September 9, 2026

Canada’s Counter Tariffs Now in Effect

Canada’s Counter Tariffs on U.S. Goods Now in Effect

Canada’s counter tariffs on U.S. origin goods are now in effect. Surtaxes of 15%, 25% or 50% apply as of September 8th, and the steel and aluminum surtax increases to 50% for certain goods. The official Customs Notices were published on Sept. 7th and are available below:

Customs Notice 26-23 (United States Surtax Order 2026): https://www.cbsa-asfc.gc.ca/publications/cn-ad/cn26-23-eng.html

Customs Notice 25-11 (steel and aluminum, updated): https://www.cbsa-asfc.gc.ca/publications/cn-ad/cn25-11-eng.html

The official list of HS codes can be found here: 

https://www.canada.ca/en/department-finance/programs/international-trade-finance-policy/canadas-response-us-tariffs/complete-list-us-products-subject-to-counter-tariffs.html

  • Goods in transit to Canada before the order takes effect on September 8th, 2026, 12:01 ET are exempt.
  • There is no exemption for CUSMA-qualifying goods.
  • Subject goods are those eligible to be marked as originating in the United States, according to the Determination of Country of Origin for the Purpose of Marking Goods (CUSMA Countries) Regulations.
  • Per an updated OIC, Remission continues for certain goods in the public health, safety, national defense, healthcare, manufacturing/processing, and food/beverage packaging 

Remission Relief Information for U.S. Counter Tariffs

We are encouraging clients to review the remission options available to them, including applying for an importer-specific remission where impacted goods cannot be sourced elsewhere.

Pending approval of the Governor in Council, it is the government’s intention for the new counter tariffs to benefit from remission in line with existing relief.

  • Product and company-specific remission that has been implemented under the United States Surtax Remission Order will apply to the new tariff measures, in accordance with the terms of the Order.  For example, steel goods currently eligible for remission of the 25% tariff would benefit from relief of the 50% tariff. 
  • In addition, the new tariff measures will be eligible for horizontal remission under the United States Surtax Remission Order covering the following goods/purposes until June 30, 2027:
    • All goods for use by identified public health, public safety and national security entities
    • Steel goods for use in auto and aerospace manufacturing
    • Non-steel goods for use in manufacturing, processing, food and beverage packaging and agricultural production in Canada
  • Manufacturing and agricultural production are broadly defined as including all activities under NAICS Chapter 31-33 and NAICS Chapter 11 (including forestry, fishing and hunting).  Specifically, regarding sectors raised on the call today, inputs to fish and seafood processing, pet food manufacturing, and fishing in Canada are covered by this horizontal carve out. 

For goods not already eligible for remission, the Department is continuing to accept and assess requests for remission under the U.S. Remission Framework, which provides for remission in certain circumstances, e.g., where goods used as inputs cannot be sourced domestically.

Please see below for more information:

Process for requesting remission of tariffs that apply on certain goods from the U.S. – Canada.ca.

Duty Drawback

Duty drawback also remains an option for clients who will be exporting impacted products within four years of import. Please reach out to our drawbacks team at drawbacks@carson.ca to see if your exports are eligible.