Please note that this situation is continually evolving and the information on this page may become out of date.

In November 2024, incoming United States President Trump announced concerning tariffs to be implemented against Canada. Since then, the Canadian Institute of Steel Construction has closely monitored these threats and continually provided members with updates on the situation.

To support the Canadian steel sector, the CISC is advocating for:

  • The introduction of domestic procurement requirements for publicly funded construction projects that leverage federal funding;
  • Government investments into new public construction and infrastructure projects to support businesses, provinces, and municipalities that commit to using Canadian steel products on new infrastructure projects; and
  • For the federal and provincial governments to work with industry to diversify Canada’s export markets.

U.S. Tariffs Frequently Asked Questions 

The Canadian Government defines country of melt and pour (COM) as the original location where raw steel is first produced in a steel-making furnace in a liquid state and then poured into its first solid shape. The COM may be different from the country of origin. More information on COM is available here.

Proclamation 10896, in Clause (4) on page 9, a derivative article listed in the Annex that is made from U.S. origin steel (melted and poured in the U.S.) is exempt from the steel derivative tariffs.  Please Note: for this response, “U.S. origin steel” refers to steel that is 100% melted and poured in the U.S.

The pertinent text of Clause (4) is as follows:

These rates of duty, which are in addition to any other duties, taxes, fees, exactions, and charges applicable to such imported derivative steel articles, shall apply to imports of derivative steel articles described in Annex I to this proclamation from all countries, but shall not apply to derivative steel articles processed in another country from steel articles that were melted and poured in the United States.

  • Assumption: This assumes that ALL of the steel in the derivative good is U.S. origin steel.
  • However, for a steel derivative good that has a mix of U.S. origin and non-U.S. origin steel, at this time we do not know how the tariffs will apply.  The EO does not provide information on such a scenario.  Presumably, there will be a follow-up notice explaining how this type of situation will be handled.
  • The EO does provide that for derivative goods outside of Chapter 73, the duty will be calculated only on the steel content of the article.  Presumably, this means the Non-U.S. origin steel content as the text does not specify this.

Additional Guidance needed from the Trump Administration is the following:

  • How to calculate the tariff covering derivative goods (in Chapter 73 and other Chapters) containing both U.S. origin and non-U.S. Origin steel.
  • Regarding goods outside of Chapter 73,  in calculating the duty, what value of the steel content will be used? i.e., the cost of the steel input paid by the producer of the derivative good or the price of the steel good the steel producer charges to buyers, such as distributers, intermediate companies in the supply chain, etc.?

CBP released guidance (under the Additional Section 232 Questions section) on how to determine the value of aluminum or steel content for derivative products outside of Ch. 76 and 73. (See excerpt below.) In a nutshell, the content is determined through standard customs valuation principles. In most cases that would be invoice price paid by your supplier for the steel/aluminum content.

  • The value of the steel/aluminum content should be determined in accordance with the principles of the Customs Valuation Agreement, as implemented in 19 U.S.C. 1401a.  Thus, the value of the steel/aluminum content is the total price paid or payable for that content, which is the total payment (direct or indirect, and exclusive of any costs, charges, or expenses incurred for transportation, insurance, and related services incident to the international shipment of the merchandise from the country of exportation to the country of importation) made/to be made for the steel/aluminum content by the buyer to, or for the benefit of, the seller of the steel/aluminum content.  Normally, this would be based on the invoice paid by the buyer of the steel/aluminum content to, or for the benefit of the seller of the steel/aluminum content. 

All tariffs are cumulative in that they are added together.  This includes the MFN (normal duty), Section 301, Section 232, IEEPA, Section 201, AD/CVD, and any other tariffs that may be applied. 

This means that for a Canadian-origin steel derivative good made with non-U.S. origin steel, if the 25% IEEPA tariff is actually imposed on March 4, it will be on top of the Section 232 tariffs meaning the total tariff could potentially be 50% if IEEPA and 232 both apply.  The rate could be even higher if there is an applicable AD/CVD order. 

CAVEAT:  Please note that the Trump Administration needs to provide several clarifications and notices to implement the steel derivative duties and that there may be some changes in the covered products as well.   For example, the following clarifications are some things the Administration will issue follow-up notices on: 

  • The date the derivative tariffs actually take effect. (Clause 8 of the Steel derivatives EO and Clause 9 of the Al derivatives EO, both provide that the tariffs take effect upon public notification by the Secretary of Commerce, that systems are in place to process and collect the tariffs for covered derivative articles). 
  • Instructions on how the reporting and calculation of the duties will be handled by CBP and in ACE.  At this time, we do not how the imposition of the additional 232 tariffs will be implemented operationally. 
  • How will the tariffs be calculated for derivatives that contain both U.S. origin steel and non-U.S. origin steel. 
  • Whether any additional HTSUS subheadings will be added to the list of covered goods and/or removed from the list of covered goods. 
  • Will there be an update on how tariffs will be calculated for derivatives in Chapters 73 and 76 that are composite goods, meaning containing both steel/aluminum content and substantial non-steel/aluminum content. 

