CBSA Announces Changes to U.S. Surtax Remission Order (Updated)

Trade Update • Updated Jan. 5, 2025

Key Points

• The Canada Border Services Agency (CBSA) has updated the United States Surtax Remission Order to provide relief from surtaxes on eligible goods.

• Remission applies to goods used in public health, health care, public safety, and national security, as well as in Canadian manufacturing, processing, and food and beverage packaging.

• Remission applies to goods imported between the surtax effective date and October 16, 2025.

• Eligible relief covers surtaxes imposed under the United States Surtax Order (2025-1), Steel and Aluminum 2025, and Motor Vehicles 2025.

• Goods listed under specific tariff classifications in the Order’s schedules also qualify for remission.

• Claims must be filed within two years of importation and supported by proper documentation, with limited eligibility for courier low value shipments.
  

• The Remission Order has been extended to allow certain steel, aluminum, aerospace, and motor vehicle-related goods to qualify for surtax relief up to June 30, 2026.
• The CBSA’s latest updates clarify which goods qualify for surtax relief, the applicable import deadlines, and the specific authorization codes needed to claim remission under the United States Surtax Remission Order (2025).
• CBSA also clarifies that Steel Derivative Goods Surtax applies to goods under HS codes 3925.20.00.10 and 3925.20.00.90, even if they contain no steel.
• Latest: The Department of Finance issued guidance on requesting remission of the 25% Steel Derivative Goods Surtax, outlining eligibility, required documentation, and review procedures.

The Canada Border Services Agency (CBSA) has updated the United States Surtax Remission Order – Customs Notice 25-19, which is intended to minimize the negative effects of the surtaxes on Canadian companies and entities by providing relief for goods that are used in Canadian manufacturing, processing and food and beverage packaging, and for those used to support public health, health care, public safety, and national security objectives.

The Remission Order allows the relief of surtaxes paid or payable by the United States Surtax Order (2025-1), the United States Surtax Order (Steel and Aluminum 2025), or the United States Surtax Order (Motor Vehicles 2025) (Surtax Order) in respect of eligible goods.

See the latest updates. The latest changes to the U.S. Surtax Remission Order appear toward the bottom of the article. Click on any section below to jump directly to the latest updates you want to review.

• Steel Derivative Goods Surtax (Remission Guidance from the Dept. of Finance)
• December 24 Updates
• Clarification on 3925.20 Surtax Application
• December 11 Updates

Key Changes as Stated in the Remission Order (2025)

New Section After Section 3: Remission — United States Surtax Order (Steel and Aluminum 2025)

3.1 Subject to section 5, remission is granted of surtaxes paid or payable under the United States Surtax Order (Steel and Aluminum 2025) in respect of goods imported

(a) for use in the manufacture of motor vehicles or chassis for motor vehicles or in the manufacture of parts of or accessories for motor vehicles or chassis for motor vehicles; or

(b) for use in aircraft, ground flying trainers or spacecraft or in parts of aircraft, ground flying trainers or spacecraft.

Replacement of Paragraph 5(a):

The updated text is as follows:

(a) in the case of a good in respect of which remission is granted under section 1 or 2, it is imported into Canada before July 1, 2026;

(a.01) in the case of a good that is referred to in Schedule 1 to the United States Surtax Order (Steel and Aluminum 2025) and in respect of which remission is granted under section 3, it is imported into Canada before July 1, 2026;

(a.02) in the case of a good that is referred to in Schedule 2 to the United States Surtax Order (Steel and Aluminum 2025) and in respect of which remission is granted under section 3, it is imported into Canada before February 1, 2026;

(a.03) in the case of a good in respect of which remission is granted under section 3.1, it is imported into Canada on or after February 1, 2026 and before July 1, 2026;

(a.04) in the case of a good referred to in Schedule 3, it is imported into Canada before the date specified in column 3 of that Schedule;

Added after Section 5: For greater certainty

5.1 For greater certainty, there is no time limit that applies in respect of the importation of goods referred to in section 4.3 or in Schedule 1, 2 or 5.

Previous Updates (Aug. 29, 2025)

The CBSA released Customs Notice 25-19 on August 29, 2025, updating the United States Surtax Remission Order with new remission provisions, clarified eligibility rules, and revised conditions of relief, including guidance for CLVS imports.

