Ottawa, July 31, 2025
1. This notice provides information on the application of the Steel Goods and Aluminum Goods Surtax Order, specifically regarding surtax provisions effective July 31, 2025, on certain steel goods melted and poured in China and certain aluminum goods smelted and cast in China.
2. The Government of Canada is introducing this surtax to address risks associated with persistent global overcapacity and non-market policies and practices in the steel and aluminum sectors, which are exacerbated by restrictive trade measures taken by the United States, notably through its imposition of tariffs on steel and aluminum under section 232 of the Trade Expansion Act of 1962.
3. The administration of the Steel Goods and Aluminum Goods Surtax Order is the responsibility of the Canada Border Services Agency (CBSA).
Application
Proof of origin
Exceptions to surtax
Accounting
Corrections, re-determinations, and refunds
4. Effective July 31, 2025, certain steel goods imported into Canada and containing steel melted and poured in China and 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 in accordance with the Steel Goods and Aluminum Goods Surtax Order. The value for duty is determined in accordance with sections 47 to 55 of the Customs Act. The Schedule to the Steel Goods and Aluminum Goods Surtax Order contains a complete list of goods subject to the surtax.
5. For the purposes of this surtax, goods contain steel melted and poured in China if the raw steel, or any portion of the raw steel, contained in the goods was first produced in a liquid state in a steel-making furnace and poured into its first solid state — which can take the form of a semi-finished or finished steel mill product — in China.
6. Steel goods are deemed to contain steel melted and poured in China if the importer fails to provide, when requested by an officer, a certificate, report or commercial invoice that demonstrates that the goods do not contain steel melted and poured in China.
7. For the purposes of this surtax, goods contain aluminum smelted and cast in China if:
the largest volume or, if any, second largest volume of primary aluminum contained in the goods was produced in China; or
the aluminum contained in the goods was most recently liquified and cast into a solid state — which can take the form of a semi-finished or finished aluminum product — in China.
8. Aluminum goods are deemed to contain aluminum smelted and cast in China if the importer fails to provide, when requested by an officer:
a certificate or report that demonstrates that:
the largest volume — and, if any, second largest volume — of primary aluminum contained in the goods was produced in a country other than China, and
the aluminum contained in the goods was most recently liquified and cast into a solid state in a country other than China; or
a commercial invoice that demonstrates that the goods do not contain aluminum smelted and cast in China.
9. For the purposes of demonstrating that the country of melt and pour (COM) or country of smelt and cast (CSC) is not China, importers should have in their possession either a commercial invoice, report or certificate with the required information. The certificate or report can be: a mill test certificate, mill test report or material test certificate; a certificate of conformance, compliance, inspection or analysis; a certified inspection report; a metallurgical test report; or a chemical analysis certificate. If a certificate, report or commercial invoice is not presented upon request by an officer or is not considered acceptable upon review, the importer will be required to pay the applicable surtax.
10. From September 22, 2025 onwards, commercial invoices and reports will no longer be acceptable for the purposes of demonstrating COM or CSC, as provided for in the Steel Goods and Aluminum Goods Surtax Order.
11. Certificates, reports or commercial invoices acceptable to demonstrate COM or CSC may differ from what is acceptable for the determination of proof of origin, as per paragraphs 16 and 17.
12. The surtax will apply to steel and aluminum goods imported for commercial purposes.
13. The surtax applies to goods otherwise classifiable under a tariff item set out in the Schedule to the Steel Goods and Aluminum Goods Surtax Order but that are classified under a tariff item of Chapter 99 of the Schedule to Canada’s Customs Tariff. Chapter 99 includes tariff items that would allow goods to receive a duty free rate or reduced duty rate.
14. Canada’s Duties Relief and Duty Drawback Programs will be available to importers for surtax paid or owed by Canadian businesses, subject to the provisions of the Canada-United States-Mexico Agreement (CUSMA). When goods are of CUSMA (US/Mexico) origin, the goods are not subject to the limitations of CUSMA and the “lesser of two duties” determination does not apply. Therefore, in these circumstances, the goods may be eligible for full relief, if the CUSMA criteria is met, as outlined in CBSA’s Memorandum D7-4-3: CUSMA Requirements for the Duty Drawback and the Duties Relief Programs.
15. The CBSA may conduct a verification to verify whether or not the goods are subject to the surtax, including review of certificates, reports or commercial invoices supporting any claim that the goods are exempt. In instances where the importer fails to provide such documentary evidence, the CBSA may re-calculate the amount of surtax owing.
Proof of origin
16. Pursuant to subsection 35.1(1) of the Customs Act and the Proof of Origin of Imported Goods Regulations, proof of origin must also be furnished for all imported goods upon request.
17. Proof of origin may be in the form of, for example, a commercial invoice, a Canada Customs Invoice or any other documentation that indicates the country of origin of the goods. The documentation must meet the requirements of any applicable obligations established under a free trade agreement or under Canada’s Most-Favoured-Nation (MFN) or General Tariff treatment provisions.
