Government of Canada is imposing 25 per cent tariffs on $30 billion in goods imported from the United States (U.S.).

These tariffs only apply to goods originating from the U.S., which shall be considered as those goods eligible to be marked as a good of the U.S. in accordance with the Determination of Country of Origin for the Purposes of Marking Goods (CUSMA Countries) Regulations.

These countermeasures are effective as of 12:01 a.m., March 4, 2025, and will remain in place until the U.S. eliminates its tariffs against Canadian goods. Canada’s countermeasures do not apply to U.S. goods that are in transit to Canada on the day on which they come into force. Additional details on the administration of these tariffs are available on the Canada Border Services Agency website: Customs Notices (cbsa-asfc.gc.ca).

The list of products outlined at the tariff item level in the table below should be read in conjunction with the Schedule to Canada’s Customs Tariff.

Effective March 4, 2025, certain goods imported into Canada and originating in the U.S. are subject to a surtax in the amount of 25% of the value for duty in accordance with the United States Surtax Order (2025-1). The value for duty is determined in accordance with sections 47 to 55 of the Customs Act. The Schedule to the United States Surtax Order (2025-1) contains a complete list of goods subject to the surtax.

The surtax will only apply to goods that originate in the U.S., which shall be considered as those goods eligible to be marked as goods of the U.S. in accordance with the Determination of Country of Origin for the Purpose of Marking Goods (CUSMA Countries) Regulations.

The surtax will apply to goods imported for commercial and personal purposes, even when exported from a country other than the U.S. into Canada.

The surtax does not apply to goods that are classified, or that should be classified, in Chapter 98 of the Schedule to the Customs Tariff, other than goods of 9804.30, 98.25, 98.26, 9897.00.00, 9898.00.00 and 9899.00.00.

The surtax does not apply to goods that may be classified in the tariff items of Chapter 99 of the Schedule to Canada’s Customs Tariff – with the exception of goods classified in tariff items 9966.00.00, 9971.00.00 and 9989.00.00. Goods in those tariff items are subject to the surtax even though they are entitled to the Most-Favoured-Nation zero customs duty rate under that Chapter.

The surtax applies to goods imported from the U.S., including those that may be eligible for the remission of customs duties, sales and/or excise taxes under the Postal Imports Remission Order or the Courier Imports Remission Order.

The surtax does not apply to goods (both casual and commercial) eligible for remission under the Akwesasne Residents Remission Order.

Canada’s Duties Relief and Duty Drawback Programs will be available for surtax paid or payable, subject to the provisions of the Canada-United States-Mexico Agreement (CUSMA).