If you import US goods that go into something you make in Canada, you have been paying the September 8 surtaxes since they came into force (Privy Council Office [PCO], 2026, s. 1). Four days earlier, the order that imposed them also amended the United States Surtax Remission Order (2025) to extend its manufacturing-and-processing remission to them (PCO, 2026, s. 5). The relief existed on the first day the surtax did, the code is 25-0466C, and no government page a reader is likely to open says so.

Section 3 — manufacture, processing, production, packaging — code 25-0466C; reaches the 2025-1, 2026 and Steel and Aluminum 2025 orders (Canada Border Services Agency [CBSA], 2026a, paras. 6, 41)

The widest reach: manufacturing or processing any good, producing an agricultural product, or packaging a food product or beverage.

Sections 1 and 2 — public health, health care, public safety, national security — codes 25-0466A and 25-0466B; all four surtax orders; imported before July 1, 2027 (CBSA, 2026a, paras. 4, 5, 15, 39, 40)

Eligibility turns on which entity uses the goods.

Sections 4, 4.1 and 4.21 — scheduled goods — codes 25-0466D, M, E, P01–P02, R01–R23; the 2026 Order for goods in Schedule 1, 2, 3 or 4.1 (CBSA, 2026a, paras. 8, 9, 11, 43–48)

The tariff classification number decides.

Claim window — two years after the date of importation, to the Minister of Public Safety and Emergency Preparedness (CBSA, 2026a, para. 15)

September entries are not lost; the payment due date bites first.

PC 2026-0785, dated September 4, 2026, comes into force September 8 by its section 10. Its sections 3 to 7 add the new order to six of the Remission Order’s relief provisions — 1, 2, 3, 4, 4.1 and 4.21 — while section 8 adds it to no relief list, replacing only the steel-and-aluminum import-before dates. The one reaching the most importers is section 3, covering goods imported for use in Canada in manufacturing, processing, agricultural production or food-and-beverage packaging. Sections 3.1, 4.2 and 4.3 were left alone (PCO, 2026, ss. 3–10; CBSA, 2026a, paras. 7, 10, 12).

A US$250,000 input shipment, at the October 2 Bank of Canada daily average of 1.4246 USDCAD, is C$356,150, and the surtax is C$53,422.50 in Schedule 1, C$89,037.50 in Schedule 2 and C$178,075 in Schedule 3 (Bank of Canada, 2026; PCO, 2026, s. 1). Value for duty is set under sections 47 to 55 of the Customs Act, not an invoice conversion — read those as scale.

Relief at import is claimed by entering the code in the Special Authority OIC field on the Commercial Accounting Declaration, with the surtax still declared alongside the remission. If the code was not on the declaration, as with most September and October entries, a correction up to the payment due date under reason code R5-00-COT relieves the surtax owing, and an adjustment after it under R2-74-1-GR-53 refunds surtax already paid (CBSA, 2026a, paras. 38, 41, 53–55).

How old a shipment can be is answered by the instrument rather than the notice. No paragraph of the Remission Order’s section 5 attaches an import-before date to a section 3 good unless it also sits in a Steel and Aluminum 2025 schedule: 5(a.01) scopes July 1, 2027 to Schedules 1 and 1.1, and 5(a.02) scopes February 1, 2026, already past, to Schedules 2 and 2.1 (Department of Justice Canada, 2026, s. 5). The notice never says so affirmatively: its paragraph 16 no-time-limit list names section 4.3 and Schedules 1, 2, 5 and 6, and section 3 is absent (CBSA, 2026a, para. 16).

All three were read on October 4, 2026. Customs Notice 25-19, updated September 11, carries the amendments at paragraphs 4, 5, 6, 8, 9 and 11 — while its paragraph 2, which states what the Order covers, still lists only the three 2025 orders (CBSA, 2026a, paras. 2, 4–6, 8–9, 11). Customs Notice 26-23, dated September 7, has one remission paragraph, and its only link goes to Finance’s remission-request process page, modified October 2, naming neither the Remission Order, nor the notice, nor any code (CBSA, 2026b, para. 39; Department of Finance Canada, 2026a). Finance’s tariff-relief page, modified September 23, grants relief under sections 1, 2, 3 and 3.1 without saying which orders they relieve (Department of Finance Canada, 2026b). None is wrong. A reader following the notice’s own pointer is asked to apply for relief they may already hold.

CBSA states the boundaries as guidance, and the hedging is its own. The provision is “generally intended” for NAICS chapters 31–33. Only processing machinery and direct inputs used in the activity qualify — a freezer chilling the good during processing qualifies; a forklift used only to load finished product “may not be eligible,” nor may hand soap or protective equipment. Repair is not included, and the onus is the importer’s (CBSA, 2026a, paras. 28–30, 37).

The strongest reading against this piece is that nothing in it is an error: the operative paragraphs are correct, the order is correct, and a broker working the notice paragraph by paragraph gets the right code. On that reading this is a hazard in how correct documents are arranged and linked, not a defect. What would falsify it is a CBSA or Finance statement that section 3 remission does not reach 2026-order surtax, which would require section 5 to mean other than it says. One limit: the consolidation is current to September 21, 2026, so a later amendment would not appear in it (Department of Justice Canada, 2026).

If you have September or October entries carrying the 2026 surtax on inputs you manufacture with, tell me which provision you land under and whether the payment due date has passed. If your broker reads paragraph 15 differently than I have, I would rather hear it than be right.

References

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

Canada Border Services Agency. (2026a). Customs Notice 25-19: United States Surtax Remission Order (2025) (updated September 11, 2026). https://www.cbsa-asfc.gc.ca/publications/cn-ad/cn25-19-eng.html

Canada Border Services Agency. (2026b). Customs Notice 26-23: United States Surtax Order (2026). https://www.cbsa-asfc.gc.ca/publications/cn-ad/cn26-23-eng.html

Department of Finance Canada. (2026a). Process for requesting remission of tariffs that apply on certain goods from the U.S. https://www.canada.ca/en/department-finance/programs/international-trade-finance-policy/process-requesting-remission-tariffs-that-apply-on-certain-goods-us.html

Department of Finance Canada. (2026b). Tariff relief for Canadian importers importing goods from the U.S. https://www.canada.ca/en/department-finance/programs/international-trade-finance-policy/canadas-tariff-responses/tariff-relief-canadian-importing-goods-us.html

Department of Justice Canada. (2026). United States Surtax Remission Order (2025) (SOR/2025-122, as amended by SOR/2026-186). Consolidated regulations, current to September 21, 2026. https://laws-lois.justice.gc.ca/eng/regulations/SOR-2025-122/FullText.html

Privy Council Office. (2026). United States Surtax Order (2026) (PC 2026-0785). https://orders-in-council.canada.ca/attachment.php?attach=48943&lang=en

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
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Canadian Trade Intelligence — Fully Briefed

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