News

U.S. Bars Certain Canadian Alcohol, Dairy and Vehicle Products Starting September 29

As of September 29, 2026 at 12:01 a.m. ET, the U.S. will no longer allow certain Canadian products into the country. Only tariff lines listed in the annexes are covered: Alcohol Annex (Proclamation 11061), Dairy Annex (Proclamation 11062) and Motor Vehicle Annex (Proclamation 11063). The list of barred products includes alcohol, whey, molasses and large motorcycles.

• Covered goods can’t be entered for consumption, admitted to an FTZ or bonded warehouse, or moved in-bond. CBP will reject these entries and cancel unreleased ACE entries at the cut-off.
• Alcohol is banned only where it meets a scope limitation in the Alcohol Annex (for example, “Packaged” means direct-to-consumer bottles, cans, boxes and kegs). Other alcohol can still be imported at the 50% duty.
• Goods imported, or placed in an FTZ or bonded warehouse, before the cut-off can still be entered or withdrawn for consumption at the 50% duty.
• Watch for ACE rejects 239, 335 and 886 (HTS not allowed or prohibited for country of origin).

Please check your HS codes against the annexes before September 29 and plan for shipments in transit. Please reach out to Carson with questions about specific products or shipments.

CITT Rescinds Anti-Dumping and Countervailing Duty Order on Chinese Solar Modules

On September 17, 2026, the CITT rescinded its order on photovoltaic modules and laminates from China. Anti-dumping and countervailing duties no longer apply to new imports of these products.

The CBSA will automatically refund these duties paid on eligible goods released on or after March 25, 2026.. For goods released on or after March 25, 2026, any outstanding re-determination process will be terminated and automatic refunds will be applied to those goods.

Goods released before March 25, 2026 are not eligible for a refund due to rescinding of the order. Assessments and reassessments relating to those earlier releases will continue.

Please read the notice for more information, or contact Carson for assistance.

IEEPA tariff refunds – Phase 3 launches October 6 For Early Plaintiffs

CBP has confirmed it will deploy Phase 3 of its CAPE refund program in ACE on Tuesday, October 6. This phase covers the older, finally liquidated entries that the Court of International Trade has ordered CBP to reliquidate, so it applies to importers who filed at the CIT. For importers who filed suit by July 30, you’ll be able to file Phase 3 declarations starting October 6. If your suit began after July 30, CBP says separate instructions are coming

If you didn’t file at the CIT, nothing changes for you here; Phases 1 and 2 remain the route for eligible entries.

CBP is currently sitting on more than 20,000 approved refunds, worth roughly $1.3 billion, that can’t be paid out because the importer never added banking (ACH) details in ACE. If you’re expecting a refund under any phase and haven’t set that up, please reach out to Carson for assistance.

CBP starts voiding importer of record (IOR) numbers this Friday, September 18

Beginning Friday, CBP will void importer numbers where the information on file (CBP Form 5106) is inaccurate or incomplete. A voided number can’t be used to make entry, meaning your shipment stops at the border with no advance warning.

The three things CBP is focused on: your physical business address (not a broker, forwarder, P.O. box or registered agent), an email address that belongs to your company (not a service provider), and a working phone number tied to your business. Non-resident importers and anyone who set up their IOR through a third party are the most likely to have incorrect details on file.

A voided IOR number could take more than 5 business days for the CBP to reinstate, so if you haven’t confirmed your 5106 details recently, please check in the ACE portal or contact us.

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.

Carson is reminding clients to prepare ahead of Canada’s counter tariffs, which are set to take effect following the long weekend, on September 8th. The CBSA has yet to issue an official Customs Notice for the counter tariffs.

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

If you are unsure if these tariffs will affect you, please request an impact report from us (consulting@carson.ca)

Please also review the below information on how to obtain a remission, or claim tariffs through a drawback if surtaxable goods are later exported.

Remission Relief Information for New U.S. Counter Tariffs

In advance of Canada’s upcoming retaliatory 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.

Remission Relief Information for New U.S. Counter Tariffs

In advance of Canada’s upcoming retaliatory 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 goods from Canada within four years of import. Please reach out to our drawbacks team at drawbacks@carson.ca to see if your exports are eligible.

Impact Reports Now Available For Retaliatory Tariffs

Please reach out to our consulting inbox (consulting@carson.ca) for an impact report to see how Canada’s upcoming Sept. 8th retaliatory tariffs could impact your business (based on prior activity).

The Government of Canada has announced its response to the U.S. Section 338 tariffs and released information on both the proposed counter-tariff measures and support programs for Canadian workers and businesses affected by the tariffs.

