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STEEL REMISSION OPPORTUNITIES

AVAILABLE, BUT IF NOT AUTOMATIC, IT WILL BE A REAL WAITING GAME!

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We have written about Canada’s many different surtaxes on steel goods here and here , and Canada’s extension of some of these steel surtaxes (including horizontal tariff relief) here .

In this Steel Industry Report, we review Remission Opportunities currently available for Canada’s surtaxes on steel goods, as some of the rules have changed.

Automatic Surtax Relief – Remission Orders

Many of Canada’s surtax orders targeting steel goods have certain "horizontal tariff relief measures" in place. These are tariff-relief measures that apply across many industries, products, or importers, and in the case of imported steel, that is in the form of specific Remission Orders. For example, for steel goods subject to a 25% surtax under the China Surtax Order (2024) , there may be potential automatic surtax relief under the China Surtax Remission Order (2024) . Each Remission Order tends to have specific ‘categories’ of relief and certain conditions for that relief, and where met, provides automatic surtax relief via special codes for CAD entries.

General Remission Relief

Where a steel good is NOT eligible for automatic surtax relief under the various Canadian Remission Orders currently in place, importers have the additional option of submitting a General Remission Application under Canada's general remission framework. Notably, the eligibility criteria for General Remission differs based on the surtax being targeted for relief.

Importers also need to be aware that requesting surtax relief through a General Remission application will be a lengthy process – taking upwards of one year in certain instances! Accordingly, if automatic surtax relief is not available under a given Remission Order, possible relief essentially becomes a waiting game – and unfortunately with NO GUARANTEES that any remission relief will be granted! :-(

Complex Processes

While a claim for automatic surtax relief or the submission of a remission application may appear straightforward at first glance, the reality is that both processes are complex and difficult to navigate.

Determining whether steel goods are eligible for surtax relief under a particular ‘category’ of relief and whether the relevant conditions for relief are met under a specific Remission Order generally requires legal advice, and confirmation of things like proper tariff classification, amongst other matters. Getting these questions totally correct is critical as the Canada Border Services Agency (“CBSA”) is currently conducting trade verifications (audits) seeking to ensure that importers are paying the proper surtaxes due and qualifying for only allowable remission relief – and this is now a CBSA compliance priority . Mistakes can give rise later to 4 years of liability for duties, interest, and penalties.

Preparation of a proper General Remission Application is also a technically challenging task that can benefit from specialized advice and well-crafted legal arguments. In life, you usually get what you pay for, and DIY or AI approaches often lack the experience necessary to capitalize on these programs. In short, Experienced International Trade Counsel can assist and maximize the chances of success.

For help with steel goods remission opportunities, please click here.