Canadian customs inspection lane, cargo truck and containers illustrating new counter-tariffs taking effect

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.
Lead development · Canada

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.

15% / 25% / 50%Rates under the new 2026 surtax schedules
C$27.6 billionApproximate value of covered trade
September 8Effective date for the new measures

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.

MeasureRateCARM CAD assessment code
2026 surtax order — Schedule 115%26186A
2026 surtax order — Schedule 225%26186B
2026 surtax order — Schedule 350%26186C
Steel/aluminum order — aluminum25% / 50%26187A / 26187B
Steel/aluminum order — steel25% / 50%26187C / 26187D
Important stacking rule: when a good is subject to both the new 2026 surtax order and Canada’s Steel Derivative Goods Surtax Order, only the 2026 surtax applies. Separately, the amended steel and aluminum order now assigns selected scheduled products either a 25% or 50% surtax.

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.

Sanctions · Aviation

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.

Practical impact: airlines, lessors, repair providers, fuel suppliers, freight forwarders and banks should rescreen counterparties—including 50%-owned entities—and document whether a transaction fits a specific wind-down authorization. The suspension is broader than a list update because it removes standing licensing pathways.

Official materials: Treasury release, OFAC action page, suspension notice, and General License DD.

Trade remedies · Revocation

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.

Commerce revocation notice, 91 FR 57132

Antidumping · Preliminary

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.

Preliminary results, 91 FR 57134

USITC · Section 337

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.

USITC termination notice, 91 FR 57161

Global policy · Not yet operative

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.

Status matters: the September 8 statement is a policy commitment, not an operative customs ban. It provides no product scope, tariff classification, origin method, commencement date or border-filing instruction. Traders should flag exposure and monitor each jurisdiction’s national process, but should not invent a shipment block from the statement alone.

Joint statement published by Global Affairs Canada

Today’s compliance action list

  1. 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.
  2. Configure CARM coding and field 85 amounts, validate U.S.-origin evidence, and separate pre-effective-date transit shipments with transport records.
  3. Rescreen aviation counterparties and ownership chains against OFAC’s September 8 additions; close or escalate activity before the September 23 wind-down cutoff.
  4. Identify mower entries made on or after July 13 and monitor CBP instructions before changing liquidation or refund assumptions.
  5. Keep the 22.07% Brazil brass-rod figure outside active cash-deposit tables until Commerce publishes final results.
  6. 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

Canada implementationCorrections to the product schedules, remission rules or CBSA assessment-code guidance.
September 23Expiry of OFAC’s limited aviation wind-down authorizations at 12:01 a.m. EDT.
Mower liquidationCBP instructions implementing the July 13 retroactive revocation and any resulting refunds.
Brazil final resultsCommerce’s final margin and the date any revised cash-deposit rate actually becomes effective.
Settlement-goods measuresNational product scope, origin rules, effective dates and customs implementation from the 12 signatories.

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

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.