CBSA Issues Steel Goods and Aluminum Goods Surtax Order

Overview 

Effective July 31, 2025, certain steel goods imported into Canada that contain steel melted and poured in China, and certain aluminum goods that contain aluminum smelted and cast in China, are subject to a surtax of 25% of the value for duty. 

What Importers Need to Know  

Subject Goods 

Goods impacted by this order include those: 

1. Containing steel with the country of melt and pour (COM) in China if the raw steel, or any portion of the raw steel, contained in the goods was first produced in a liquid state in a steel-making furnace and poured into its first solid state in China.
   
2. Containing aluminum with the country of smelt and cast (CSC) in China if: 

• the largest volume or, if applicable, second-largest volume of primary aluminum contained in the goods was produced in China; or 

• the aluminum contained in the goods was most recently liquified and cast into a solid state — whether as a semi-finished or finished aluminum product — in China. 
  
  

Documentation Requirements: 

Effective September 22, 2025, a commercial invoice, report or certificate will no longer be acceptable for the purposes of demonstrating COM or CSC. Only the following certificates will be accepted:  

• Mill test certificate, mill test report or material test certificate 

• Certificate of conformance, compliance, inspection or analysis 

• Certified inspection report 

• Metallurgical test report 

• Chemical analysis certificate 

Important to note: if the proper documentation is not presented upon request by an officer or is not considered acceptable upon review, the importer will be required to pay the applicable surtax. 

Exceptions to Surtax  

• Steel and aluminum goods in transit to Canada on the date on which the surtax comes into force (with proof).  

• Steel and aluminum goods that originate in the United States, as determined in accordance with the Determination of Country of Origin for the Purpose of Marking Goods (CUSMA Countries) Regulations.

• 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.  

• Steel and aluminum goods that are subject to a surtax under the China Surtax Order (2024). 

• Casual goods as defined in section 2 of the Persons Authorized to Account for Casual Goods Regulations.

• Steel and aluminum goods classified under Chapter 98 of the Customs Tariff, even if the goods are otherwise classifiable under a tariff item set out in the schedule. 

Sources:   

• Government of Canada – Steel Goods and Aluminum Goods Surtax Order 
• CBSA – Customs Notice 25-28  
  
  

Delmar Support 

Our Customs Advisory and Consulting experts remain available to assist with important questions on the topic at hand. Delmar will continue to provide pertinent updates from the Government of Canada as they become available.   
 
For additional information and assistance, please contact your local Delmar Representative.