In a word, yes. The removal of surtax remission, reduction of tariff rate quotas and introduction of steel derivatives has altered the landscape for most importers.
Canada maintains a non-stackable policy for its tariffs on steel and aluminum. Only one of the measures can apply to a particular good, following this order of precedence:
1. Tariffs on steel imports over the established tariff rate quotas for non-CUSMA countries;
2. Either: a) tariffs on U.S. steel and aluminum products; b) tariffs on Chinese steel and aluminum products; or c) tariffs on non-U.S. imports that contain steel melted and poured, or aluminum smelt and cast, in China;
3. tariffs on steel derivative products from all countries (effective December 26, 2025).
Effective July 31, 2025, on certain steel goods melted and poured in China and certain aluminum goods smelted and cast in China will be subject to 25% surtaxes.
The China Surtax Remission Order that removed surtaxes will expire December 31, 2025 and subject goods will have a 25% surtax applied.
The USA Surtax Remission Order is subject to the following changes:
- For steel goods, used for manufacturing, processing, food and beverage packaging, and agricultural production in Canada is extended to January 31, 2026 (this would represent the current OIC 25-0466C)
- For steel goods used for the manufacturing of motor vehicles, aerospace goods, and their parts, for which remission is extended to June 30, 2026.
- For aluminum goods used for manufacturing, processing, food and beverage packaging, and agricultural production in Canada remission is extended to June 30, 2026.
- For goods used for public health, health care, public safety and national security purposes remission is extended to June 30, 2026.
All other conditions will be subject to 25% surtaxes.
Effective December 26, 2025, tariff rate quota levels have been reduced to:
- 20 per cent of 2024 levels for non-free trade agreement (FTA) partners, and
- 75 per cent of 2024 levels for non-CUSMA FTA partners.
To avoid tariff rate quotas (TRQ), importers must be in possession of a valid import permit to avoid 50% surtaxes that came into effect June 27, 2025.
Importers can monitor tariff rate quota utilization on the Global Affairs Canada website.
Effective December 26, 2025, the Government of Canada is imposing 25 per cent tariffs on the full value of the steel derivative products.
Goods that are subject to a tariff under the China Surtax Order (2024), the United States Surtax Order (Steel and Aluminum 2025), the Order Imposing a Surtax on the Importation of Certain Steel Goods or the Steel Goods and Aluminum Goods Surtax Order are not subject to derivatives.