Last updated September 11, 2026. Canada’s new counter-tariffs on a defined list of U.S.-origin goods took effect at 12:01 a.m. on September 8, 2026. The product list is confirmed, Finance Canada has published a remission-request process, and the Canada Border Services Agency (CBSA) published Customs Notice 26-23 on September 7 with administration and accounting instructions. Importers should use both the official product list and the CBSA notice when confirming shipment-specific treatment.
For Canadian importers, the practical question is not simply whether a shipment comes from the United States. The questions are whether the goods are U.S.-origin under the applicable marking rules, whether the exact tariff item appears on the counter-tariff list, and whether an exception applies.
September 11 update: what changed after implementation?
As of this review, Finance Canada’s published list still sets the September 8 counter-tariff rates at 15, 25, or 50 per cent. We found no subsequent change to those rates in the official Canadian sources reviewed. Two separate developments deserve attention when planning cross-border trade:
U.S. measures affecting Canadian exports. The White House’s September 8 announcement sets September 15 for additions and removals from U.S. Section 338 tariff coverage, and September 29 for import bans on specified Canadian products. These are U.S. measures on Canadian goods, not changes to Canada’s counter-tariff rates on U.S. goods. Businesses shipping southbound should check the applicable proclamation annexes and CBP instructions before accepting orders or dispatching goods.
A separate Canadian canned-vegetable safeguard. In its September 9 statement, Finance Canada said the existing 10 per cent safeguard remains while it reviews the CITT report, for up to 200 days from its June 19 start or until replaced by final measures. CBSA Customs Notice 26-14 exempts U.S.-origin goods, among other origins, and excludes frozen vegetables. Do not automatically add this safeguard to a U.S.-origin shipment’s counter-tariff; check the separate product and origin rules when comparing alternative suppliers.
What Canada has confirmed
According to the Department of Finance product list, the new measures:
- took effect at 12:01 a.m. on September 8, 2026;
- apply surtax rates of 15, 25, or 50 per cent, depending on the listed tariff item;
- cover $27.6 billion in U.S.-origin products across areas including steel, dairy, appliances, agricultural equipment, pulp and paper, and electronics;
- apply only to goods considered U.S.-origin under Canada’s marking rules; and
- exclude U.S. goods that were already in transit to Canada when the measures took effect, provided the importer has the required proof.
The rate cannot be determined from a general product description or industry alone. Importers must match each product to the exact tariff item in the official list.
Does every shipment from the United States face a new tariff?
No. The country a shipment leaves from and the country where its goods originate are not always the same.
A product shipped by a U.S. supplier may have been manufactured elsewhere. A U.S.-origin product may also enter Canada through another country. The new counter-tariffs depend on origin and tariff classification, not only the vendor’s address or the route shown on a freight document.
Before assuming that a shipment is affected or exempt, confirm:
- The product’s complete commercial description, composition, function, and model or part number.
- The tariff classification currently used for the product.
- The product’s country of origin, supported by supplier records.
- Whether that exact tariff item appears on Finance Canada’s list.
- Whether the shipment qualifies for an exception or other treatment described in CBSA’s administration notice.
Five steps importers should take now
1. Build a list of open and upcoming U.S. purchase orders
Review open purchase orders and entries affected on or after September 8. Include the supplier, product description, tariff classification, origin, value, shipping date, arrival date, and Incoterms. This creates one working list for procurement, finance, logistics, and your customs broker.
2. Check tariff classifications against the official product list
Do not search the list only by product name. The legal trigger is the listed tariff item. Review classifications that were copied from supplier invoices, inherited from an older database, or assigned without complete product specifications.
3. Validate origin evidence
Ask suppliers for origin information early. Country of export, country of purchase, and country of origin can be different. Keep the supporting records with the product and shipment file so the entry can be reviewed consistently.
4. Identify shipments that may qualify for the in-transit exception
CBSA confirms that U.S. goods that were in transit to Canada when the surtax took effect are not subject to the measure. For this exception, the goods must have been bound for Canada, not yet arrived in Canada, and under the control of a carrier. The importer must possess proof, which may include a bill of lading, report of entry document, or cargo control document.
5. Model the cash and margin impact
For each potentially affected product, model the applicable surtax. Include regular customs duty, any SIMA or excise amounts, freight, insurance, brokerage, exchange-rate exposure, financing, and inventory carrying cost. Share the result with purchasing and sales before committing to new quantities or pricing.
