Toronto, September 25, 2025
With the number of recent changes to steel import requirements into both Canada and the U.S., here’s a comprehensive outline of the latest information:
Imports into Canada
Although most Retaliatory Tariffs applied against the U.S. have been removed, effective September 1, 2025, there still remain tariffs on a number of US made products (steel, aluminum and automotive) regardless of whether or not CUSMA/USMCA is applicable.
- Complete list of U.S. products subject to counter tariffs may be found here.
- Refer to the “Effective September 1, 2025” tab to search by HS tariff classification of those goods still subject to a 25% Retaliatory Tariff
The Government of Canada has introduced additional surtaxes to address the risk of steel trade diversion from third countries into the Canadian market due to restrictive trade measures taken by the United States, notably through its imposition of tariffs on steel under section 232 of the Trade Expansion Act of 1962.
Customs Notice 25-24: Order Imposing a Surtax on the Importation of Certain Steel Goods (effective June 27, 2025)
- Application: Certain steel goods imported into Canada are subject to a surtax in the amount of 50% of the value for duty. Goods originating in Canada, the United States, or Mexico are not subject to this surtax and are excluded from the determination of the quantity of goods imported.
- Permits: Importers must have a shipment-specific permit to declare the importation is under the Tariff Rate Quotas (TRQ) and is not subject to the surtax. This permit must be valid at the time the goods are accounted for under the Customs Act.
- Import permits will not be issued once the quantities indicated in Schedule 1 to the Order have been reached, therefore surtax will be payable.
- Shipments with no permit at the time of accounting, will have surtax payable.
The TRQ will be put in place for the duration of one year, from June 27, 2025, to June 26, 2026. Reports, updated daily, from Global Affairs Canada on steel TRQ utilization are available here.
Customs Notice 25-28: Steel Goods and Aluminum Goods Surtax Order (effective July 31, 2025)
- Application: Certain steel goods imported into Canada, and containing steel melted and poured in China, as well as certain aluminum goods imported into Canada and containing aluminum smelted and cast in China, are subject to a surtax in the amount of 25% of the value for duty.
- Steel and aluminum goods that originate in the United States, as determined in accordance with the Determination of Country of Origin for the Purpose of Marking Goods (CUSMA Countries) Regulations, are not subject to the surtax.
- Steel and aluminum goods for which the cumulative value for duty of all goods subject to the Steel Goods and Aluminum Goods Surtax Order and accounted for under a single Commercial Accounting Declaration (CAD) does not exceed $5,000 are not subject to the surtax.
- Documentation requirements: For the purposes of demonstrating that the country of melt and pour (COM) or country of smelt and cast (CSC) is not China, importers must be in possession of one of the following documents effective September 22, 2025, otherwise the importer will be required to pay the applicable surtax. Documentation acceptable to prove COM and CSC:
- Mill test certificate
- Material test certificate
- Certificate of conformance
- Certificate of compliance
- Certificate of inspection
- Certificate of analysis
- Certified inspection certificate
- Metallurgical test certificate
- Chemical analysis certificate
Imports into USA
The White House issued their fact sheet on President Trump’s restoration of the Section 232 Tariffs on imports of steel and aluminum on February 11, 2025. Since then, a number of additions to the list of affect products have been implemented:
- February 11, 2025: Proclamation 10895 Adjusting Imports of Aluminum Into the United States
Proclamation 10896 Adjusting Imports of Steel Into the United States- Both proclamations introduced an additional 25% duty on goods under the affected HTS lists as provided by the proclamations and updated guidance.
- June 3, 2025: A new Executive Order increased the tariff rate for steel and aluminum articles, and their derivative items, from the above proclamations to 50% (except UK country of origin products which remain at 25%).
- August 18, 2025: An additional list of steel and aluminum derivative tariff codes were added.
Section 232 FAQs by US Customs and Border Patrol (CBP)
Proclamation 10895 (Adjusting Imports of Aluminum Into the United States) and further guidance key takeaways
- US Customs requires the aluminum content value to be reported along with the aluminum content weight, country of primary smelt, country of secondary smelt (as applicable) and country of casting.
- The value of the aluminum content should be determined in accordance with the principles of the Customs Valuation Agreement, as implemented in 19 U.S.C. 1401a. Thus, the value of the aluminum content is the total price paid or payable for that content.
- Primary Country of Smelt Code: ISO country code where the largest volume of new aluminum metal is produced from alumina (or aluminum oxide) by the electrolytic Hall-Héroult process.
- Secondary Country of Smelt Code: ISO country code where the second largest volume of new aluminum metal is produced from alumina (or aluminum oxide) by the electrolytic Hall-Héroult process.
- Country of Cast Code: ISO country code where the aluminum (with/without alloying elements) was last liquified by heat and cast into a solid state. The final solid state can take the form of either a semi-finished product (slab, billets or ingots), or a finished aluminum product.
- United States country of smelt/cast aluminum is exempt from Section 232 duties.
- United States country of origin products are not subject to Section 232 duties.
- United Kingdom country of origin products are subject to a reduced Section 232 duty rate of 25%.
- Russian country of smelt/cast aluminum is subject to an increased Section 232 duty rate of 200%.
- Important! Unknown country of smelt/cast aluminum will be subject to the increased Section 232 duty rate of 200% imposed on Russian smelt/cast aluminum.
Proclamation 10896 (Adjusting Imports of Steel Into the United States) and further guidance key takeaways:
- US Customs requires the steel content value to be reported along with the steel content weight and the country of melt and pour.
- The value of the steel content should be determined in accordance with the principles of the Customs Valuation Agreement, as implemented in 19 U.S.C. 1401a. Thus, the value of the steel content is the total price paid or payable for that content.
- Melt and Pour Country Code: ISO country code where steel was originally melted. Country of melt and pour refers to the original location where the raw steel is first produced in a steel-making furnace in a liquid state, and then poured into its first solid shape. The first solid state can take the form of either a semi-finished product (slab, billets, or ingots), or a finished steel mill product. The location of melt and pour is customarily identified on mill test certificates that are common place in steel production, generated at each stage of the production process, and maintained in the ordinary course of business.
- Steel melted and poured in the US is exempt from Section 232 duties.
- Products made in the US are exempt from Section 232 duties.
- United Kingdom country of origin products are subject to a reduced Section 232 duty rate of 25%.
- Unknown country of melt and pour steel, are subject to 50% duty rate on the steel content value (or 25% if UK country of origin).
Importers must ensure the applicable country of melt and pour (for steel) and/or country of smelt and cast (for aluminum), along with metal content values, are available on import documentation in order to avoid delays and import entry adjustments post-clearance.
For more information, please call Brian Rowe, Director – Customs Compliance & Regulatory Affairs at (905) 882-4880, ext. 1213.
