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Tariffs and Trade Policy Resource Centre

Reduce uncertainty. Inform strategy. Protect value.

Companies operating in North America are grappling with a new trade environment. Court decisions overturn tariff policies. Temporary import surcharges replace permanent ones. Evolving national security measures reshape what’s actually in effect. Rapid shifts in legal authority and policy tools have created new cost exposures, refund considerations, and compliance challenges for Canadian businesses selling into or operating in the US.

Tariffs are no longer a static cost to manage. They’re part of a dynamic policy environment that can change quickly, creating downstream impacts across pricing, supply chains, tax, and financial reporting. Companies that proactively align trade compliance, supply chain strategy, tax planning, and contract management will be better positioned to manage risk, capture recovery opportunities, and compete amid ongoing volatility.

How do US tariffs affect Canadian businesses?

Evolving tariffs and other trade actions can raise costs for Canadian companies and reshape their competitiveness in the US market. The impact depends on your industry, product mix, and supply chain design. Automotive, aerospace, industrial materials, chemicals, consumer goods, agriculture, and energy-related value chains typically face the highest exposure. Companies that model different scenarios—accounting for changes in scope, duration, and application—can pinpoint their risks and opportunities, and build a strategy that spans supply chains, trade, customs, tax, and regulations.

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Our proprietary Tariff Impact Assessment (TIA) tool quantifies potential tariff costs and uncovers risks and opportunities, providing a clear picture of potential costs and mitigation strategies.

Key trade policy developments affecting Canadian businesses

US Supreme Court decision invalidating IEEPA tariffs

In February 2026, the US Supreme Court ruled that the International Emergency Economic Powers Act (IEEPA) doesn’t authorize the president to impose tariffs without clear congressional approval. As a result, tariffs imposed under IEEPA in 2025 and early 2026 were invalidated. This eliminated a major source of executive-driven tariff authority and triggered significant refund considerations for affected importers.

Why this matters

  • Many Canadian exporters and their US customers were affected by IEEPA-based tariffs
  • For companies, the focus has shifted from tariff mitigation to refund recovery, cash-flow timing, transfer pricing, and financial statement implications
  • This ruling increases the importance of understanding importer-of-record status and contractual risk allocation

IEEPA tariff refunds: CBP process

Following the Supreme Court’s decision, the US Court of International Trade ordered US Customs and Border Protection (CBP) to remove IEEPA tariffs from unliquidated entries and to reliquidate eligible liquidated entries without regard to IEEPA duties. CBP is processing refunds administratively through its Consolidated Administration and Processing of Entries (CAPE) system.

Why this matters

  • Refunds are issued to the importer of record, which may be a US affiliate or customer—not the Canadian exporter
  • Companies may need to support their customers by providing documentation, assessing pricing impacts, and revisiting commercial arrangements
  • Recovery timing, interest entitlement, transfer pricing implications, and accounting treatment each require attention

Temporary replacement tariffs under Section 122 of the Trade Act

In response to the invalidation of IEEPA tariffs, the US introduced a temporary import surcharge under Section 122 of the Trade Act of 1974. Key components of this measure include a temporary, across‑the‑board import surcharge of up to 10% and exemptions for goods qualifying under the Canada‑United States‑Mexico Agreement (CUSMA). Additionally, the measure ends the combination (or “stacking”) of additional tariffs on goods subject to Section 232 tariffs. These tariffs apply for up to 150 days (unless extended by Congress) and are subject to important exemptions.

Why this matters

  • Short‑term tariffs increase pricing uncertainty and planning complexity

  • CUSMA origin qualification determines eligibility for the tariff exemption

  • Companies are managing overlapping trade measures with different legal bases and timelines

Expansion and recalibration of Section 232 tariffs on steel, aluminum, and copper

Section 232 tariffs now apply to the full customs value of covered products rather than only the metal content. Coverage of derivative products has expanded, with tiered rates based on sourcing and composition.

Why this matters

  • Canadian manufacturers, automotive suppliers, industrial companies, defence contractors, and energy firms face increased tariff exposure

  • Classification, valuation, and origin determinations are more consequential

  • Supply chain and sourcing decisions may require reassessment

De minimis suspension and US border treatment

Despite the IEEPA ruling, the suspension of US de minimis treatment continues, increasing costs and compliance burdens for companies managing low-value shipments, e-commerce operations, and direct‑to‑consumer sales.

Why this matters

  • Higher landed costs for low‑value shipments

  • Increased customs processing and compliance requirements

  • E-commerce and fulfillment strategies reliant on de minimis treatment may require reassessment

2026 CUSMA review and evolving trade relationship dynamics

Canada, the United States, and Mexico are engaged in the formal review process of CUSMA. While the agreement remains in force, the review could change how key provisions are interpreted, enforced, and prioritized—particularly in areas such as rules of origin, labour and environmental commitments, dispute settlement, and trade remedies.

