Author: BCB Canada

Please be advised that, effective September 8th, the Government of Canada has imposed a retaliatory surtax on certain goods originating in the United States upon entry into Canada. The applicable surtax rates range from 15% to 50%, depending on the classification of the goods, and this order supersedes and replaces the surtax orders issued in March 2025.

A complete listing of the Harmonized System (HS) codes subject to this surtax, together with the corresponding applicable rate for each code, may be found at the following resource published by the Department of Finance Canada: Complete List of U.S. Products Subject to Counter-Tariffs.

Additional information regarding this surtax order has been published by the Canada Border Services Agency (CBSA) and may be accessed via Customs Notice CN26-23: https://www.cbsa-asfc.gc.ca/publications/cn-ad/cn26-23-eng.html.

Please note that the remission previously granted under the United States Surtax Remission Order (2025), as applicable to the prior surtax order, has been carried forward and extended to this new surtax order, and shall apply to the full surtax rate assessed thereunder.

Key points of this surtax order:

• Applies to targeted HS codes on shipments released on or after September 8th
• Shipments with a ship date on or before September 8th are exempt
• Shipments requiring an Import for Re-Export Program (IREP) permit are exempt
• Duty relief license and duty drawback provisions remain eligible under this order
• The remission previously granted under the United States Surtax Remission Order (2025) carries over to this new surtax order and will continue to cover the full surtax rate

Finance Canada has published the complete list of U.S. products subject to counter tariffs, effective 12:01 a.m. on September 8, 2026. These countermeasures will match the U.S.’s Section 338 and Section 232 tariffs dollar for dollar, with rates of 15%, 25%, and 50% applied based on the corresponding U.S. rate for each good. The tariffs will focus on sectors including steel, dairy, appliances, agricultural equipment, pulp and paper, and electronics, covering roughly $27.6 billion (CAD) in U.S. imports across more than 700 tariff items.

Please note that goods already in transit to Canada on the day the countermeasures take effect will not be subject to these tariffs.

CBSA has not yet issued official guidance on how these counter tariffs will be administered from a Customs perspective. Once that guidance is published, BCB Canada will send out a Trade Alert with full details on classification, application, and any compliance steps importers need to take.

In the meantime, we’d recommend reviewing your U.S.-origin import list against the published tariff item schedule to get a sense of potential exposure ahead of the September 8 effective date.

Source: https://www.canada.ca/en/department-finance/programs/international-trade-finance-policy/canadas-response-us-tariffs/complete-list-us-products-subject-to-counter-tariffs.html#wb-auto-8

March 13, 2026 Update: CBSA has advised remission is permitted for eligible goods imported since December 26, 2025 in respect of surtax applied per the Steel Derivative Goods Surtax Order.

CBSA and Finance Canada have officially released the Customs Notice regarding the Steel Derivative Goods Surtax Remission Order. This is a significant update for importers looking to recover or avoid surtax on specific products.

How to determine if your goods qualify
The remission applies only to specific products. We recommend reviewing the official Schedule immediately, paying close attention to:

• HS Classifications
• Product Descriptions

For full details on the application process, please view Customs Notice 26-07.

Key details regarding this remission include:

• Remission is granted of surtaxes paid or payable under the Steel Derivative Goods Surtax Order in respect of goods imported for use by any of the following entities for the purpose of health care, public health, public safety, national defence or national security:

(a) a government health research organization or clinical health research organization;

(b) an organization that produces or stores medical countermeasures, including pharmaceuticals or medical devices;

(c) the office of a public health official, as defined in subsection C.10.001(1) of the Food and Drug Regulations;

(d) an organization that provides ambulance or other emergency response services;

(e) a firefighting service;

(f) a law enforcement agency;

(g) a federal or provincial correctional service;

(h) the Department of National Defence;

(i) the Canadian Forces; or

(j) the Canadian Security Intelligence Service

• Remission is granted of surtaxes paid or payable under the Steel Derivative Goods Surtax Order in respect of goods imported

(a) for use in the provision of medically necessary health care services, including services provided at

(i) a hospital,

(ii) a health care or dental clinic,

(iii) a medical, dental or diagnostic laboratory, or

(iv) a long-term care facility; or

(b) for use, for the purpose of health care or public health, by:

(i) an entity that provides products or services related to blood, cells, tissues or organs for medically necessary health care, or

(ii) a federal, provincial, local or Indigenous health authority

• Remission is granted of surtaxes paid or payable under the Steel Derivative Goods Surtax Order in respect of the goods referred to in column 2 of the schedule that are classified under a tariff classification number set out in column 1.

