Effective 12:01 a.m., July 30, 2025, certain steel products containing steel melted and poured in China, and certain aluminum products containing aluminum smelt and cast in China will be subject to a surtax of 25% on the value of the imported goods.
Origination
A steel product is considered melted and poured in China if the 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. This can take the form of a semi-finished or finished steel mill product.
Similarly, an aluminum product is considered smelt and cast in China if the largest volume or, if any, second largest volume of primary aluminum contained in the goods was produced in China. Alternatively, a product is considered smelt and cast if the aluminum contained in the goods was most recently liquified and cast into a solid state in China. This can take the form of a semi-finished or finished aluminum product.
Documentation
If you are an importer of steel, aluminum and/or steel or aluminum derivatives, it is critical that you maintain accurate and up-to-date documentation regarding the origination of your imported products. The Canada Border Services Agency (CBSA) may determine your goods to be originating in China and require you to pay the aforementioned surtax if you are unable to provide documentation showing the goods do not originate in China, or if you provide documentation that is incomplete.
To verify origination outside of China, importers must provide either a commercial invoice, report or certificate with the required information. This can be a mill test certificate, mill test report or material test certificate; a certificate of conformance, compliance, inspection or analysis; a certified inspection report; a metallurgical test report; or a chemical analysis certificate.
Exceptions
There are three exceptions to the surtax being imposed.
- Steel and aluminum products already in transit at the time the surtax comes into effect.
- Steel and aluminum products considered originating in the United States.
- Steel and aluminum products that have a cumulative value of less than $5,000 for one commercial accounting declaration (CAD)
Why has the government put the surtaxes in place?
The surtaxes are being imposed to protect Canadian industry against unfair competition from underpriced steel and aluminum originating in China, a glut of which is now on international markets as a result of tariffs imposed by the United States against goods originating in China and additional steel and aluminum tariffs.
Bond Requirements
If you currently have a customs surety bond, it is critical that you ensure the value of that bond is still sufficient when considering these new tariffs. If you have not yet secured a bond, it is critical that you factor in the additional cost of these tariffs when calculating your bond requirements.
Click here to learn more about how tariffs will impact bond surety obligations, and click here to learn more about bond requirements under the Canada Border Services Agency’s Assessment and Revenue Management Initiative (CARM).
How Livingston is responding
We understand there is currently a significant degree of uncertainty regarding trade activity, and that you’re likely to have many questions. We would like to reassure you that Livingston International is mobilizing quickly to adjust our processes to adapt to these new measures to ensure your duties to the Canada Border Services Agency (CBSA) are calculated correctly and in accordance with these new policies. These additional duties and any associated charges will be visible on your subsequent invoice from Livingston so that you can better understand the financial impact to your business.
We would also like to advise you that the implementation of tariffs in recent months has resulted in a higher level of scrutiny by CBSA officials, which has often led to delays at the border. We encourage you to make your carrier partners aware of these delays and ask that they check wait times at specific border crossings prior to departing to the border.
Need More Information?
For additional information, please refer to Customs Notice 25-28: Steel Goods and Aluminum Goods Surtax Order.
Should you have any questions regarding the impact of these tariffs to your customs process, billing or responsibilities as an importer or exporter, please contact Livingston.