The list of products is available below and is set to take effect on September 8, 2026

• List of products from the United States subject to counter-tariffs effective September 8, 2026:
  View the product list
• Support for Canadian workers and businesses affected by U.S. tariffs: View the support measures

MPF Increase Effective October 1, 2026

CBP has published its annual inflation adjustment to customs user fees for fiscal year 2027. Effective October 1, 2026, the Merchandise Processing Fee (MPF) will increase as follows:

• Ad valorem rate: unchanged at 0.3464%
• Minimum formal MPF: $33.58 to $34.58
• Maximum formal MPF: $651.50 to $670.86
• Informal Entry/Release (automated):$2.77

Other user fees are also adjusting, including the dutiable mail fee ($7.61), express consignment carrier fee ($1.38 per bill), commercial truck arrival fee ($7.60), and permit fee ($190.88)

See here for more details: https://www.federalregister.gov/documents/2026/07/31/2026-15530/customs-user-fees-to-be-adjusted-for-inflation-in-fiscal-year-2027

Following the enactment of section 338 tariffs on Canadian origin goods, PM Mark Carney of Canada provided an update and announced that retaliatory tariffs on U.S. origin goods will arrive in September. 

No official details of the tariffs have been released, but according to PM Carney’s announcement sectors such as U.S. steel, dairy, appliances, agricultural equipment, pulp and paper, electronics will be targeted with “dollar for dollar” tariffs

Please read here for more details: 

https://www.pm.gc.ca/en/news/speeches/2026/08/22/prime-minister-carney-delivers-remarks-canada-us-trade-negotiations

CBP Guidance Issued for Section 338 Tariffs on Canadian Origin Good

U.S. Customs has issued their formal guidance on how the new section 338 tariffs apply on Canadian goods. You can find the full details, including impacted HS codes and chapter 99 details, here.

What Section 338 means for your shipments to the USA:

• CUSMA/USMCA does not exempt these duties.
• Duties stack. The new 50% is charged on top of the regular duty owed, with an exemption for goods already subject to section 232 (steel/aluminum tariffs)
• Advance duty payment may be required for entries on or after August 21. Late payment risks interest, cargo holds, mandatory cash payment, and other CBP action.
• Shipments may face delays.

The three-day pause has expired. Effective 9:01 p.m. PST Friday, Aug. 21 (12:01 a.m. ET Saturday, Aug. 22), the 50% Section 338 tariffs on certain Canadian-origin goods are in effect.

The additional ad valorem duties imposed in Proclamations 11046, 11047, and 11048 took effect at 12:01 a.m. ET on Saturday, Aug. 22. Canadian-origin goods classified under the covered provisions are now subject to the additional 50% duty at the time of entry.

What this means for your shipments:

• CUSMA/USMCA does not exempt these duties.
• Duties stack. The new 50% is charged on top of the regular duty owed.
• Confirm crossing times with your carrier.
• Advance duty payment may be required for entries on or after August 21. Late payment risks interest, cargo holds, mandatory cash payment, and other CBP action.
• Shipments may face delays.

Please work with your trucking partners and carriers if you wish to reschedule any importations to the US at this time.

President Trump announced yesterday evening, Aug. 18, that he would pause the 50% Section 338 tariffs on an array of Canadian products for three days as the U.S. and Canada continue their trade negotiations. The tariffs were initially scheduled to take effect this Wednesday, Aug. 19, at 12:01 a.m. ET.

“After considering the information, opinions, and recommendations that have been provided to me by senior executive branch officials, among other relevant information and considerations, I determine that in these circumstances, the public interest requires suspending for a period of 3 days the additional ad valorem duties imposed in Proclamation 11046, 11047, and 11048,” the president said. 

The presidential action states the effective date of the additional ad valorem duties imposed in Proclamations 11046, 11047, and 11048 shall now be 12:01 a.m. ET on Aug. 22

Sparing a last minute deal, a new 50% tariff on certain products of Canada is set to take effect tonight. Talks between Ottawa and Washington are ongoing, but as of this bulletin no delay, suspension, or carve-out has been announced.

Scope of the New 338 Tariffs

Please review the annexes below to determine if the tariffs will impact you:

• Dairy proclamation — “Imposing Additional Duties to Offset Canadian Discrimination Against the Commerce of the United States with Respect to Dairy”: Annex I | Annex II
• Alcoholic beverages proclamation — “Imposing Additional Duties to Offset Canadian Discrimination Against the Commerce of the United States with Respect to Alcoholic Beverages”: Annex I | Annex II
• Motor vehicles proclamation — “Imposing Additional Duties to Offset Canadian Discrimination Against the Commerce of the United States with Respect to Motor Vehicles”: Annex I | Annex II

Key points

The entry date matters. The 50% duty applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on August 19 — not the date of shipment, order, or border crossing. No in-transit exemption has been announced.

CUSMA/USMCA does not exempt covered goods. The 50% duty applies regardless of CUSMA eligibility. Goods that currently enter duty-free under a valid CUSMA claim will still owe the additional 50%. A valid CUSMA (or TPL for some apparel products) is still required to avoid regular duty.

The duty stacks. The new rate is charged in addition to the duty otherwise owed under the regular HTS subheading, along with any other applicable duties, taxes, and fees.

Narrow exclusions. Energy products, potash, fish, and critical minerals are excluded, as are articles already subject to Section 232 duties (such as steel, aluminum, copper, automobiles and parts, and lumber), which continue to pay their existing Section 232 rates instead.

Please contact Carson for assistance