• Remission is granted of surtaxes paid or payable under the Steel Derivative Goods Surtax Order in respect of utility wind towers, and sections of those towers, that are classified under tariff item 7308.20.00 and that:

(a) are imported for installation on an offshore energy project; or

(b) are the subject of a purchase order, signed before December 26, 2025 by the proponent of an energy project in Canada, that specifies their price and quantity.

• Remission can only be applied to shipments released from customs on February 24th or later.

How to Request a Correction
If you have shipments released on or after February 24 that qualify for this remission, please forward the details to BCB Canada. Our team will review the information and initiate the necessary corrections and adjustments.

Finance Canada has announced a remission for the Steel Derivative Goods Surtax Order. You can find the list of eligible products via the official Order in Council here.

Below are the key points regarding this remission:

• Remission is granted of surtaxes paid or payable under the Steel Derivative Goods Surtax Order in respect of goods imported for use by any of the following entities for the purpose of health care, public health, public safety, national defence or national security:

(a) a government health research organization or clinical health research organization;
(b) an organization that produces or stores medical countermeasures, including pharmaceuticals or medical devices;
(c) the office of a public health official, as defined in subsection C.10.001(1) of the Food and Drug Regulations;
(d) an organization that provides ambulance or other emergency response services;
(e) a firefighting service;
(f) a law enforcement agency;
(g) a federal or provincial correctional service;
(h) the Department of National Defence;
(i) the Canadian Forces; or
(j) the Canadian Security Intelligence Service

• Remission is granted of surtaxes paid or payable under the Steel Derivative Goods Surtax Order in respect of goods imported

(a) for use in the provision of medically necessary health care services, including services provided at

(i) a hospital,
(ii) a health care or dental clinic,
(iii) a medical, dental or diagnostic laboratory, or
(iv) a long-term care facility; or

(b) for use, for the purpose of health care or public health, by:

(i) an entity that provides products or services related to blood, cells, tissues or organs for medically necessary health care, or
(ii) a federal, provincial, local or Indigenous health authority

• Remission is granted of surtaxes paid or payable under the Steel Derivative Goods Surtax Order in respect of the goods referred to in column 2 of the schedule that are classified under a tariff classification number set out in column 1.

• Remission is granted of surtaxes paid or payable under the Steel Derivative Goods Surtax Order in respect of utility wind towers, and sections of those towers, that are classified under tariff item 7308.20.00 and that:

(a) are imported for installation on an offshore energy project; or
(b) are the subject of a purchase order, signed before December 26, 2025 by the proponent of an energy project in Canada, that specifies their price and quantity.

• Remission can only be applied to shipments released from customs on February 24th or later.

While this remission took effect on February 24th, Finance Canada and the CBSA have not yet released instructions on how to apply it. Consequently, declarations must continue to account for entries with the applicable surtax for the time being.

Please maintain a record of all shipments where the surtax was paid but the remission should apply. Once the government provides application guidelines, you can send your list of transactions for correction/adjustment to BCB Canada.

The Government of Canada has announced additional measures to help safeguard the Canadian steel industry. A summary of these measures is outlined below for your reference.

Steel Derivatives

Effective December 26, 2025, the Government of Canada will impose 25 cent tariffs on the full value of the listed steel derivative products from all countries.

For complete details, please refer to the following link:

List of steel derivative products subject to 25 per cent tariffs effective December 26, 2025 – Canada.ca

Steel Tariff Rate Quotas (TRQs)

Further to the Prime Minister’s announcement on November 26, 2025, updates to the tariff rate quotas (TRQs) for certain steel goods listed under Item 82 on the Import Control List (ICL) will take effect on December 26, 2025.

In accordance with the Second Amending Surtax Order:

• TRQ import volumes for non-FTA partners have been reduced to 20% from 50% of 2024 import volumes.
• TRQ import volumes for non-CUSMA FTA partners have been reduced to 75% from 100% of 2024 levels.