Why this matters 

  • Outcomes from the CUSMA review could affect Canadian companies’ market access, their eligibility for preferential tariffs, and compliance expectations

  • Increased scrutiny or changes in enforcement will require greater attention to origin qualification, documentation, and governance

  • The review adds another layer of uncertainty alongside tariffs and other trade measures, reinforcing the value of scenario‑based planning over relying on a single forecast

Build your trade and tariff strategy: How PwC Canada can help

PwC Canada’s Customs and International Trade specialists work closely with tax, supply chain, deals, and economics teams to help companies navigate today’s rapidly evolving trade environment—from exposure assessment and refund recovery to supply chain redesign and long-term strategic planning.

A comprehensive assessment helps illuminate the full impact of tariffs and other trade actions on your business. This lets you develop a holistic strategy that encompasses supply chains, trade and customs, regulations, and tax. A scenario analysis is a crucial step. It helps pinpoint your risks and opportunities, helping you build an effective strategy to address those areas.

Examine potential options, key suppliers and customers, contracts, and potential exclusions to address trade and customs challenges. 

Review dependencies and use the information for potential supplier negotiations, sourcing, manufacturing, and stockpiling decisions.

Evaluate transfer pricing policies and transactional characterizations while considering the overall income tax impacts and opportunities of supply chain decisions, including the mix of income, tax attributes, and incentives.

Explore our Customs and International Trade Services

Navigate global trade with confidence— turn customs rules into a competitive advantage

Managing indirect tax complexity across borders

US trade policy changes—tariffs, refund developments, and temporary measures are evolving quickly

Tariff and Trade Perspectives 

Gain insights to help your business navigate the tariff landscape.

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Episode 1: Steel and aluminum
Join Kara Selby and Philippe Pourreaux as they discuss the impact of tariffs on the aluminum and steel sectors, as well as the broader value chain. Learn how companies can mitigate the financial impact, enhance operational stability, and maintain their competitive edge. Watch the video for key insights.

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Episode 2: Customs & International Trade
Dive into the complexities of international trade with our latest episode of Tariff and Trade Perspectives. Join Kara Selby and Martha Goncalves as they discuss the impact of CUSMA and the recent tariff changes on Canadian businesses. Don't miss out on these valuable insights.

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Episode 3: Economics and Policy
Kara Selby and Mikaela McQuade dive into the economics and policy of tariffs. Discover why governments impose tariffs, their economic impacts, and how businesses can navigate these challenges. 

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Episode 4: Tax Policy 
Canadian businesses are adapting to US tariffs by accessing government relief measures. Kara Selby and Colin Mowatt discuss tax credits and incentives that support key investments. Learn how to combine federal and provincial supports to seize new growth opportunities.

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Episode 5: Industrial Manufacturing
In Episode 5 of Tariff and Trade Perspectives, Kara Selby is joined by Vipul Soni and Martha Goncalves to explore how US trade policies are reshaping Canada’s manufacturing sector—especially automotive

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Episode 6: Defence
In Episode 6, Kara Selby speaks with Laura Wood about how global defence spending and US trade shifts are opening new opportunities for Canadian companies—especially in supply chains, manufacturing, and digital defence infrastructure.

Canada’s tariff relief programs: Unlock government support

Canadian businesses can access new tariff relief measures and stack existing tax credits and incentives to enhance funding opportunities.

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Martha Goncalves

Martha Goncalves

Partner, Tax, Customs & International Trade, PwC Canada

Marc Levstein

Marc Levstein

Tax Business Units Leader, Global Structuring, PwC Canada

Tel: +1 647 388 5692

Mikaela McQuade

Mikaela McQuade

Economics and Policy Practice Leader, PwC Canada

Michael Dobner

Michael Dobner

Partner, Economics and Policy, PwC Canada

Tel: +1 416 520 5859

Kirsten Baker

Kirsten Baker

Energy Leader, PwC Canada

Tel: +1 403 714 2681

Chris Casey

Chris Casey

Industrial Manufacturing and Automotive Sector Lead, PwC Canada

Tel: +1 416 320 8175

Kara Ann Selby

Kara Ann Selby

National Growth Priorities Markets Leader, Partner International Tax, PwC Canada

Colin Mowatt

Colin Mowatt

Partner, Tax Policy Leader, PwC Canada

Tel: +1 416 723 0321

Sean Rowe

Sean Rowe

National Deals Markets and Value Creation Leader, PwC Canada

Jamie Siu

Jamie Siu

Partner, National Operations and Procurement, PwC Canada

Tel: 403-966-9534

Nissa Shariff

Nissa Shariff

Partner, Healthcare & Public Sector, Strategy&, PwC Canada

Tel: +1 647 702 5289

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