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CBSA Updates United States Surtax Orders Including Steel, Aluminum and Motor Vehicles (Updated)

Trade Update • Updated Sept. 11, 2025

Key Points

  • As of September 4, 2025, CBSA has updated five Customs Notices related to Canadian Surtax Orders. Of these, only one contains a value-based exemption.
  • Updates clarify surtax application to goods classified under Chapters 98 and 99 of Canada’s Customs Tariff.
  • Amended provisions are retroactive to the original entry into force of the respective surtax orders.
  • Importers may submit corrections or adjustments and claim refunds where applicable.
  • Customs Notice 25-10 repeals the United States Surtax Order (2025-1) effective September 1, 2025, with the exception of steel, aluminum and motor vehicles.
  • Customs Notice 25-11 replaces Schedule 1 with Schedule 2 for goods subject to surtax under the Steel and Aluminum Order.
  • Customs Notice 25-15 confirms that, effective April 9, 2025, U.S.-origin motor vehicles imported into Canada face a 25% surtax.
  • Schedules 1 and 2 of the Motor Vehicles surtax order detail the complete list of affected goods.
  • U.S. Surtax Remission Order (updated Aug. 29) to provide surtax relief on eligible goods.
  • List of HS Updates – U.S. goods subject to counter tariffs, updated Sept 1, 2025..
Flags of the United States and Canada symbolizing trade relations and surtax updates

The Canada Border Services Agency (CBSA) has issued updates to the United States Surtax Order (2025-1), the United States Surtax Order (Steel and Aluminum 2025) and the United States Surtax Order (Motor Vehicles 2025) in respect of eligible goods. These updates clarify surtax application, confirm exemptions, and outline procedures for corrections, adjustments, and refunds, including retroactive provisions and guidance for goods classified under Chapters 98 and 99 of Canada’s Customs Tariff.

Access: Complete list of U.S. good subject to Canadian counter tariffs (updated Sept. 4, 2025).

Clarification on Value-Based Exemptions (Sept. 4, 2025)

As of September 4, 2025, the CBSA has published updates to five Customs Notices related to Canadian Surtax Orders. Of these, only one order contains a provision allowing exemptions based on the value of goods. The other four do not.

Surtax Orders without Value-Based Exemptions

Surtax Order with Value-based Exemptions

Customs Notice 25-28: Steel Goods and Aluminum Goods Surtax Order (2025)

  • Steel Goods and Aluminum Goods Surtax Order (2025). Effective July 31, 2025, a 25% surtax applies to certain steel goods containing steel melted and poured in China and aluminum goods containing aluminum smelted and cast in China. The Order includes a value-based exemption:

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.

Previous Updates (Sept. 1, 2025)

Customs Notice 25-10:
United States Surtax Order (2025-1)

Updated (see paragraphs 5 and 6)

5. In accordance with the Order Amending and Repealing Certain Orders Made Under the Customs Tariff (United States Surtax), this notice has been updated to provide additional clarity regarding the application of surtaxes to goods that are classified under a tariff item of Chapters 98 or 99 of the Schedule to Canada’s Customs Tariff (see paragraphs 10 and 11). The amended provisions are retroactive to the date of entry into force of the surtax order. Importers may submit a correction/adjustment and receive a refund if applicable (see section “Corrections, re-determinations and refunds”). When making corrections/adjustments, importers are reminded to review the instructions for accounting detailed below (see section “Accounting”). This updated notice also provides clarifications in paragraphs 40 and 41.

6. Effective this Order is repealed.

Customs Notice 25-11:
United States Surtax Order (Steel and Aluminum 2025)

Updated: September 1, 2025 (see paragraph 6)

6. In accordance with the Order Amending and Repealing Certain Orders Made Under the Customs Tariff (United States Surtax), this notice has been updated to provide additional clarity regarding the application of surtaxes to goods that are classified under a tariff item of Chapters 98 or 99 of the Schedule to Canada’s Customs Tariff (see paragraphs 10, 11 and 12). The amended provisions are retroactive to the date of entry into force of the surtax order. Importers may submit a correction/adjustment and receive a refund if applicable (see section “Corrections, re-determinations and refunds”). When making corrections/adjustments, importers are reminded to review the instructions for accounting detailed below (see section “Accounting”). This updated notice also provides clarifications in paragraphs 38 and 39. Effective September 1, 2025, Schedule 1 of goods subject to the surtax under the United States Surtax Order (Steel and Aluminum 2025) is replaced with Schedule 2 of the Order Amending and Repealing Certain Orders Made Under the Customs Tariff (United States Surtax).

Update (as per CSCB)
Clarity on the use of tariff code 9971.00.00 with goods of Chapter 89:

Thus, goods classified under tariff item 9971.00.00 (which is found in Schedule 3 and Schedule 4) and also eligible for classification under Schedules 1 or 2, respectively, are subject to surtax. Vessels of chapter 89 are not found in Schedules 1 or 2 of the Order and, as such, are not subject to surtax, even when classified under 9971.00.00.

Justification:

(a) goods that are classified under any of the tariff items set out in Schedule 1 or 2;

(b) goods that are classified under any of the tariff items set out in Schedule 3 that are otherwise classifiable under a tariff item set out in Schedule 1; and

(c) goods that are classified under any of the tariff items set out in Schedule 4 that are otherwise classifiable under a tariff item set out in Schedule 2.

The amended provisions are retroactive to the date of entry into force of the surtax order. Importers may submit a correction/adjustment and receive a refund if applicable. When making corrections/adjustments, importers are reminded to review the instructions for accounting detailed in the Customs Notice 25-11.

Customs Notice 25-15:
United States Surtax Order (Motor Vehicles 2025)

Updated: September 1, 2025 (see paragraph 4 and 5)

4. In accordance with the Order Amending and Repealing Certain Orders Made Under the Customs Tariff (United States Surtax), this notice has been updated to provide additional clarity regarding the application of surtaxes to goods that are classified under a tariff item of Chapters 98 or 99 of the Schedule to Canada’s Customs Tariff (see paragraphs 11, 12 and 23). The amended provisions are retroactive to the date of entry into force of the surtax order. Importers may submit a correction/adjustment and receive a refund if applicable (see section “Corrections, re-determinations and refunds”). When making corrections/adjustments, importers are reminded to review the instructions for accounting detailed below (see section “Accounting”). This updated notice also provides clarifications in paragraphs 40 and 41.

Application

5. Effective , motor vehicles originating in the U.S. and imported into Canada are subject to a surtax in the amount of 25% of the value for duty in accordance with the United States Surtax Order (Motor Vehicles 2025). The value for duty is determined in accordance with sections 47 to 55 of the Customs Act.

Schedules 1 and 2 to the United States Surtax Order (Motor Vehicles 2025) contain a complete list of goods subject to the surtax.

Recover Your Surtax on Eligible Imports – GHY Can Help

If you’ve paid or are owing Canadian surtax on past imports of eligible goods, you may qualify for a refund. GHY will handle the process for you—filing corrections and adjustments on your behalf to recover what you’re owed. Acting now helps us move quickly to recover what you’re owed and avoid additional costs.

📩 Reach out today to get started: GTS@ghy.com

For future imports, the OIC remission number can be applied to relieve Canadian surtax on your eligible goods. Your Client Care Manager can work with you to ensure that we are applying the relief to the correct products at time of importation.

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.

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