Canada’s Response to U.S. Tariffs on Steel and Aluminum Products
UPDATE: March 17th, 2025
UPDATE: CBSA Customs Notice 25-11: United States Surtax Order (Steel and Aluminum 2025)
CBSA Customs Notice 25-11: United States Surtax Order (Steel and Aluminum 2025)
Canada is implementing a 25% surtax on steel, aluminum, and certain goods imported from the U.S., effective March 13, 2025. This surtax is a response to the U.S. tariffs on Canadian steel and aluminum products.
The following is a summary of the information provided in the Customs Notice. To review the full Customs Notice, please click on the link below:
CBSA Customs Notice 25-11: United States Surtax Order (Steel and Aluminum 2025)
Goods Affected
- The surtax applies to steel, aluminum, and specific goods originating in the U.S.
- A complete list of these goods is available in the Schedules to the United States Surtax Order
Exemptions
- The surtax does not apply to certain aluminum and goods classified under specific tariff items in Chapters 98 and 99 of Canada’s Customs Tariff
- Goods eligible for remission under the Akwesasne Residents Remission Order are also exempt
Commercial vs. Casual Goods
- Commercial Goods: Must provide proof of origin through invoices or documentation as per CUSMA requirements
- Casual Goods: Considered to originate from the U.S. if marked accordingly or lacking country of origin marking
Duties Relief
Canadaโs Duties Relief and Duty Drawback programs are available for any surtax paid, in line with CUSMA provisions.
Surtax Calculation
A surtax of 25% is applied to the value for duty of imported goods under the United States Surtax Order (Steel and Aluminum 2025). This surtax is in addition to any other applicable duties, such as anti-dumping duties.
Exceptions to Surtax
- The surtax does not apply to U.S. steel, aluminum, and certain goods that are in transit to Canada on the day the surtax comes into force. Proof of transit is required, which can include shipping documents like bills of lading
- Goods returning to Canada that were previously duty-paid in the U.S. are exempt
- Goods made in the U.S. that are repaired or altered across the border and previously duty-paid are also exempt
Accounting Procedures
- Importers must declare goods subject to surtax using the Commercial Accounting Declaration (CAD), indicating the surtax code 25095A in field 85.
- If using the self-declare option in CARM, importers must calculate the surtax and enter it in the designated field.
- Goods qualifying for an exception must be declared as non-subject to surtax during accounting
Corrections and Adjustments
- Corrections to declarations must follow procedures outlined in various memoranda, including D11-6-6 for self-adjustments and D6-2-3 for refunds.
- Adjustments for commercial goods can be submitted via CARM or EDI/API if surtax was incorrectly assessed.
- For casual goods, adjustments require a Form B2G, which cannot be submitted through CARM.
Re-determinations
The origin, tariff classification, and value for duty may be re-determined in accordance with the Customs Act, which may also consider any undeclared surtax amounts.
Examinations and Verifications
Imported goods are subject to examination upon importation and may undergo post-release verification to ensure compliance with Tariff Classification, Valuation, Origin, and other regulations set by the Canada Border Services Agency (CBSA). Non-compliance can lead to:
- Imposition of surtax
- Additional customs duties and taxes
- Assessment of penalties and accruing interest on outstanding amounts
Advance Rulings for Commercial Importations
To provide predictability and certainty for importers, binding rulings can be requested in advance regarding:
- Free Trade Agreement (FTA) Origin
- Tariff classification
- Marking of goods imported from a Canada-United States-Mexico Agreement (CUSMA) country
Recourse Option
Under the Customs Act, individuals who receive a notice of re-determination can request a review within 90 days if:
- All dues, including duties and interest, are settled
- Security satisfactory to the Minister is provided for the total amount owing
- For further details, refer to the Request under Section 60 of the Customs Act
Additional Information
For those seeking comprehensive information about surtax application, collection, and adjustments, refer to:
Memorandum D16-1-1 which details the administration and enforcement of surtax orders under relevant sections of the Customs Tariff
PREVIOUS POST:
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.). To view the Department of Finance’s announcement, please click on the link below:
List of products from the United States subject to 25 per cent tariffs effective March 13, 2025
Backgrounder
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).
Summary of Products Impacted
Below is a partial listing of the 539 Tariff items/products impacted by this announcement.
| Assorted articles of Iron, Steel, and/or Aluminum | Telephones & Smartphones for wireless networks |
| Computers & Laptops | Assorted Hand Tools, Saws, Files, etc. |
| Assorted Tableware & Kitchenware articles | Assorted sporting equipment |
| Flashlights | Microphones |
| Loudspeakers | Headphones and Earphones |
| Storage Water Heaters | Prefabricated Buildings |
| Articles of natural or cultured pearls, precious or semi-precious stones | Assorted Office Equipment: Filing cabinets, paper trays, etc. |
To search the full list of products impacted at the tariff item level, please click on the link below.
Note: The list should be read in conjunction with the Schedule to Canada’s Customs Tariff.
List of products from the United States subject to 25 per cent tariffs effective March 13, 2025
To stay updated on these Tariffs, please feel free to visit our website Blog page,