Guidance on the TRQs—including information on purpose, coverage, quota volumes, duration, and administration—is available in the new Notice to importers: Item 82 – Steel goods – Serial No. 1160.

U.S.-Originating Steel and Aluminum Remission Update

To provide stability for Canadian businesses as they adjust their supply chains, the Government of Canada has temporarily extended the horizontal remission of Canadian tariffs on imports from the United States as follows:

• To January 31, 2026, for steel goods used in manufacturing, processing, food and beverage packaging, and agricultural production in Canada, excluding steel goods used in the manufacturing of motor vehicles, aerospace goods, and their parts, for which remission is extended to June 30, 2026.
• To June 30, 2026, for aluminum goods used in manufacturing, processing, food and beverage packaging, and agricultural production in Canada.
• To June 30, 2026, for any goods used for public health, health care, public safety, and national security purposes.

The full announcement can be found here:

Government implements new measures to protect Canada’s steel industry – Canada.ca

The Honourable Shafqat Ali, President of the Treasury Board of Canada, visited Brannon Steel in Brampton, Ontario, to reiterate new measures announced by the Government of Canada to protect and transform Canada’s steel and lumber industries.

Building on previously announced measures to help transform the Canadian steel and softwood lumber industries, the government will:

Further limit foreign steel imports to ensure that Canadian steel producers have better access to the domestic market

• Canada will tighten the tariff rate quota levels for steel products from non-free trade agreement (FTA) partners from 50% to 20% of 2024 levels.
• For non-CUSMA partners with which we have an FTA, Canada will reduce tariff rate quota levels for steel products from 100% to 75% of 2024 levels.
• Canada will impose a global 25% tariff on targeted imported steel-derivative products such as wind towers, prefabricated buildings, fasteners, and wires.
• Canada will also toughen our border measures to combat foreign steel dumping and verify compliance with applicable surtaxes. To do so, we will equip the Canada Border Services Agency with a dedicated steel compliance team, enhanced detection of false declarations, and an expanded online reporting tool.
• To move away from relying on imported steel and to give Canadian companies time to adjust their supply chains to use Canadian steel, the temporary remission of Canadian tariffs on imports will end on January 31, 2026, for steel used in Canada for manufacturing, food and beverage packaging, and agricultural production.
• These measures will boost the competitiveness of Canadian steel producers by protecting them against trade diversion. They will also unlock over $1 billion in new domestic demand for Canadian steel.

Please visit the following link for more information: https://www.canada.ca/en/treasury-board-secretariat/news/2025/12/minister-ali-announces-new-measures-to-protect-and-transform-canadas-steel-and-lumber-industries.html

Please be informed that Customs Notice 25-19: United States Surtax Remission Order (2025), has been updated as of October 17, 2025. This update extends the period of relief for goods under various applications from October 16, 2025, to December 16, 2025.

In addition to the extension, the Order also implements the following changes:

• Relief provided for public health, public safety and national security entities under Sections 1 and 2 has been extended to December 15, 2025.
• Relief provided for goods used in manufacturing, processing and the packaging of a food or beverage under Section 3 has also been extended to December 15, 2025, and expanded to cover goods used in agricultural production.

Upon the recommendation of Finance Canada, a further Remission Order will be published in the November 5, 2025, edition of Part II of the Canada Gazette. This publication will expand upon and provide further details regarding the Order Amending the China Surtax Remission Order (2024) and the United States Surtax Remission Order (2025-1).

The updated notice and associated Remission Order will be accessible via the Canada Gazette publications.

—

Excerpt from Customs Notice 25-19: United States Surtax Remission Order (2025)

Conditions of Relief

12. Claims for relief of surtax upon importation or for refund of surtax paid under this Order must be made by the importer (which may be a private or public sector entity). This may include non-resident importers.