Remission for Public Health, Public Safety, and National Security

Remission is granted of surtaxes paid or payable under the United States Surtax Order (2025-1), the United States Surtax Order (Steel and Aluminum 2025) or the United States Surtax Order (Motor Vehicles 2025) in respect of goods imported by or on behalf of:

• A government health research organization or clinical health research organization;
• An organization that produces or stores medical countermeasures, including pharmaceuticals or medical devices;
• The office of a public health official, as defined in subsection C.10.001(1) of the Food and Drug Regulations;
• An organization that provides ambulance or other emergency response services;
• A firefighting service;
• A law enforcement agency;
• A federal or provincial correctional service;
• The Department of National Defence;
• The Canadian Forces; or
• The Canadian Security Intelligence Service.

Remission for Health Care

Remission is granted for goods imported under the above surtax orders for use in medically necessary health care services, including services provided at:

• Hospitals,
• Health care or dental clinics,
• Medical, dental or diagnostic laboratories, or
• Long-term care facilities;

Or by or on behalf of:

• An entity that provides products or services related to blood, cells, tissues or organs for medically necessary health care, or
• A federal, provincial, local or Indigenous health authority.

Remission for Manufacture, Processing, or Packaging

Remission is granted of surtaxes paid or payable under the United States Surtax Order (2025-1) or the United States Surtax Order (Steel and Aluminum 2025) for goods imported for use in Canada in manufacturing, processing, or packaging of food or beverages.

Additional clarifications:

• The end product may be exported; it does not have to remain in Canada.
• Remission is available to the importer of record or consignee who conducts the covered activities or goods imported for immediate sale to entities conducting manufacturing, processing, or packaging.
• Supporting documentation (contracts, invoices) must be maintained to substantiate these activities.
• Only direct inputs and manufacturing machinery integral to the finished product are eligible; indirect inputs (lubricants, fuels, maintenance supplies) are not.
• Packaging remission is limited to products used for human food consumption and not for animal food or personal use containers.

Remission for Goods in the Order’s Schedule

Remission is granted under section 4 and 5 of the Order for surtaxes paid or payable in respect of goods listed in the schedules to the Order classified under specified tariff classification numbers.

Additional Remission Provisions by Schedule Classifications

• Section 4.1 and 5: Remission is granted for goods referred to in Schedule 2 or 3 of the Order under the United States Surtax Order (2025-1) or the United States Surtax Order (Steel and Aluminum 2025) based on tariff classification numbers set out respectively in columns 1 and 2 of those schedules.
• Section 4.2 and 5: Remission is granted for goods referred to in column 3 of Schedule 4, classified under tariff classification numbers in column 2 of Schedule 4, under the United States Surtax Order (2025-1) or the Steel and Aluminum 2025 Order.
• Section 4.3 and 5: Remission is granted for surtaxes paid under the United States Surtax Order (Motor Vehicles 2025) in respect of specific tariff classifications described in the Order.

Conditions of Relief

Remission is granted on the following conditions:

• The goods were imported into Canada on or after the date the surtax came into force and before October 16, 2025;
• No other claim for relief of the surtax has been granted under the Customs Tariff for the good;
• The claimant makes a remission claim to the Minister of Public Safety and Emergency Preparedness within two years after the date of importation;
• Claims must be supported by relevant import documentation such as Commercial Accounting Document (CAD), purchase orders, commercial invoices, bills of lading, and others.

Courier Low Value Shipment (CLVS) Program Relief

For goods imported under the CLVS program, the majority will not be eligible for remission. If eligible goods with surtax applied are imported via CLVS, remission can be claimed by adjusting the Customs Accounting Declaration via the CBSA’s Commercial Client Portal (CCP) using the appropriate Special authorization code.

Additional details can be found here:

OIC United States Surtax Remission Order (2025)
Customs Notice 25-19: United States Surtax Remission Order (2025)

Latest Updates

Steel Derivative Goods Surtax (Remission Guidance from the Dept. of Finance)

Importers can request remission of the 25% Steel Derivative Goods Surtax by submitting applications to the Department of Finance Canada at remissions‑remises@fin.gc.ca. Each request is evaluated individually, and relief is granted only in exceptional circumstances, such as:

• The goods or suitable substitutes cannot be obtained from Canadian suppliers.
• Situations that could cause serious negative effects on the Canadian economy.

Applications should include documentation to support the claim, including:

• Product information: tariff codes, technical specifications, and intended use.
• Evidence of sourcing efforts: proof that the goods or substitutes were sought domestically.
• Contract or technical constraints: any binding agreements or specifications that prevent alternative sourcing.
• Financial impact: quantification of how the surtax affects costs or operations.
• Consent to share non-confidential information: allowing engagement with domestic producers to verify availability.

