Update on Recent Counter Tariffs: Update to United States Surtax Remission Order 25-19

6 hours ago

3 min read

Dear Members,

Customs Notice 25 -19 was recently updated, providing additional guidance on the remission of surtaxes for goods imported from the United States for use in Canadian manufacturing or processing.

This update is particularly relevant following the new United States Surtax Order (2026), which took effect on September 8, 2026.

In our previous correspondence, we identified several tariff classifications relevant to the fenestration industry, including:

7610.10.00 - aluminum doors, windows, frames and thresholds
8302.41.10 - certain casement and window hardware
8302.42.00 - miscellaneous fittings and hardware
8302.49.00 - hinges and other fittings
7308.30.00 - iron or steel doors, windows, frames and thresholds
7318.11.00 through 7318.29.00 - a broad range of iron or steel fasteners

The manufacturing remission pathway established under the United States Surtax Remission Order (2025) remains available using CBSA special authorization code 25-0466C. Recent amendments have expanded that pathway to include qualifying goods subject to the new United States Surtax Order (2026).

Importantly, however, there are now different remission timelines depending on which surtax regime applies.

1. Hardware subject to the new United States Surtax Order (2026)

Tariff classifications including 8302.41.10, 8302.42.00 and 8302.49.00 are included in Schedule 2 of the new 2026 Order and are subject to a 25% surtax.

Where these goods are imported for use in Canadian manufacturing or processing and meet the applicable conditions, they may be eligible for remission using 25-0466C.

There is currently no stated expiry date for this manufacturing remission under the 2026 Order.

2. Aluminum goods

Aluminum products remain covered under the separate United States Surtax Order (Steel and Aluminum 2025).

Goods in Aluminum Schedules 1 and 1.1 remain eligible for the general manufacturing remission where they are imported before July 1, 2027.

This includes 7610.10.00 - aluminum doors, windows, frames and thresholds, which is currently included in Schedule 1.1 and subject to a 50% surtax before remission.

Where qualifying goods are imported for direct use in Canadian manufacturing or processing, 25-0466C may be used to claim remission through June 30, 2027.

3. Steel goods

The situation for steel is different.

Goods in Steel Schedules 2 and 2.1 of the United States Surtax Order (Steel and Aluminum 2025) qualify for the general manufacturing remission only where they were imported before February 1, 2026.

This affects several classifications relevant to fenestration manufacturing, including:

7308.30.00 - iron or steel doors, windows, frames and thresholds
7318.11.00 through 7318.29.00 - iron or steel screws, bolts, nuts, washers, rivets and other fasteners
7326.90.90 - other articles of iron or steel, a classification currently being used for some steel insulating glass spacer

As the underlying Order is presently written, these Schedule 2.1 goods do not have access to the general manufacturing remission for imports occurring after January 31, 2026.

Fenestration Canada has identified an apparent discrepancy between the underlying Order in Council and the September 11 update to Customs Notice 25-19 regarding the treatment of Schedule 2.1 steel goods. We are seeking clarification from CBSA and will provide members with an update once we receive a response.

What Members Should Do

Members importing U.S.-origin components should review their tariff classifications with their customs broker and determine which surtax regime applies to their products.

Members should also review whether 25-0466C can be used for qualifying goods imported for direct use in Canadian manufacturing or processing.

If you are seeing surtaxes applied to a fenestration component and are unsure whether remission may be available, please send the product description, tariff classification and country of origin to adrian@fenestrationcanada.ca.

We are continuing to map where the industry is affected and will provide support and pursue relief where possible.

Humbly Yours,

Adrian Edge

Director - Codes and Regulatory Affairs