CBSA issued Customs Notice 25-28, CBSA Customs Notice 25-28 – Steel and Aluminum Goods
This outline is intended to help you understand how the surtax may apply to your imported goods and what documentation may be required.
What Products Are Affected?
- Aluminum Goods
These include:- Products classified under tariff items listed in Part 2 of the schedule.
- Products classified under Chapter 99 of the List of Tariff Provisions if they would otherwise fall under Part 2.
- Steel Goods
These include:- Products classified under tariff items listed in Part 1 of the schedule.
- Products classified under Chapter 99, if they would otherwise fall under Part 1.
Key Focus: Origin of Materials
- Steel Melted and Poured in China
Goods are considered to contain Chinese steel if any portion of the raw steel was first melted and poured into solid form in China. - Aluminum Smelted and Cast in China
Goods are considered to contain Chinese aluminum if:- The largest (or second-largest) volume of primary aluminum was produced in China, or
- The aluminum was most recently liquified and cast into solid form in China.
Surtax Application
- Steel Goods
A 25% surtax applies to steel goods containing Chinese steel, based on the value for duty under the Customs Act. - Aluminum Goods
A 25% surtax applies to aluminum goods containing Chinese aluminum, also based on the value for duty.
Documentation Requirements
To avoid automatic surtax application, importers must provide, upon request:
- For steel goods:
- A certificate, report, or commercial invoice confirming the steel is not from China.
- For aluminum goods:
- A certificate or report confirming the aluminum was produced and cast outside China, or
- A commercial invoice demonstrating the same.
If this documentation is not provided, the goods will be deemed to contain Chinese-origin materials, and the surtax will apply.
Special Attention: Amendments Coming into Force
- September 22, 2025:
Updates to documentation requirements for steel and aluminum goods will take effect, requiring certificates (i.e., mill test or material test certificate; a certificate of conformance, compliance, or analysis; a metallurgical test report; or a chemical analysis certificate specifically, rather than broader documentation) to demonstrate non-Chinese origin.
Exemptions
The surtax does not apply to:
- Shipments valued at $5,000 CAD or less in a single declaration.
- Goods already subject to the China Surtax Order (2024).
- Casual goods, as defined in applicable regulations.
- Goods classified under Chapter 98 of the List of Tariff Provisions.
- Goods that originate in the United States under CUSMA rules.
- Goods in transit to Canada as of the effective date of this Order.
Effective Dates
- The Order takes effect on July 31, 2025, unless registered later, in which case it takes effect upon registration.
- Amendments noted in Sections 6 and 7 of the CN will come into force on September 22, 2025.
These measures are part of a broader effort to stabilize Canada’s steel market and ensure fair competition while ensuring businesses like yours can continue to access the materials you need.