Since March 13, 2025, steel and aluminum goods originating in the United States have carried a 25% surtax on entry into Canada under the United States Surtax Order (Steel and Aluminum 2025), Canada’s response to the U.S. Section 232 tariffs on Canadian steel and aluminum. For eighteen months that rate has been a fixed part of the landed cost of U.S. metal, and importers built their pricing, sourcing and cash-flow assumptions around it. On September 7, 2026, the Canada Border Services Agency republished Customs Notice 25-11 to reflect an amending order (P.C. 2026-0786, SOR/2026-187) that took effect the following morning. The trigger is set out in the notice itself: the amendments follow the U.S. decision to impose Section 338 tariffs on Canadian goods, which came into force on August 22 after the Canada–U.S. trade talks ended without an agreement. The amending order came into force on the same day as the broader United States Surtax Order (2026), so September 8 is the date on which Canada’s whole set of U.S. countermeasures moved to its new footing.
Before September 8 versus after
The structure of the order is what changed, and the structure is what importers need to understand. Before September 8 there was one rate, 25%, applied to two commodity schedules: Schedule 1 for aluminum goods and Schedule 2 for steel goods, with Schedules 3 and 4 catching the same goods when they are entered under a Chapter 98 or 99 tariff item. Since September 8 there are four commodity schedules and two rates. The old Schedules 1 and 2 have been cut down to a short list of finished household articles that stay at 25%, and two new schedules, 1.1 for aluminum and 2.1 for steel, now carry the bulk of the metal trade at 50%. Counting the tariff items in the order as published, the picture looks like this:
| Schedule | Rate | Tariff items | What is in it |
|---|---|---|---|
| 1 (aluminum) | 25% | 2 | Aluminum table, kitchen and household articles and sanitary ware (7615.10, 7615.20) |
| 1.1 (aluminum) | 50% | 27 | Unwrought aluminum, bars, rods, profiles, wire, plates, sheets, foil, tubes, structures, containers, cable and other articles (7601 through 7616) |
| 2 (steel) | 25% | 21 | Springs and leaves (7320.10), stove parts, radiators, kitchen and household articles and sanitary ware (7321 through 7324) |
| 2.1 (steel) | 50% | 244 | Chapter 72 from ingots and semi-finished products onward (headings 72.06 to 72.29: flat-rolled, bars, wire, stainless and alloy) plus structures, tubes, fittings, fasteners, chain, springs and other articles of Chapter 73 (7301 through 7326) |
The practical reading is simple: if you import industrial steel or aluminum from the U.S., assume your rate doubled on September 8, and check the schedule only to confirm which of the small number of finished consumer articles stayed behind at 25%. Note also that the 50% covers Chapter 72 from heading 72.06 onward, which is nearly the whole chapter; it is not a targeted list of products.
What did not change: origin, valuation and the Chapter 98/99 rules
The mechanics under the new rates are the ones importers have been living with since March 2025. The surtax applies only to goods that originate in the United States, meaning goods eligible to be marked as U.S. goods under the CUSMA marking regulations, and it applies whether or not the goods are shipped to Canada directly from the U.S. A supplier’s U.S. address is not the test; the country of origin under the marking rules is, and that is worth re-verifying now that the cost of getting it wrong has doubled. The surtax is calculated on the value for duty under sections 47 to 55 of the Customs Act, on top of any customs duty and any anti-dumping or countervailing duty, and GST is then charged on the total. The notice’s own example makes the point: a $150 steel part at 0% MFN duty now attracts $75 of surtax and $11.25 of GST, for $86.25 payable, against $46.88 before the change. Goods entered under a Chapter 98 or 99 tariff item are outside the surtax unless that item is listed in Schedule 3 or 4 and the goods would otherwise fall in Schedules 1, 1.1, 2 or 2.1. Canada’s steel surtaxes remain non-stackable: where a good is caught by both this order and the Steel Derivative Goods Surtax Order, the U.S. order applies and the derivative surtax does not.