Calculation of surtax when accounting for commercial importations
18. The amount of surtax payable is calculated in the amount of 25% of the value for duty of the imported good in accordance with the Steel Goods and Aluminum Goods Surtax Order. This is in addition to any other duties owing (e.g., in addition to customs duties, anti-dumping and countervailing duties, and taxes that may be applicable).
Example 1:
The value for duty (VFD) of an imported good subject to a surtax is $1,000. The imported good has a Most Favoured Nation (MFN) duty rate of 0%. The applicable surtax rate is 25%, as per the Steel Goods and Aluminum Goods Surtax Order.
The amount of surtax is calculated as follows:
$1,000 (VFD) x 0.25 (surtax rate) = $250 (surtax payable)
Customs duties and taxes are to be calculated as follows:
$1,000 (VFD) x 0 (% MFN duty) = $0 (customs duty)
$1,000 (VFD) + $250 (surtax payable) + $0 (customs duty) = $1,250 (value for tax)
$1,250 x 0.05 (% GST) = $62.50 (GST)
Total payable: $250 (surtax) + $0 (customs duty) + $62.50 (GST) = $312.50
Example 2:
The value for duty (VFD) of an imported good subject to a surtax is $1,000. The imported good has a Most Favoured Nation (MFN) duty rate of 5% and is subject to anti-dumping duties of $34. The applicable surtax rate is 25%, as per the Steel Goods and Aluminum Goods Surtax Order.
The amount of surtax is calculated as follows:
$1,000 (VFD) x 0.25 (surtax rate) = $250 (surtax payable)
Customs duties and taxes are to be calculated as follows:
$1,000 (VFD) x 0.05 (% MFN duty) = $50 (customs duty)
$1,000 (VFD) + $250 (surtax payable) + $50 (customs duty) + $34 (anti-dumping duties) = $1,334 (value for tax)
$1,334 x 0.05 (% GST) = $66.70 (GST)
Total payable: $250 (surtax) + $50 (customs duty) + $34 (anti-dumping duties) + $66.70 (GST) = $400.70
19. The value for duty must be determined in accordance with sections 47 to 55 of the Customs Act. Refer to the Customs valuation handbook for more details.
20. Under the transaction value method, transportation and associated costs, and insurance costs, arising after the place from which goods begin their direct and uninterrupted journey to Canada would not be included in the transaction value of the goods. Any amounts for Canadian customs brokerage fees which are included in the price paid or payable may be deducted as associated costs and as such are not included in the transaction value of the goods. Estimates of the transportation costs are not acceptable. Refer to Memorandum D13-3-3 – Transportation and Associated Costs, Memorandum D13-3-4 – Place of Direct Shipment, and Memorandum D13-4-7 – Adjustments to the Price Paid or Payable (Customs Act, Section 48) for details.
Exceptions to surtax
21. The surtax will not apply to steel and aluminum goods that are in transit to Canada on the date on which the surtax comes into force. This includes goods that were in transit before the surtax comes into force. For the purpose of this Customs Notice, ‘in transit to Canada’ refers to goods bound for but not yet arrived in Canada, and under the control of a carrier. Importers must have proof in their possession that such goods were in transit to Canada in order to demonstrate that the surtax is not applicable. Such proof may include the following documentation: shipping documents (for example, a bill of lading), report of entry documents, and cargo control documents. Such proof may be requested at any time by a CBSA officer.
22. 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.
23. 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. For specificity, a shipment or transaction accounted for under a single CAD may contain other non-subject goods; the value of those goods will not count towards the $5,000 limit.
24. Steel and aluminum goods that are subject to a surtax under the China Surtax Order (2024) are not subject to the surtax.
25. Casual goods as defined in section 2 of the Persons Authorized to Account for Casual Goods Regulations are not subject to the surtax.
26. Steel and aluminum goods that are classified under a tariff item of Chapter 98 of the Schedule to Canada’s Customs Tariff, even if the goods are otherwise classifiable under a tariff item set out in the Schedule to the Steel Goods and Aluminum Goods Surtax Order, are not subject to the surtax.
27. Where goods may have otherwise been subject to multiple surtaxes, the surtax imposed under the Order Imposing a Surtax on the Importation of Certain Steel Goods shall be the only surtax that applies. Refer to Customs Notice 25-24: Order Imposing a Surtax on the Importation of Certain Steel Goods for more information.
Accounting
28. Importers must provide Country of Melt and Pour (COM) information, where applicable, in order to obtain release of steel goods into Canada, including when using the Single Window Integrated Import Declaration (IID). Please refer to paragraphs 20 to 28 of Memorandum D19-10-2: Administration of the Export and Import Permits Act (Importations) and Customs Notice 24-38: Amendments to the GIP number 80 – Carbon steel and GIP number 81 – Specialty steel products for details on these requirements.
29. Importers must declare imported goods as subject to a surtax when completing a CAD via CARM Client Portal (CCP), Electronic Data Interchange (EDI) or Application Programming Interface (API) and declare the applicable surtax code. The surtax code is 25154A for steel goods and 25154B for aluminum goods. The amount of surtax owing is entered in field 85 “Surtax” of the CAD. If importers elect to use the self-declare option in CARM, the amount of surtax owing must be calculated by the importer and entered in the “Surtax” field.