Remission requests should also consider existing statutory exemptions, including:

• Goods already in transit when the surtax came into effect.
• Imports used in automotive or aerospace production until July 1, 2026.
• Other narrowly defined cases outlined in the Steel Derivative Goods Surtax Order.

The Department of Finance reviews requests in coordination with other relevant federal departments. No fixed timelines are set for decisions, and applicants may be asked for additional information or clarification during the review process.

December 24 Updates

The CBSA’s latest updates, as of December 24, 2025, provide guidance on eligible goods, import deadlines, and special authorization codes for remission claims. Relief applies to goods for manufacturing, processing, packaging, health care, public safety, and national security.

Below are the key changes and a few clarifications, notes, and references:

Remission for Motor Vehicles and Aerospace (Section 3.1)

Relief of surtaxes applies to goods imported for the manufacture of motor vehicles, vehicle parts, aircraft, ground flying trainers, or spacecraft. Goods imported under this provision must enter Canada between February 1, 2026, and July 1, 2026.

Time Limits for Importation

• Goods eligible under sections 1 or 2 must be imported before July 1, 2026.
• Goods listed in Schedule 1 must enter before July 1, 2026.
• Goods in Schedule 2 must enter before February 1, 2026.
• Goods in Schedule 3 must enter before the date specified in column 3 of that schedule.

Eligibility for Remission (Sections 1 & 2)

Companies or commercial importers not importing goods for use by an eligible entity listed in Section 1 or subsection 2(b) are not eligible for remission.

Agricultural Products (Section 30)

Remission covers goods imported for activities under NAICS Chapter 11, including agriculture, forestry, fishing, and hunting.

Packaging Clarification

For packaging, only the imported product used for packaging qualifies. The good being packaged does not qualify unless it independently meets requirements for manufacturing or processing. For example, imported empty aluminum cans for packaging peanuts may qualify, while the peanuts themselves may not.

Special Authorization Codes

Use the following codes for remission claims, depending on the type of import:

• 25-0466A: Public Health, Public Safety, and National Security
• 25-0466B: Health Care
• 25-0466C: Manufacture, Processing, or Packaging
• 25-0466S01: Motor vehicle or aircraft/spacecraft manufacturing, including parts
  • 25-0466Q01: Schedule 4
  • 25-0466R01–R09: Schedule 4.1
  • 25-0466N: Motor vehicles and all-terrain vehicles, Schedule 5

Historical Note: Section 45 retains codes for Schedule 4 under pre-October 15, 2025 amendments. Importers should follow the updated codes (Sections 46–48) for current claims.

3925.20 Surtax Clarification

The Canadian Society of Customs Brokers (CSCB) asked the CBSA whether the surtax applies to 3925.20 goods that do not contain steel. The CBSA confirmed that:

• Goods under 3925.20.00.10 and 3925.20.00.90 are covered by the surtax.
• Exemptions include:
  • Goods already subject to other designated surtax orders
  • Casual goods under Canadian regulations
  • Items under Chapter 98 of the Customs Tariff
  • Imports before July 1, 2026 for manufacturing motor vehicles, aircraft, or related parts
  • Utility wind towers (tariff 7308.20.00) for eligible projects west of the Ontario–Manitoba border
  • Goods already in transit to Canada when the order took effect

December 11 Updates

On December 11, 2025, Canada issued the Order Amending the United States Surtax Remission Order (2025) under section 115 of the Customs Tariff. Below is a summary of the key changes.

Remission Order Entry into Force: December 11, 2025. Full text published in the Canada Gazette on December 31, 2025.

Horizontal Relief Extended:

• Steel goods for manufacturing, processing, food and beverage packaging, and agricultural production: extended to January 31, 2026.
• Steel goods for aerospace, motor vehicles, or parts thereof: extended to June 30, 2026 (Section 3.1).
• Aluminum goods for manufacturing, processing, food and beverage packaging, and agricultural production: extended to June 30, 2026.
• Goods used for public health, health care, public safety, or national security: extended to June 30, 2026 (Sections 1 and 2).

Application of Remission: CBSA will administer claims; special authorization codes are required for submissions. Further guidance will be published in CBSA’s Customs Notice.

Key Dates for Importation under Updated Order:

• Goods under Sections 1 or 2: before July 1, 2026.
• Schedule 1 goods under Section 3: before July 1, 2026.
• Schedule 2 goods under Section 3: before February 1, 2026.
• Section 3.1 goods: February 1 – July 1, 2026.
• Schedule 3 goods: before the date specified in the schedule.

No Time Limit: Goods in Section 4.3 or Schedules 1, 2, or 5 have no import time limit.

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.

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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.

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