Daily Trade & Customs Brief
Canada Counter-Tariffs Take Effect
CBSA released the filing rules behind Canada’s 15%, 25% and 50% U.S.-origin surtaxes. Separate U.S. actions today tighten Iran aviation sanctions, revoke lawn-mower trade orders and advance two case-specific trade remedies.
What changed today
- Canada’s counter-tariffs now apply to listed U.S.-origin goods, with operational CARM codes and origin, transit, relief and tax-base instructions.
- OFAC listed 36 Iran-related aviation targets and suspended several standing aviation authorizations, with narrow wind-down relief through September 23.
- Commerce revoked the China and Vietnam walk-behind mower orders retroactive to July 13, while a Brazil brass-rod rate remains preliminary only.
- A semiconductor Section 337 investigation ended by settlement, without an exclusion order.
- Twelve governments signaled future restrictions on settlement goods, but no product list, customs instruction or effective date was issued today.
New CBSA guidance turns the counter-tariff announcement into entry instructions
Effective September 8, Canada imposes surtaxes on scheduled U.S.-origin goods at 15%, 25% or 50%. The covered trade is approximately C$27.6 billion and spans selected steel and aluminum goods, dairy, appliances, agricultural equipment, pulp and paper, plastics and electronics. The original policy was announced in August; today’s operative change is the entry into force of the orders and CBSA’s detailed customs guidance.
The test is origin—not the country of shipment. The goods must be eligible to be marked as U.S. goods under CUSMA marking rules, and the surtax can apply even when they are exported to Canada from a third country. CBSA says commercial and casual goods are covered. Goods marked as originating in Puerto Rico, Guam, the Northern Mariana Islands, American Samoa or the U.S. Virgin Islands are outside this definition.
The surtax is calculated on value for duty and is additional to customs duties and trade-remedy duties. GST is calculated on the value for tax plus applicable customs duties and surtax. Chapter 98 and 99 goods are generally excluded unless their tariff item appears in Schedule 4. Postal, courier de minimis and remission thresholds do not by themselves remove the surtax.
| Measure | Rate | CARM CAD assessment code |
|---|---|---|
| 2026 surtax order — Schedule 1 | 15% | 26186A |
| 2026 surtax order — Schedule 2 | 25% | 26186B |
| 2026 surtax order — Schedule 3 | 50% | 26186C |
| Steel/aluminum order — aluminum | 25% / 50% | 26187A / 26187B |
| Steel/aluminum order — steel | 25% / 50% | 26187C / 26187D |
Goods already under carrier control and bound for Canada before the effective date may qualify for the in-transit exception, but the importer must keep supporting transport records. For steel and aluminum goods already in transit on or before September 8, the new increase does not apply, although the prior 25% surtax remains. CBSA assigns code 25095A to that transit treatment. Duties Relief and Duty Drawback may be available subject to the published conditions, and origin proof can be an invoice or other document containing the minimum CUSMA data elements.
See the CBSA 2026 surtax notice, the updated steel and aluminum notice, and Finance Canada’s authoritative product list.
OFAC blocks a wider Iran aviation network and suspends standing authorizations
On September 8, Treasury announced action against 36 targets, including 27 Iranian airlines and third-country procurement and logistics actors. Property and interests in property of blocked persons in U.S. jurisdiction are blocked, and the restriction also reaches entities owned 50% or more, directly or indirectly, by one or more blocked persons.
OFAC also indefinitely suspended authorizations covering certain overflight payments, aircraft safety transactions, bunkering or emergency repairs, and transactions involving non-U.S. airlines operating U.S.-origin aircraft under General License J-1. General License DD allows only the wind-down of transactions formerly authorized under sections 560.522 and 560.529 and GL J-1 through 12:01 a.m. EDT on September 23, 2026. Aircraft-safety requests formerly covered by section 560.528 will instead be considered case by case. A separate GL 37 gives the same September 23 deadline for limited wind-down dealings with three newly blocked logistics companies.
Official materials: Treasury release, OFAC action page, suspension notice, and General License DD.