Categories of products impacted include HTS codes 7308 (structures and parts of structures), 7318 (screws and bolts), 7325 (cast articles of iron or steel), and 9406 (prefabricated buildings). For the full list of impacted products, please reference the Annex in the notice and utilize the U.S. HTS database.  

Please refer to this document prepared by our legal team for sample language.
Please note: this is not legal advice and members are encouraged to seek independent legal counsel.

In regard to the Section 232 steel and aluminum tariffs, the Canadian Government is following a dollar-for-dollar approach.

  • Canada is imposing, as of 12:01 am, March 13, 2025, 25 per cent reciprocal tariffs on a list of steel products worth $12.6 billion and aluminum products worth $3 billion, as well as additional imported U.S. goods worth $14.2 billion, for a total of $29.8 billion. The list of additional products affected by counter tariffs includes tools, computers and servers, display monitors, sport equipment, and cast-iron products.

The full list of products that will be tariffed is available here.

The Government of Canada has outlined a framework and process for how it will consider remission requests for the tariffs on products from the United States (U.S.). Under specific circumstances, remission allows for relief from the payment of tariffs, or the refund of tariffs already paid. Inquiries or remission requests must be sent to remissions-remises@fin.gc.ca with the subject line “U.S. Remission.” More details are available here.

On March 6, the President announced that tariffs will only apply on goods that do not satisfy U.S.-Mexico-Canada Agreement (USMCA) rules of origin that claim and qualify for USMCA preference. The Section 232 steel and aluminum tariffs are separate. Anything entered between March 4 and March 7 before 12:01 a.m. EST is subject to the tariffs. More information is available at the below links:

Have more questions?
Please email Rita Rahmati, Director of Communications and Public Affairs at rrahmati@cisc-icca.ca

CISC Statements 

Federal Government Support Programs and Measures

Tariff Remissions

The Department of Finance is accepting applications for the remission of duties where goods cannot be reasonably sourced from within Canada or from non-U.S. alternatives. A remission is an exemption from tariffs for a particular product.

This option is particularly relevant for steel and other industrial inputs where supply chains have been disrupted, or where substitutes simply do not exist. In their applications, companies must provide documentation showing efforts to source alternatives. Supporting evidence such as supplier correspondence, market analysis, and procurement records strengthens the application.

Remissions are granted by Cabinet, and we expect that the first set will be granted following the federal election. Remissions granted during the 2018 U.S. steel tariffs were typically processed quarterly, although there are vastly more products impacted in 2025. The increased volume may result in longer processing times and potentially impact the government’s timelines for granting remissions.

Duties Relief Program

Administered by the Canada Border Services Agency (CBSA), the Duties Relief Program allows businesses to import goods without paying duties, provided those goods are later exported either as-is or as part of a manufactured product. The application process involves the certification of operations and the manufacturing facility, typically taking 60 to 90 days during regular operations to become registered with CBSA.

Duty Drawback Program

For businesses that have already paid duties on imported goods, the Duty Drawback Program allows for retroactive reimbursement when those goods are exported or used to make a good that is exported. This program is also administered by the CBSA and is retroactive on duties already paid. The initial application process is also typically 60 to 90 days.

Employment Insurance Support

New EI provisions have been launched to assist workers in sectors directly impacted by the trade conflict. These measures provide greater flexibility for qualification and faster access to benefits. The federal government has acknowledged that steel and manufacturing workers may be particularly hard hit and has committed to ensuring timely support for our workers.

Special measures have also been introduced under the EI Work-Sharing program to support businesses affected by the tariffs. Employers experiencing a decline in business activity attributable to the threat or potential realization of U.S. tariffs may be eligible for special support.

Financial Assistance for Exporters

Export Development Canada (EDC) is deploying a $5 billion Trade Impact Program to help affected businesses identify new international markets, manage credit and currency risk, and secure working capital. The program is intended to support market diversification and preserve jobs in key export sectors, including steel. More details on this program will be rolled out in the coming months.

Business Development Bank of Canada Loans

The Business Development Bank of Canada (BDC) is making $500 million in low-interest loans available to businesses directly affected by tariffs. These loans are intended for companies that are experiencing supply chain disruption or customer loss due to the tariffs.

Useful Links

Last Updated March 13