Tax & Trade Blog

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CANADIAN EXPORT CONTROLS

MORE ENFORCEMENT COMING ON CANADIAN EXPORT SANCTIONS?

Canada, like many of its trading partners has a significant framework of export sanctions, targeting the controlled export of goods and technology to sensitive destinations, governments, and foreign actors worldwide.  Yet, for the duration of my International Law practice to date — some 35+ years — the unspoken joke has been that Canada’s enforcement actions were almost nonexistent, at least relative to the situation in the US.  (Indeed, one needs to look far and wide for caselaw regarding Canadian export controls enforcement).

With the recent trade wars and President Trump‘s desire to strengthen borders, this appears to have changed.  We review a recent Canadian arrest for sanctions evasion below, which may be a harbinger of greater action to come despite the rarity of such cases.

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CUSTOMS NON-COMPLIANCE NEVER PAYS!

HIGH DUTIES AND TARIFFS MAKE NON-COMPLIANCE A TEMPTING TRAP

Given the high tariff rates importers are facing due to Canada’s retaliatory tariffs (actually surtaxes), importers may be tempted to consider various methods to try and minimize the duty paid.  Unfortunately, most of these methods could be considered “evasion” – and there is no shortage of unscrupulous people hawking them.  On balance, these strategies are a poor choice given the potentially serious consequences for violating customs laws. 

As an example, the European Public Prosecutor’s Office (the “EPPO”) recently dealt with a customs evasion scheme in Italy involving Chinese electric bicycles (“e-bikes”).

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TARIFF REMISSION CLAIMS

A RECOMMENDED OPTION FOR BUSINESSES SEEKING TARIFF RELIEF

With the Canada-United States trade dispute enduring, Canada’s retaliatory tariffs are unlikely to be lifted soon.  Many businesses that considered their strategic options have now concluded Remission Claims are the only viable option to deal with Canada’s retaliatory tariffs.  In this Report, we review the Remissions Process, and why retaining Experienced Trade Counsel is a good idea at this early stage.

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CANADA OPENS 2025 DAIRY QUOTA APPLICATIONS

APPLICATION PERIOD RUNS UNTIL JUNE 15, 2025

Global Affairs Canada (“GAC”) recently announced the opening of the tariff-rate quota (“TRQ”) application period for the 2025-2026 dairy year, which is open from May 1 to June 15, 2025.  There are no changes to the existing ministerial allocation policies from the previous year, though this will be the second year Canada applies its new CPTPP dairy TRQ policies we have previously written about here.

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CBSA INVESTIGATING STEEL STRAPPING

DUMPING OF STEEL STRAPPING FROM CHINA, KOREA, TÜRKIYE & VIETNAM

On May 12, 2025, the Canada Border Services Agency (“CBSA”) issued a Notice of Initiation of Investigation under the Special Import Measures Act (“SIMA”) in respect of the alleged dumping of certain steel strapping originating in or exported from China, Korea, Türkiye and Vietnam.  This investigation was prompted by a complaint filed by JEM Strapping Systems Inc., a manufacturer located in Ontario.

This investigation continues a broader trend of increased scrutiny on foreign steel products.  Just last month, the CBSA and the Canadian International Trade Tribunal (the “CITT”) launched investigations into potential dumping of steel wire, which we wrote about here.