30. Accounting for surtax under the Steel Goods and Aluminum Goods Surtax Order will follow the instructions outlined in Memorandum D16-1-1, Information pertaining to the application, collection, and adjustment of a surtax.
31. Commercial goods qualifying for an exception to this surtax – and to which no other surtaxes apply – must be declared as non-subject to surtax at the time of accounting.
32. When an amount of surtax is being declared at importation, refer to Memorandum D17-1-10, Coding of Customs Accounting Documents for additional information on completing the CAD.
33. Goods eligible for the remission of customs duties, sales and excise taxes under the Postal Imports Remission Order or the Courier Imports Remission Order and subject to a surtax must be accounted for.
Corrections, re-determinations, and refunds
34. Corrections or adjustments to original declarations and requests for re-determinations are to be made in the prescribed form and manner under the relevant provisions of the Customs Act, in accordance with the procedures outlined in Memorandum D11-6-6 : ‘Reason to Believe’ and Self-Adjustments to Declarations of Origin, Tariff Classification, and Value for Duty and Memorandum D6-2-3: Refund of Duties.
35. If surtax was not correctly self-assessed or was self-assessed in error for commercial goods, then an adjustment to the CAD may be submitted via the CCP or via EDI/API. For more information on how to submit an adjustment for commercial goods, refer to Memorandum D17-2-1, Adjusting Commercial Accounting Declarations.
36. The origin, tariff classification, and value for duty of imported goods may be re-determined or further re-determined in accordance with the Customs Act and the Determination, Re-determination and Further Re-determination of Origin, Tariff Classification and Value for Duty Regulations. This may occur further to a self-adjustment. In so doing, as with customs duties and taxes, the CBSA may consider the applicability of any undeclared amount of surtax.
Examinations and verifications
37. Imported goods may be subject to examination at the time of importation and to post-release verification for compliance with the tariff classification, valuation, origin, and any other applicable provisions administered by the CBSA. In cases of non-compliance, in addition to the imposition of surtax, customs duties and taxes, penalties may be assessed, and interest may accrue on the amount owing.
Advance rulings for commercial importations
38. For predictability and certainty on how goods are to be accounted for, an application for a ruling pertaining to origin (Most-Favoured-Nation Tariff or non-Free Trade Agreement (FTA) Preferential Tariff Treatment), valuation, or marking can be made as a request for a National Customs Ruling (NCR). An NCR must be requested from the CBSA in advance of the importation of goods. Refer to Memorandum D11-11-1 National Customs Rulings for additional information.
39. For predictability and certainty on how goods are to be accounted for, an application for a ruling on the origin of goods and their entitlement to a preferential tariff treatment under Canada’s FTAs is to be made as a request for an advance ruling. Advance Rulings must be requested in advance of the importation of goods. Refer to Memorandum D11-4-16, Advance Rulings for Origin Under Free Trade Agreements for additional information.
40. Refer to Memorandum D11-11-3, Advance Rulings for Tariff Classification, for additional information on requesting an advance ruling on the tariff classification of goods.
Recourse – Surtax and appeal process
41. The imposition of a surtax by the Governor in Council, including the rate of that surtax, is not subject to appeal under the Customs Tariff or the Customs Act. However, the CBSA reviews accounting documents to ensure that the correct amount of surtax has been declared. Determinations, re-determinations and further re-determinations made by officers, which may include the applicability of the surtax, may be subject to appeal under the Customs Act.
42. In accordance with the Customs Act and section 12 of the Customs Tariff, individuals who receive a notice of re-determination or further re-determination under subsection 59(2) of the Customs Act may request a review under section 60 of the Customs Act. This request must be submitted within 90 days of the notice and only after all amounts owing as duties and interest in respect of the goods are paid, or security satisfactory to the Minister is provided for the total amount owing. For more information please refer to Memorandum D11-6-7: Request under Section 60 of the Customs Act for a Re-determination, a further Re-determination or a Review by the President of the Canada Border Services Agency.
Additional information
43. Refer to Memorandum D16-1-1, Information pertaining to the application, collection, and adjustment of a surtax, for additional information concerning the administration and enforcement of surtax orders under sections 53(2), 55(1), 60, 63(1), 68(1), 77.1(2), 77.6(2) or 78(1) of the Customs Tariff.
44. For more information call the Border Information Service (BIS) at 1-800-461-9999 (toll-free in Canada and the USA). If calling outside Canada and the United States, call 1-204-983-3500 or 1-506-636-5064. Long distance charges will apply. Our automated telephony service provides general information in English and French on CBSA programs, services and initiatives through recorded scripts. Live agents are also available to assist you Monday to Friday 8 am to 4 pm local time, as per time zones in Canada and USA (closed on federal statutory holidays). TTY is also available within Canada: 1-866-335-3237. Alternatively, you may send your enquiries using our Client Support Contact Form.
45. For questions related to the policy outlined in the Steel Goods and Aluminum Goods Surtax Order, please contact the Department of Finance: fin.simaconsult-lmsiconsult.fin@fin.gc.ca.
Original source: Customs Notice 25-28: Steel Goods and Aluminum Goods Surtax Order
