Canada Updates China Surtax Remission Order

Trade Update • February 25, 2026

Key Points

• Remission applies to eligible goods under the China Surtax Remission Order (2024), effective January 31, 2025.
• Relief covers certain goods listed in Schedule 1 and Schedule 2, including steel and aluminum products.
• Importers must meet specific conditions, including time-bound import periods and no duplicate relief claims.
• Claims require supporting documentation and use of designated special authorization codes.
• Corrections and adjustments may be filed through CARM, subject to defined reason codes and deadlines.

O​​​​​​​​​​n February 4, 2026, the Canada Border Services Agency (CBSA) posted an update to Customs Notice 25-05 to implement changes to the China Surtax Remission Order (2024). The Order, effective January 31, 2025, grants relief from surtaxes paid or payable under the China Surtax Order (2024), including certain steel and aluminum goods. Remission applies under section 115 of the Customs Tariff and aligns with amendments to the original Order. The CBSA administers the program and requires importers to comply with detailed eligibility criteria, documentation standards, and reporting procedures.

Scope of Remission

Schedule 1 Goods

Remission applies to goods listed in Schedule 1 if:

• The goods are not subject to a finding or order under the Special Import Measures Act at the time of import.
• The goods were imported between October 22, 2024, and December 31, 2026.
• No other surtax relief claim has been granted under the Customs Tariff.
• The goods are not exported to the United States in the same condition.
• The importer submits a claim within two years from the date of importation.

Schedule 2 Goods

For goods listed in Schedule 2:

• Only the importer identified by business number may claim remission.
• Imports must occur within the specified period in the Schedule.
• Any additional listed conditions must be satisfied.
• Claims must not duplicate other relief under the Customs Tariff.

Eligible Products

The updated schedules cover a broad range of steel and aluminum goods, including:

• Stainless steel sheets, plates, bars, and wires (ASTM A240, A276, A519 specifications).
• Silicon grain-oriented and specialty steel products.
• Seamless line pipes, drill pipes, and mechanical tubes.
• Aluminum plates, sheets, strips, coils, and foils (including aerospace-grade alloys).
• Hollow profiles, extrusions, and alloy bars.
• Certain non-plug-in hybrid passenger vehicles, subject to volume limits.

Remission applies strictly to goods that match the detailed technical descriptions under the specified tariff items.

How to Claim Remission

At the time of Import (Commercial Goods)

Importers must enter the applicable special authorization code in the Special Authority OIC field on the Commercial Accounting Declaration (CAD). Surtax remains declared but offset through the remission code.

Each Schedule 1 and Schedule 2 item corresponds to a specific authorization code (e.g., 25-054A through 25-054M). Importers must select the correct code based on:

• Tariff classification
• Item number
• Import period
• Business number (where applicable)

Non-Commercial Goods

For qualifying non-commercial imports accounted for on Form BSF715 or BSF715-1, surtax will not be collected at time of accounting when remission conditions are met.

Corrections and Adjustments

If remission was not claimed at import:

• Before CAD payment due date: Submit a correction through CARM using reason code R5-00-COT.
• After payment due date: Submit an adjustment using reason code R2-74-1-GR-53 to obtain a refund.
• Non-commercial goods: File Form B2G (CBSA Informal Adjustment Request).

The CBSA may re-determine origin, tariff classification, or value for duty. Additional surtax, duties, penalties, and interest may apply in cases of non-compliance.

Compliance and Verification

Imported goods may undergo examination at import or post-release verification. The CBSA may assess surtax and penalties if it identifies incorrect classification, valuation, or origin declarations.

Importers may request advance rulings for tariff classification or origin to support accurate accounting before importation.

Practical Considerations for Importers

• Review technical product specifications against the updated Schedules.
• Confirm applicable import periods and business number eligibility.
• Maintain complete documentation (bill of lading, invoice, sales contract, waybill).
• Monitor deadlines for remission claims and post-entry adjustments.

In case of discrepancy, the official schedules in the China Surtax Remission Order (2024) prevail over the Customs Notice version.

How GHY Can Help?

GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.

By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.

Contact Us Today! Booking a Meeting, email consult@ghy.com, or call +1 (800) 667-0771.