Issue 025  ·  Sunday, September 27, 2026

Forged grinding media: threat of injury, not injury — duty refundable

The September 22 finding splits your file in two. Goods released May 25 through September 22 carry refundable duty. Goods released from September 23 carry a permanent one.

If you have imported forged grinding media from China since May 25, every entry has carried provisional SIMA duty of between 43.6 and 125.3 per cent of export price, and until Tuesday nobody could tell you whether that money was yours or the Crown’s. On September 22 the Canadian International Trade Tribunal found that the dumping and subsidizing “have not caused injury to the domestic industry, but are threatening to cause injury to the domestic industry” (Canadian International Trade Tribunal [CITT], 2026a). A threat finding is not a diluted injury finding. It is the one result that sends the whole provisional period back to you — and makes every entry from September 23 a permanent cost.

What the two documents say, and which half each one covers

The Tribunal’s release covers the forward half only: duties “will be collected by the Canada Border Services Agency going forward” (CITT, 2026a). It does not mention the four months already paid. CBSA’s Memorandum D14-1-7 does. Where the Tribunal finds threat of injury, “provisional duty paid will be refunded, the balance of the security posted will be adjusted or the security posted will be returned to the Surety, as appropriate” (Canada Border Services Agency [CBSA], 2025, para. 14). Definitive duty applies “on goods released from customs after the date of the finding” (CBSA, 2025, para. 15).

So the file splits at the finding date: goods released May 25 through September 22 are the refundable half; goods released from September 23 carry definitive duty on the terms CBSA posted September 25 (CBSA, 2026a). Reasons follow October 7 (CITT, 2026b).

The number

Six provisional rates were set on May 25, on goods “released from the CBSA on or after May 25, 2026” (CBSA, 2026c):

• Jiangyin Xingcheng Magotteaux Steel Balls — 43.6%
• Changshu Feifan Metalwork — 53.5%
• Changshu Longte Grinding Ball — 57.0%
• Tangshan ZWell Equipment Manufacturing — 76.2%
• Oriental Casting and Forging — 82.9%
• All other exporters — 125.3%

US$500,000 of export price over the period, at the September 25 Bank of Canada daily average of 1.4145 USDCAD, is C$707,250 (Bank of Canada, 2026). At 125.3 per cent the provisional duty on it is C$886,184. At 43.6 per cent it is C$308,361. Export price is a SIMA-defined value your broker computes, not your invoice; read those as scale, not your figure.

What it does to your books this week

If you close on calendar quarters, Q3 closes Wednesday, eight days after the finding. Provisional duty that went into landed cost — expensed through cost of sales or sitting in inventory — is now a recoverable amount rather than a cost. If you priced it into customer quotes since May, you have recovered from customers a duty you are now getting back yourself. If you posted security instead, the bond release is working capital you have carried since spring. How you present it is your accountant’s call; the point is the decision exists this week and did not last week.

The forward half is the bigger number over time, and its terms are not the May rates. Four exporters — Longte, Xingcheng Magotteaux, Oriental, ZWell — hold normal values, so their anti-dumping duty is the gap between normal value and export price, not a published percentage; the page says to get the values from the exporter (CBSA, 2026a). Everyone else, including Changshu Feifan, which appears on neither table, pays 94.7 per cent of export price in anti-dumping duty plus 193.45 CNY per tonne in countervailing duty (CBSA, 2026a). Longte and Oriental carry specific per-tonne countervailing amounts (119.86 and 127.65 CNY); Xingcheng Magotteaux and ZWell had the subsidy investigation terminated as insignificant (CBSA, 2026a). The margins in the August 24 final determination are not the duty going forward; the notice says so itself (CBSA, 2026b). If Q4 pricing carried the May rate or no duty at all, both ended Tuesday.

Three things to do

1. Pull every entry of 7326.11.00.00 released between May 25 and September 22 and total the provisional SIMA duty on them. Note which of the six rates each carried; named versus unnamed is an 81.7-point gap.

2. Send your broker that total and ask which refund route applies — duty paid and security posted are handled differently. Paragraph 14 names three routes, qualified with “as appropriate.”

3. Re-price Q4 from the measures-in-force page, not the May notice. Four suppliers have normal values: ask them for the numbers, because the duty is price-based. Everyone else: 94.7 per cent on export price plus a per-tonne countervailing amount that moves with weight, not price — two separate lines in the model.

Where this could be wrong

D14-1-7 is CBSA’s statement of administrative practice, not the operative instrument, and it qualifies the three routes with “as appropriate.” The Tribunal’s reasons, due October 7, set the finding’s scope and could narrow which goods were ever subject; if yours fell outside the subject class, there was no provisional duty on them to return. What would falsify this piece: a CBSA notice implementing NQ-2026-002 that retains the provisional duty. The measures-in-force page, as of September 25, is silent on it. And the measures-in-force page names the Tribunal reference as PI-2025-008, the preliminary inquiry, not NQ-2026-002 — a cross-reference that has not caught up.

References

Bank of Canada. (2026). Daily exchange rates. https://www.bankofcanada.ca/rates/exchange/daily-exchange-rates/

Canada Border Services Agency. (2025). Memorandum D14-1-7: Assessment and payment of duties required under the Special Import Measures Act (SIMA). https://www.cbsa-asfc.gc.ca/publications/dm-md/d14/d14-1-7-eng.html

Canada Border Services Agency. (2026a). Forged grinding media: Measures in force. https://www.cbsa-asfc.gc.ca/sima-lmsi/mif-mev/fgm-eng.html

Canada Border Services Agency. (2026b). Notice of final decisions: Forged grinding media (FGM 2026 IN). https://www.cbsa-asfc.gc.ca/sima-lmsi/i-e/fgm2026/fgm2026-nf-eng.html

Canada Border Services Agency. (2026c). Notice of preliminary determinations: Forged grinding media (FGM 2026 IN). https://www.cbsa-asfc.gc.ca/sima-lmsi/i-e/fgm2026/fgm2026-np-eng.html

Canadian International Trade Tribunal. (2026a, September 22). Tribunal finds threat of injury—Forged grinding media from China. https://www.canada.ca/en/international-trade-tribunal/news/2026/09/tribunal-finds-threat-of-injuryforged-grinding-media-from-china.html

Canadian International Trade Tribunal. (2026b). Active dumping and subsidizing cases. https://www.citt-tcce.gc.ca/en/anti-dumping-injury-inquiries/active-dumping-and-subsidizing-cases

A note on framing: Fully Briefed synthesizes publicly available government source material and translates it into financial terms. That synthesis is machine-assisted: automated research pulls from primary government sources and produces a first draft each week. I check every figure, date and citation against the source, edit the result, and decide what ships. Errors are mine. This is education, not legal, customs, or tax advice. Nothing here determines how a specific product, shipment or filing should be treated — the published instruments govern, and your customs broker works the inputs.

Trevor Ryhorchuk, CPA, CIA, PMP

Canadian Trade Intelligence — Fully Briefed
tradeintel.fullybriefed.ca