At a glance
- Existing tariff relief and remission mechanisms may apply to the new counter-tariffs.
- Eligibility depends on the imported goods, their end use, and the conditions of the applicable remission order.
- Importers should assess potential surtax exposure and available relief before the new tariffs take effect.
A French version will be posted shortly.
This publication was posted based on the information available at the time. Due to the uncertainty of the trade landscape, some rules may have changed since then, but the insights provided remain highly relevant for adapting to ongoing shifts in the market.
Existing tariff relief and remission mechanisms may apply to the new Sept. 8 counter-tariffs, pending final approval and administrative guidance.
This means, goods already covered by certain remission measures may also receive relief from the new tariffs. For example, steel goods currently eligible for remission of the 25% surtax would benefit from relief from the new 50% surtax, provided the terms of the remission order are met.
The government has also indicated that horizontal remission will continue to apply to certain goods and uses until June 30, 2027, including:
- Goods used by identified public health, public safety, and national security entities
- Steel goods used in auto and aerospace manufacturing
- Eligible aluminum goods used as manufacturing inputs, and eligible steel goods used as manufacturing inputs in the auto and in the auto industry.
In practice, businesses may need to assess whether their activities fall within manufacturing, processing, food and beverage packaging, or agricultural production based on the wording of the remission order, applicable NAICS classifications, and CBSA guidance.
This assessment may be particularly relevant for Canadian manufacturers, processors, food and beverage businesses, agricultural producers, auto and aerospace suppliers, and importers using U.S. origin goods in Canadian operations.
For more information on how tariff remission works and the difference between general and specific remission, read our article: Tariff remission can ease import costs.
How can remission help importers manage tariff costs?
For eligible goods, remission may help reduce tariff-related cash flow pressure by allowing duties to be waived at the time of import when the appropriate authorization code is used on the customs declaration.
Paying surtax first and applying for a refund later can create avoidable cash flow strain, particularly for businesses importing high-volume or high-value goods.
Importers should also consider whether other relief programs may apply, including the Import for Re-export Program, Duties Relief Program, or Duty Drawback Program.
Remission requires a supportable customs position
Tariff remission can provide meaningful relief, but it is not simply an administrative exercise. Eligibility depends on a defensible customs position and complete supporting documentation.
Businesses should avoid relying on general assumptions or unsupported interpretations when assessing remission eligibility. If a claim is incorrect, the business may face denied relief, reassessments, interest, penalties, and broader customs scrutiny.
An unsupported position can create exposure that grows with each import. Businesses should monitor the final approved order and CBSA administrative guidance before relying on remission treatment.
Can remission eligibility differ by imported product?
Tariff remission could apply differently depending on the imported goods, their end use, and the conditions of the applicable remission order.
Consider a Canadian food manufacturer that imports approximately $1.2 million annually of U.S.-origin aluminum foil used in food packaging and $600,000 of specialized stainless-steel fittings used in its Canadian processing equipment. At a 50% counter-tariff, the combined annual surtax exposure could reach approximately $900,000.
The remission analysis, however, may differ for each product.
Aluminium foil: The aluminum foil may qualify for existing horizontal remission applicable to eligible non-steel goods used in manufacturing, processing, food and beverage packaging and agricultural production in Canada. If the conditions are met, the manufacturer could potentially avoid approximately $600,000 in annual surtax costs by claiming remission at the time of import rather than paying the tariff and seeking a refund later.
Stainless-steel fittings: The fittings may not qualify for the same horizontal relief. However, if the manufacturer can demonstrate that the fittings are necessary inputs and cannot reasonably be sourced from Canadian or non-U.S. suppliers, it may be able to pursue a specific remission request for the approximately $300,000 in annual surtax exposure.
A single importer may have goods that qualify for existing general relief, goods requiring a specific remission request, and other imports for which no remission is available. Which is why, remission should be assessed product by product.
What should importers do now
Importers should act before the Sept. 8 effective date where possible. They should consider these three steps:
For goods not already eligible for remission, businesses may still be able to request relief under the U.S. Remission Framework, including where goods used as inputs cannot be sourced domestically.
How BDO can help
BDO’s Customs & International Trade Services team can help businesses assess tariff exposure, determine whether remission or other relief programs may apply, and support the documentation needed to defend the position. This includes:
- Reviewing tariff classification, origin, and product use
- Assessing eligibility under existing remission orders
- Identifying opportunities to use authorization codes at the time of import
- Supporting refund claims for surtax already paid
- Preparing remission requests where existing relief does not apply
- Reviewing other duty relief options, including IREP, Duties Relief, and Duty Drawback
With new tariff measures taking effect, businesses should confirm their position before costs build into pricing, inventory, and cash flow.
Contact BDO’s Customs & International Trade Services team to review your position and assess available tariff relief options.
The information in this publication is current as of Aug. 28, 2026.
This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact BDO Canada LLP to discuss these matters in the context of your particular circumstances. BDO Canada LLP, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it.