The surtax is calculated on value for duty, and GST generally includes the surtax in its taxable base. See our worked landed-cost example for the distinction between product cost and the GST cash requirement.
Why the in-transit date needs special attention
A September 7 shipping label alone does not necessarily establish the exception. CBSA defines “in transit to Canada” as goods that were bound for, but had not yet arrived in, Canada and were under the control of a carrier when the surtax came into force.
Keep the supporting transportation records with the entry file. CBSA may request proof at any time, including shipping documents such as a bill of lading, report of entry documents, and cargo control documents.
Finance Canada has published a remission process
Finance Canada has published the process for requesting remission of tariffs on certain U.S. goods. It says remission may be considered where goods used as inputs cannot be sourced domestically or reasonably from non-U.S. sources, or in other exceptional circumstances that could have severe adverse effects on the Canadian economy.
Only companies registered in Canada are eligible to submit a request. Applicants must provide detailed operational, sourcing, classification, import-value, and economic-impact evidence. Submitting a request is not itself approval: for remission to take effect, an Order in Council must be approved by the Governor in Council.
How CBSA says the surtax is administered
CBSA published Customs Notice 26-23: United States Surtax Order (2026) on September 7. The notice confirms that:
- the surtax applies to commercial and casual goods of U.S. origin, including goods exported to Canada from another country;
- goods classified under Chapters 98 and 99 are exempt unless the applicable Chapter 98 or 99 tariff item is specifically listed in Schedule 4 of the Order;
- when goods are subject to both this Order and the Steel Derivative Goods Surtax Order, only the surtax under the United States Surtax Order (2026) applies;
- the surtax still applies to shipments that qualify for the Postal Imports Remission Order or Courier Imports Remission Order, including shipments within de minimis thresholds; and
- the Duties Relief and Duty Drawback Programs remain available, subject to the applicable CUSMA requirements.
Accounting codes in CARM
Importers must declare affected goods on the Commercial Accounting Declaration through the CARM Client Portal, EDI, or API. The applicable surtax codes are:
- 26186A for goods subject to the 15 per cent surtax;
- 26186B for goods subject to the 25 per cent surtax; and
- 26186C for goods subject to the 50 per cent surtax.
The surtax amount is entered in field 85 of the Commercial Accounting Declaration. Commercial goods that qualify for an exception must be declared as not subject to surtax at the time of accounting. Corrections and adjustments for commercial goods can be submitted through CARM or EDI/API, as applicable; casual-goods adjustments use Form B2G. CBSA may examine goods at importation or conduct post-release verification, and non-compliance can result in duties, penalties, and interest.
How Welke can help you prepare
Welke helps importers organize shipment data, review customs requirements, and coordinate brokerage and freight decisions across Canada and the United States. The earlier your broker sees the product, origin, value, and timing information, the more time your team has to resolve gaps before the goods reach the border.
For a focused review, send us:
- complete product descriptions and specifications;
- the tariff classifications currently being used;
- supplier and country-of-origin information;
- purchase orders, invoices, and shipment dates; and
- the expected value and volume of affected imports.
Learn more about Welke’s customs brokerage services, or request a quote to discuss your upcoming imports.
Frequently asked questions
When did Canada’s new counter-tariffs take effect?
The counter-tariffs took effect at 12:01 a.m. on September 8, 2026.
Are all goods imported from the United States affected?
No. The measure applies to the listed tariff items when the goods are U.S.-origin under the applicable marking rules. Both classification and origin must be checked.
Are goods already in transit exempt?
CBSA says U.S. goods that were already in transit when the measure took effect are not subject to the counter-tariff. The goods must have been bound for Canada, not yet arrived, and under a carrier’s control. Importers must keep supporting proof such as a bill of lading, report of entry document, or cargo control document.
What CARM surtax code should an importer use?
Use 26186A for the 15 per cent surtax, 26186B for the 25 per cent surtax, or 26186C for the 50 per cent surtax. The amount owing is entered in field 85 of the Commercial Accounting Declaration.
Can an importer rely on a supplier’s tariff code?
A supplier’s code can be a starting point, but the Canadian importer remains responsible for the Canadian customs entry. Confirm the classification using complete product information.
This article provides general information, not shipment-specific legal or customs advice. Confirm the treatment of your goods with a qualified customs professional and the current government notices.