13. All claims for relief of surtax under the Order must also be supported by relevant documents (for example, Commercial Accounting Document (CAD), purchase order, commercial invoice, Canada customs invoice, bill of lading, waybill, etc.) that demonstrate that they meet the following conditions of relief set out in the Order:

A. The good is imported into Canada before:

i. December 16, 2025, in the case of a good in respect of which remission is granted under any of sections 1 to 3, or

ii. The date specified in column 3 of Schedule 3, in the case of a good referred to in that Schedule;

I. In the case of a good that is classified under the tariff classification number set out in column 2 of Schedule 4,

i. It is imported into Canada by a person whose business number is set out in column 1,

ii. It conforms to the description set out at column 3, if any,

iii. It is imported before September 1, 2025, and

iv. It is imported in accordance with the conditions set out in column 4, if any,

II. In the case of a good that is classified under the tariff classification number set out in column 2 of Schedule 4.1,

i. It is imported into Canada by a person whose business number is set out in column 1,

ii. It conforms to the description set out at column 3, if any,

iii. It is imported during the period specified in column 4, if any, and

iv. It is imported in accordance with the conditions set out in column 5, if any;

B. No other claim for relief of the surtax has been granted under the Customs Tariff in respect of the good

C. The importer makes a claim for remission to the Minister of Public Safety and Emergency Preparedness within two years after the date of importation

Please be aware that the Buffalo and Fort Erie Public Bridge Authority website has posted the following alert:

The Buffalo and Fort Erie Public Bridge Authority advises all Canada-bound commercial carriers to avoid the Peace Bridge crossing until further notice, due to ongoing processing delays related to a Canada Border Services Agency (CBSA) systems outage that occurred earlier this week. While CBSA has implemented a processing systems fix, resulting delays continue, and all adjacent queuing areas within the Western New York region are at, or beyond, capacity.

 

In recognition of the United States’ continued approach to allowing most Canadian goods to enter the U.S. tariff-free under the Canada-United States-Mexico Agreement (CUSMA), the Government of Canada has amended its trade measures. Effective September 1, 2025, Canada has removed the majority of counter tariffs introduced in March 2025 on U.S. imports.

Key Measures

• Counter tariffs on most U.S. goods have been lifted as of September 1, 2025.
• Sector-specific tariffs on steel, aluminum, copper, and certain motor vehicles will remain in place. These targeted measures reflect the fact that the United States continues to apply tariffs in these sectors, without providing CUSMA-based exemptions for Canadian goods.

Clarification on CUSMA Qualification and Surtax Exemption

While the Prime Minister previously indicated that goods must qualify under CUSMA to be exempt from the 25% surtax, the Canada Border Services Agency (CBSA) has clarified that the surtax is being removed for all U.S. goods outside of the designated sectors, regardless of whether they carry CUSMA certification.

As stated by the CBSA:

“The amending order repeals the broad U.S. surtax (2025-1) and narrows the measures to sector-specific orders only. That means, as of the retroactive dates, only steel, aluminum, copper, and certain motor vehicles remain subject to a 25% surtax. It does not impose a general surtax on all U.S. goods, nor does it create a blanket CUSMA-based exception. Instead, goods outside those specific sectors simply revert to normal MFN tariff treatment under the Customs Tariff. The Prime Minister’s statement about retaining tariffs on steel, aluminum, and autos lines up with this legal text, but it does not establish any across-the-board surtax tied to CUSMA qualification.”

Additional Resources

• A revised list of products subject to counter tariffs, effective September 1, 2025, can be found here:
  • U.S product subject to counter tariff
• Updates have been made to the following Customs Notices:
  • Customs Notice 25-10: United States Surtax Order (2025-1)
  • Customs Notice 25-11: United States Surtax Order (Steel and Aluminum 2025)
  • Customs Notice 25-19: United States Surtax Remission Order (2025)
• Full text of the Order-in-Council:
  • Order Amending and Repealing Certain Orders Made Under the Customs Tariff (United States Surtax)

An amendment has been made to the surtax order imposing a 50% surtax on certain steel goods. In the original surtax order, steel manufactured in a country with a free trade agreement (FTA) in place was exempted from this 50% surtax with no requirements.

This order now advises that there is a quota for free trade countries as well. To continue to import product manufactured in a country with a free trade agreement without any surtax, importers must now apply for a permit to take part of the quota at the time of release. If a permit is not obtained at the time of release, a 50% surtax will apply.

