‍Applicable Goods

Beginning August 1, 2025, a 25% surtax now applies to certain steel and aluminum goods imported into Canada that have been melted, poured, smelted, or cast in China. The surtax applies if the raw steel or aluminum, or any portion of it, was first produced in a liquid state and poured into its first solid state in China. This is applicable regardless of the final country of origin of the manufactured goods, as long as the initial melting or casting took place in China.

‍Proof of Origin and Documentation

To demonstrate that imported goods are not subject to the surtax, importers must provide documentation that proves the country of melt and pour (COM) or country of smelt and cast (CSC) is not China.

• From July 31, 2025, to September 21, 2025: Acceptable documents include a commercial invoice, an analysis certificate, or a metallurgical report.
• From September 22, 2025, onwards: Only an analysis certificate or a metallurgical report will be considered acceptable documentation. Commercial invoices will no longer be sufficient for this purpose.

Exemptions

There are several specific exemptions from the surtax:

• CUSMA Compliant Goods: Goods that originate in the United States, as defined by the Canada-United States-Mexico Agreement (CUSMA), are exempt regardless if the steel or aluminum, or any portion of it, was first produced in a liquid state and poured into its first solid state in China.
• De Minimis Value: The surtax does not apply to steel and aluminum goods with a cumulative value for duty of $5,000 (CDN) or less under a single Commercial Accounting Declaration (CAD). The $5,000 limit applies only to the value of goods subject to the surtax, not to the value of any other non-subject goods in the shipment.
• Casual Goods: The surtax does not apply to certain casual goods, which are defined as goods for personal use and not for resale.
• China Surtax Order: Steel and aluminum goods that are subject to a surtax under the China Surtax Order (2024, CN 24-36) are not subject to the surtax.

We understand that navigating customs regulations and trade policies can be complex. As your trusted broker, we are here to simplify this process for you, ensuring your shipments comply with all requirements and avoid any unnecessary delays or surtaxes. Please feel free to reach out to us with any questions or if you need assistance with your next shipment.

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Further Reading

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Link to Publication CN 25-28: 

https://www.cbsa-asfc.gc.ca/publications/cn-ad/cn25-28-eng.html

‍Schedule of Subject HS Codes: https://orders-in-council.canada.ca/attachment.php?attach=47486&lang=en 

‍CUSMA Rules of Origin:

https://www.cbsa-asfc.gc.ca/publications/dm-md/d11/d11-5-17-eng.html 

‍China Surtax Order (2024):

https://www.cbsa-asfc.gc.ca/publications/cn-ad/cn24-36-eng.html

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