The transition: goods in transit and the new surtax codes
The amending order carries an explicit transition rule. Goods that were in transit to Canada on September 8, meaning bound for Canada but not yet arrived and under the control of a carrier, stay at the rate that applied before that day, which for most goods is 25%. The CBSA will want proof: a bill of lading, cargo control documents or report-of-entry documents that show the shipment was moving before the change, and an officer may ask for it at any time. On the accounting side, the single old surtax code has been replaced by four. On the Commercial Accounting Declaration, aluminum at 25% is declared with code 26187A, aluminum at 50% with 26187B, steel at 25% with 26187C and steel at 50% with 26187D; goods that qualify for the in-transit rate keep the old code 25095A. The amount goes in field 85, and importers who self-declare in the CARM Client Portal have to calculate it themselves. Anyone who filed a September 8 shipment under the old code, or who filed before the codes were published, should expect to correct the declaration through a CAD adjustment rather than assume the entry is settled.
Relief: remission, drawback and what the surtax does to your recourse
The relief landscape shifted on the same day, in ways that cut both directions. The United States Surtax Order (2026) amended the standing United States Surtax Remission Order (2025) so that its categories, goods for health care, public health, public safety, national defence and security, and goods imported for use in manufacturing, processing, agricultural production or food and beverage packaging, now expressly cover the new 1.1 and 2.1 schedules. But the manufacturing-use remission carries a deadline that differs by metal. For aluminum the September amendments extend it: goods must be imported before July 1, 2027, where the order had previously read July 1, 2026. For steel the date was left untouched at February 1, 2026, which means that window has already closed. A steel fabricator who was relying on that standing remission earlier in the surtax’s life should not assume it is still there. Beyond the standing categories, the Department of Finance continues to accept case-by-case remission requests under its U.S. remission framework, on two grounds: inputs that cannot be sourced domestically or from non-U.S. suppliers, or other exceptional and compelling circumstances. Duty drawback and the Duties Relief Program remain available for surtax paid on goods that are later exported, subject to CUSMA rules. On recourse, the notice is blunt: the surtax itself cannot be appealed. What can be appealed, within 90 days and after paying the amount owed, is a CBSA determination of origin, tariff classification or value for duty, which are precisely the three things that decide whether, and at what rate, the surtax applies. Advance rulings on classification and origin are available for the same reason.
What to do this week
The change is large enough that it deserves a deliberate review rather than a line-item update. Pull every U.S.-origin steel and aluminum classification you import and sort it into the 25% survivors and the 50% schedules; do not rely on a supplier’s description of the goods, because the schedule works on tariff items. Re-check origin evidence for anything sourced through a U.S. distributor, since goods of Mexican, European or Asian origin routed through the U.S. are not subject to this surtax at all, and a marking-rules analysis may take some of your volume out of scope. Gather in-transit proof now for anything that crossed the September 8 line, and confirm with your broker that the new 26187 codes are set up in the EDI or portal profile. Reprice: a 50% surtax with GST on top changes the economics of U.S. metal against Canadian, Mexican or offshore supply, and that comparison should be run against the anti-dumping and safeguard measures that apply to the alternatives. Finally, read the new United States Surtax Order (2026) alongside this one. It took effect the same day at 15%, 25% and 50% on a separate list of U.S. goods, from dairy and appliances to paper, plastics and furniture, and an importer whose steel exposure is small may find the larger change is somewhere else in the catalogue. We have written a plain-language guide to that order: Canada’s New Counter-Tariffs Are Here.
Read Customs Notice 25-11 on the CBSA website · Order Amending the United States Surtax Order (Steel and Aluminum 2025), P.C. 2026-0786 · Department of Finance: process for requesting remission of tariffs on certain goods from the U.S.
NoGlobalBorders can review your U.S.-origin steel and aluminum classifications against the new schedules, assemble in-transit documentation and prepare remission requests. Contact us if you would like help working through the change.