Walk-behind mower orders on China and Vietnam are revoked retroactively
Commerce revoked the antidumping duty orders on certain walk-behind lawn mowers and parts from China and Vietnam and the countervailing duty order on the same merchandise from China. The notice is published September 8 but the revocation is effective July 13, 2026, because no domestic interested party filed a substantive response in the sunset reviews.
Commerce will instruct CBP to terminate suspension of liquidation for subject entries made on or after July 13. Earlier entries remain suspended and continue under the deposit and administrative-review framework. Importers should therefore split entry populations by date instead of treating the publication date as the cutoff. The written scope controls; the notice identifies HTSUS 8433.11.0050 as the typical classification, with possible entries under 8407.90.1010 or 8433.90.1090.
Brazil brass-rod review preliminarily assigns Termomecanica 22.07%
Commerce preliminarily calculated a 22.07% dumping margin for Termomecanica São Paulo S.A. for the December 1, 2023–May 31, 2025 review period. This is not yet a new cash-deposit rate: a revised rate would follow only after final results. The current all-others rate for companies not otherwise covered remains 22.78%.
Final results are generally due within 120 days unless extended. Case briefs are due within 21 days of publication and hearing requests within 30 days. Importers should not overwrite broker or landed-cost systems with the preliminary number.
Semiconductor investigation ends by settlement—no exclusion order issued
The USITC declined to review an administrative law judge’s order terminating Investigation 337-TA-1443 in full based on settlement. The case concerned certain foreign-fabricated semiconductor devices, products containing them and related components; all remaining respondents were direct or indirect TSMC customers.
The practical result is closure of this investigation, not an import ban. The Commission issued no exclusion order or cease-and-desist order.
Twelve governments signal restrictions on trade in settlement goods
Canada, Denmark, Finland, France, Iceland, Ireland, Norway, Poland, Portugal, Spain, Sweden and the United Kingdom jointly said they intend to introduce national restrictions, support European restrictions, or are actively considering measures on trade in goods with Israeli settlements. The statement says the United Kingdom, France and Canada will bring forward national measures.
Today’s compliance action list
- Map Canadian imports against the exact tariff items in the three 2026 schedules and the amended steel/aluminum schedules; do not classify by product description alone.
- Configure CARM coding and field 85 amounts, validate U.S.-origin evidence, and separate pre-effective-date transit shipments with transport records.
- Rescreen aviation counterparties and ownership chains against OFAC’s September 8 additions; close or escalate activity before the September 23 wind-down cutoff.
- Identify mower entries made on or after July 13 and monitor CBP instructions before changing liquidation or refund assumptions.
- Keep the 22.07% Brazil brass-rod figure outside active cash-deposit tables until Commerce publishes final results.
- Flag supply chains involving settlement goods for monitoring, but wait for national legislation and customs instructions before treating the joint statement as a shipment prohibition.
What to watch next
Frequently asked questions
Do the new Canadian surtaxes apply to every U.S. product?
No. They apply only to tariff items listed in the governing schedules. Classification, origin and the published exceptions must all be checked.
Can routing a U.S.-origin product through another country avoid the Canadian surtax?
No. CBSA applies the marking-origin test and says covered U.S.-origin goods remain subject even when exported to Canada from a third country.
Are the Canadian surtaxes included in the GST calculation?
Yes. CBSA says GST is calculated on the value for tax plus customs duties and the applicable surtax.
Does OFAC’s September 23 date restore the suspended aviation authorizations?
No. It is the end of limited wind-down relief. The underlying authorizations are suspended indefinitely unless OFAC later changes that status.
Should importers immediately use the 22.07% Brazil brass-rod rate?
No. It is preliminary. A new cash-deposit rate would apply only after final results are published.
Primary sources
- CBSA Customs Notice 26-23 and Order in Council P.C. 2026-0785
- CBSA updated Customs Notice 25-11 and Order in Council P.C. 2026-0786
- OFAC September 8 action package
- Commerce mower-order revocation
- Commerce Brazil brass-rod preliminary results
- USITC Investigation 337-TA-1443 termination
- Joint foreign ministers’ statement on settlement-goods restrictions
Compliance note: This publication is a concise operational summary, not legal or customs advice. Official schedules, written scopes, licensing terms and agency instructions control. Confirm product classification, origin, entry date, ownership and transaction facts before acting.
