Tax Insights: Canada introduces remission framework for the steel derivative goods surtax ─ What importers need to know

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Issue 2026-15

In brief

What happened?

On March 11, 2026, the Canada Border Services Agency (CBSA) released Customs Notice 26‑07¹ “Steel Derivative Goods Surtax Remission Order,” which provides administrative guidance on the process for claiming remission of surtaxes applied to certain steel derivative goods imported into Canada after December 25, 2025.

Targeted surtax relief became available when the Governor General in Council issued the Steel Derivative Goods Surtax Remission Order² (the Remission Order) on February 24, 2026, under section 115 of the Customs Tariff. This Remission Order represents the first broad, category-based relief framework for businesses to claim remission on the surtaxes paid or payable on those imported steel derivative goods.

Why is it relevant?

The steel derivative goods surtax has increased landed costs for many Canadian businesses. The Remission Order provides a defined pathway to reduce or recover those costs, subject to specific conditions and compliance requirements.

Actions to consider

Businesses should review recent and upcoming imports of steel derivative goods to determine if they are eligible for remission of surtaxes and determine the appropriate timing for claiming it. They should ensure that their customs brokers apply the correct authorization codes and verify supporting documentation.

In detail

Background

Starting December 26, 2025, Canada has been imposing a global 25% surtax on certain imported steel derivative goods under the Steel Derivative Goods Surtax Order³ that was issued on December 11, 2025. This was in response to persistent global overcapacity and non‑market policies and practices in the steel sector, which have been compounded by restrictive US trade measures.

Canada has also been applying surtaxes on imports of certain steel mill products when those imports exceed the tariff rate quotas set for that country, as well as other steel-related surtaxes. However, as Canada has a non‑stackable surtax policy, only one surtax measure can apply to a particular good at a time, following a prescribed order of precedence prescribed by the CBSA.

When the global 25% surtax was announced, the government indicated that remission requests would be considered in limited circumstances. Canada has now introduced targeted remission from this 25% steel derivative goods surtax.

Remission categories

The Remission Order provides relief in four categories:

• Public health, public safety and national security – goods imported for use by eligible entities, such as a government or clinical health research organization, an organization that produces or stores medical countermeasures (including pharmaceuticals or medical devices), an ambulance or firefighting service, a law enforcement agency, the Department of National Defence or the Canadian Forces; commercial importers that import goods for their own use (and not for use by the above noted entities) do not qualify
• Health care – goods imported for use:
  • to provide medically necessary health care services at a hospital, health care or dental clinic, a medical, dental or diagnostic laboratory or a long‑term care facility, or
  • for health care or public health purposes by a public health authority, or an entity that provides medically necessary health care products or services related to blood, cells, tissues or organs
• Scheduled goods – specified goods listed in the Schedule⁴ to the Remission Order, covering 43 tariff groupings; this relief is intended to address goods in short supply, non‑steel goods inadvertently captured by tariff classifications and goods not produced domestically
• Utility wind towers – utility wind towers and tower sections classified under tariff item 7308.20.00 that are:
  • imported to be installed on an offshore energy project, or
  • subject to a purchase order (that specifies the price and quantity) signed before December 26, 2025, for an energy project in Canada

How to claim remission

At the time goods are imported into Canada

For commercial goods, remission can be claimed at the time goods are imported into Canada by entering the appropriate special authorization (SA) code⁵ in the Special Authority OIC field on the Commercial Accounting Document (CAD) through the CBSA Assessment and Revenue Management (CARM) system. If remission has already been granted, the surtax must still be declared on the CAD, in addition to claiming the remission separately.

Post‑import corrections and adjustments

If the imported goods are eligible for remission, but the remission was not claimed on the CAD at importation, an importer can recover the surtax through CARM by submitting:

• a correction, which can be filed before the CAD payment due date to relieve surtaxes owing
• an adjustment, which can be filed after the payment due date to request a refund of surtaxes paid

Adjustments for non‑commercial goods cannot be made through CARM and must be submitted using a CBSA informal adjustment request form.

The importer must submit a claim for remission within two years after the date of importation.

Supporting documentation, compliance and enforcement

Importers must retain sufficient documentation to substantiate eligibility for remission, including commercial invoices, CADs, purchase orders, contracts and evidence of end use. The CBSA may also examine goods at importation and conduct post‑release verifications to confirm tariff classification, valuation, origin and compliance with the Remission Order.

When remission is incorrectly claimed or unsupported, the CBSA may reassess surtax, impose penalties and charge interest. Importers remain responsible for the accuracy of claims, even when brokers are used.

What businesses need to do

Businesses that import steel derivative goods into Canada should:

• review recent and upcoming imports of steel derivative goods to identify whether these goods could be eligible for surtax relief under the Remission Order
• confirm whether remission should be claimed at importation or through post‑import corrections or adjustments
• ensure that customs brokers are using the correct SA codes in CARM
• review contracts, purchase orders and end‑use documentation to support eligibility for remission
• prepare for potential CBSA post‑release verification

The takeaway

The Remission Order provides a structured pathway to targeted surtax relief. However, while the Remission Order does provide relief, remission is not automatic. Importers must understand the eligibility rules and actively assess eligibility, claim remission correctly and maintain robust documentation to support their claims. If they do not, they risk overpaying the surtax or face reassessments if claims are incorrectly made.