This amendment is only effective to shipments that were shipped on August 1^st 2025 or later, and were not manufactured in the US, Mexico, or Canada. Please note that any shipments that shipped prior to August 1^st will continue to be exempted from this surtax.

Effective June 27, 2025, certain steel goods imported into Canada are subject to a surtax in the amount of 50% of the value for duty in accordance with the Order Imposing a Surtax on the Importation of Certain Steel Goods. On August 1, 2025, amendments introduced in the Order Amending the Order Imposing a Surtax on the Importation of Certain Steel Goods take effect. The value for duty is determined in accordance with sections 47 to 55 of the Customs Act. Schedule 1 and Schedule 2 to the Order Amending the Order Imposing a Surtax on the Importation of Certain Steel Goods contains a complete list of goods and their importation quotas subject to the surtax for goods originating in a non-FTA country and in a subject FTA country.

For goods imported between June 27, 2025 and July 31, 2025, Schedule 1 to the Order Imposing a Surtax on the Importation of Certain Steel Goods contains a complete list of goods and their importation quotas subject to the surtax when they originate in a country other than those listed in Schedule 2 to the original Order Imposing a Surtax on the Importation of Certain Steel Goods.

The Order imposes trade measures in the form of separate tariff rate quotas (TRQ) on imports of certain steel products. Imports above the specified volumes for each class of steel goods will be subject to a surtax in the amount of 50% of the value for duty in accordance with the Order.

The annual quota is divided into four quarters, except for goods imported from FTA countries, which undergo a transition period before entering the second quarter. The quota available in each quarter is also subject to a quantity limit. Any volumes imported above the quota will be subject to a 50% surtax. Effective August 1, 2025, unused TRQ volumes from previous quarters cannot be carried forward.

Effective August 1, 2025 the surtax will apply to steel imports if:

• For non-FTA countries, the quantity of goods of the same class imported during the same quarterly period exceeds the total set out in column 2 of Schedule 1 for that class
• For FTA countries, the quantity of goods of the same class imported during the same quarterly period exceeds the total set out in column 2 of Schedule 2, or column 2.1 during the transitional period of August 1 to September 25, 2025 for that class
• For non-FTA countries, the quantity of goods of the same class that originate in the same country and are imported during the same quarterly period exceeds the quantity determined by multiplying the percentage in column 3 of Schedule 1 by the total in column 2 of Schedule 1 for that class
• For FTA countries, the quantity of goods of the same class that originate in the same country and are imported during the same quarterly period exceeds the quantity determined by multiplying the percentage in column 3 of Schedule 2 by the total in column 2 of Schedule 2 for that class.

For goods imported between June 27, 2025 and July 31, 2025, the Surtax will apply to steel imports if:

• The quantity of goods of the same class imported during the same quarterly period exceeds the total set out in column 2 of Schedule 1 to the Order Imposing a Surtax on the Importation of Certain Steel Goods for that class
• The quantity of goods of the same class that originate in the same country and are imported during the same quarterly period exceeds the quantity determined by multiplying the percentage set out in column 3 of Schedule 1 to the Order Imposing a Surtax on the Importation of Certain Steel Goods by the total set out in column 2 of Schedule 1 for that class

Where multiple surtaxes could apply to the same goods, surtaxes do not stack. However, the 50% steel surtax takes precedence and will be the rate applied, not any lower surtax rates that might otherwise be applicable.

Importers must have a shipment-specific permit to declare the importation is under the TRQ and is not subject to the surtax. Importers may apply for a shipment-specific import permit under item 82 of the Import Control List in accordance with subsection 8(1) of the Export and Import Permits Act. Import permits will not be issued once the quantities indicated in Schedule 1 to the Order have been reached. Goods may continue to be imported under General Import Permit No. 80 or 81, as applicable, in excess of the limits set out in the Order, but will be subject to the surtax. The shipment-specific permit must apply to steel goods listed in item 82 of the Import Control List and must be valid at the time the goods are accounted for under the Customs Act.

If you would like BCB Canada to obtain a shipment-specific import permit for your clearance, please include your EIPA on the relevant documents and send them to permit@bcbcanada.ca with your permit application request. Contact us for information about permit application fees.

For further information, and to review the updated quota schedules, please refer to the order amending the order imposing a surtax on certain steel goods.