Update from Fenestration Canada: Customs Notice 25-33 and Proposed Tariff Remission Request

Hello Fenestration Canada members,

This is a complex subject, so I've provided a quick read of the situation at the top. For those who want to understand the picture, please continue reading after the summary.

Action required - please read (30 seconds):

New tariffs under Customs Notice 25-33 are now affecting window and door hardware (HS 8302.41.90) and certain uPVC and fibreglass products (HS 3925.20.00).

Finance included these items to capture products containing steel; many products captured under these codes contain little or no steel at all and/or there's little to no domestic supply.

Fenestration Canada is preparing a tariff remission request, and member support letters are essential to correcting this misalignment.

If you import under either HS code - especially if your hardware or items falling under 3925.20.00 have no steel content - your input is critical.

Letters can be brief and high-level; Fenestration Canada will provide templates and review drafts upon request to adrian@fenestrationcanada.ca.

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I am writing to provide an update regarding Customs Notice 25-33, issued on December 26, which introduced a new set of tariffs intended to protect Canada’s steel producers. These measures include tariff item 8302.41.90 (window and door hardware) and 3925.20.00 (certain builder-grade plastic products, including finished uPVC and fibreglass windows and doors).

Over the past two weeks, I have heard from many members affected by these tariffs. To support you effectively, I will need your help.

I have been in contact with the Ministry of Finance and am currently engaging with the official responsible for this file. A key point raised by Finance is the presence of steel content within products captured by these tariff items. In particular, tariff item 3925.20.00 was included to capture products that incorporate steel reinforcement.

As we know from industry practice, fibreglass and uPVC products do not consistently contain steel, and many products classified under this code contain no steel at all. As a result, a significant portion of what is currently captured does not align with the stated policy intent of the notice.

Proposed Path Forward: Remission Request

At this stage, the approach recommended by Finance is to pursue a tariff remission request. If other avenues emerge or prove successful, I will provide updates as they develop but know that this is the only path officially available.

For clarity, the remission process works as follows:

• Fenestration Canada submits a remission request on behalf of the sector.

  
  

• Because this request has a horizontal effect (i.e., it applies broadly across an industry rather than to a single firm), it is assessed by an assigned official within the Ministry of Finance. Although I don't want to dissuade individual members from submitting, know that if they get bombarded by requests, our industry request will take longer to process.

  
  

• There is typically a period of back-and-forth between Finance and Fenestration Canada to test whether the request meets the intent of the Customs Notice. Unknown how long that will take and I'll keep you all updated via this channel as we make progress.

  
  

• If Finance determines that the request is justified, the Minister of Finance (Minister Champagne) may issue an Order in Council to remove or modify the application of the tariff item.

  
  

Scope of the Remission Request

We are preparing a remission request seeking relief from customs duties applied to goods classified under the following tariff items:

• 8302.41.90: Window and door hardware is a critical input, and in many cases, there are no Canadian-produced alternatives available at the required scale or specification.

  
  

• 3925.20.00: This code captures finished fibreglass products (notably door slabs), where domestic manufacturing capacity is limited and where steel content is often absent or minimal.

Request for Member Support Letters

As part of the remission process, Finance looks for evidence of real-world impacts. To support this effort, I am seeking letters of support from members willing to describe how these tariff items affect their operations.

Letters do not need to include sensitive commercial information or detailed pricing data. High-level, practical input is sufficient. In particular, it is important that members be explicit about steel content (or the lack thereof).

Helpful points to address include:

• How products under these tariff items are used in your operations;

  
  

• Whether domestic supply is limited or unavailable for your needs;

  
  

• Whether the products you import do or do not contain steel reinforcement;

  
  

• The impact of these duties on costs, competitiveness, or investment decisions;

  
  

• Any downstream effects on manufacturing, employment, pricing, or project delivery.

If you are willing to provide a letter of support, please let me know as soon as possible. I can provide a short template tailored to the tariff item(s) affecting your business and am happy to review drafts before submission.

Finally, any concerns or feedback on this approach are welcome. While I cannot promise a change in direction, critical input is always appreciated, and I will continue to adjust course where possible in line with the overall sentiment of the membership.

Thank you for your engagement and support.

Humbly yours,

Adrian Edge

Director of Codes and Regulatory Affairs