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U.S. Announces Import Bans and Section 338 Tariff Changes of Certain Canadian Goods

U.S. Announces Import Bans and Section 338 Tariff Changes of Certain Canadian Goods - Route Newsletter: September 2026

On September 8, 2026, US President Donald Trump issued a number of Proclamations that took effect as early as September 15, 2026, on certain Canadian-origin goods.

Importers must closely review the following, as these changes may significantly affect tariffs or the ability to import certain Canadian-origin products into the United States.

Changes to certain Section 338 Tariffs

The original Proclamation 11046 imposing the 50 percent Section 338 tariff on certain Canadian origin goods exempted goods subject to Section 232 tariffs – these adjustments now remove that exemption and both tariffs, under Section 338 and Section 232, may apply to the same goods, equating to a possible 100 percent tariff in certain circumstances:

The duties imposed pursuant to Proclamation 11048, as modified in this proclamation, shall apply in addition to duties imposed pursuant to section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862).  These changes shall be effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on September 15, 2026.

Examples of Section 232 additions to the list, which may now be subject to a 100% stacked tariff, include:

7308.90.30 Iron or steel columns, pillars, posts, beams and girders, not in part of alloy steel
7308.90.60 Iron or steel columns, pillars, posts, beams and girders, nesoi
7308.90.95 Iron or steel structures (excluding prefabricated structures) and parts of structures, nesoi
7604.10.10 Aluminum non-alloyed profiles
7604.10.30 Aluminum non-alloyed bars and rods, with a round cross section
7604.10.50 Aluminum non-alloyed bars and rods, without a round cross section
7604.21.00 Aluminum alloy hollow profiles
7604.29.10 Aluminum alloy profiles (other than hollow profiles)
7604.29.30 Aluminum alloy bars and rods, with a round cross section
7604.29.50 Aluminum alloy bars and rods, without a round cross section
7608.10.00 Aluminum non-alloyed tubes and pipes
7608.20.00 Aluminum alloy tubes and pipes

The original Proclamation 11046 imposing a 50 percent Section 338 tariff on certain Canadian origin goods exempted goods subject to Section 232 tariffs – these adjustments now remove that exemption and both tariffs, under Section 338 and Section 232, may apply to the same goods, equating to a possible 100 percent tariff in certain circumstances:

The duties imposed pursuant to Proclamation 11046, as modified in this proclamation, shall apply in addition to duties imposed pursuant to section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862).  These changes shall be effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on September 15, 2026.

Canadian origin goods banned from import

Importers should take note – CUSMA/USMCA does not shield covered goods.

The White House Fact Sheet confirms that Section 338 duties apply to all covered goods made in Canada, regardless of whether the goods originate under CUSMA/USMCA.  This breaks the pattern that importers have relied on for the past 18 months, in which a valid origin certification generally provided relief under IEEPA and Section 122 measures. A CUSMA/USMCA certificate of origin will not exempt a listed product here.

If you are unsure whether your products fall under any of the three Annexes, our US Customs Consulting Services regulatory team can help you determine their classifications. Reach out to Brian Rowe, Director – Customs Compliance & Regulatory Affairs, or your Universal Logistics representative.

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