Toronto, September 15, 2026
Further to our previous announcement of September 11, 2026, importers of certain Steel and/or Aluminum Canadian origin goods into the U.S. should take note that the products listed below will be subject to both the 50 percent Section 338 Tariff and a 50 percent Section 232 Tariff, for a combined rate of 100 percent, effective 12:01 am ET on September 15, 2026. These changes are as a result of Proclamations issued by US President Donald Trump of September 8, 2026, on certain Canadian origin goods.
Changes to certain Section 338 Tariffs
- Modifying the Scope of Products of Canada Subject to the Additional Duties Imposed to Offset Canadian Discrimination Against the United States with Respect to Motor VehiclesEffective 12:01 a.m. ET on September 15, 2026, this list of additional Canadian origin goods subject to 50% tariff has become effective. The revised list of tariffs may be found in ANNEX I, a complete list of additions, e.g. certain paper products, tooling, electronic goods, and furniture, certain steel and aluminum, along with deletions, e.g. salt, Portland cement, Tissue Paper, Fishing Rods, etc., may be found in ANNEX II.
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 These changes shall be effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on September 15, 2026.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 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
Importers should take note – CUSMA/USMCA does not shield covered goods.
The White House Fact Sheet confirms the Section 338 duties apply to all covered goods, made in Canada, regardless of whether the good originates under CUSMA/USMCA. This breaks the pattern importers have relied on for the past 18 months, where 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 work through the classifications. Reach out to Brian Rowe, Director, Customs Compliance & Regulatory Affairs, or your Universal Logistics representative.
