Steel derivative surtax remission: who qualifies, which code goes on the CAD, and claiming it back on past lines

What does the remission order relieve?

The Steel Derivative Goods Surtax Remission Order (SOR/2026-34, P.C. 2026-145) came into force on February 24, 2026, two months after the 25% steel derivative surtax started on December 26, 2025. It was made under section 115 of the Customs Tariff and relieves only one surtax: the one under the Steel Derivative Goods Surtax Order (SOR/2025-267). Whether a line carries that surtax at all is a separate test, set out in is my product on the steel derivative surtax list.

The order was rewritten on October 23, 2026 by the Order Amending the Steel Derivative Goods Surtax Remission Order, No. 1 (SOR/2026-227, P.C. 2026-1014), published in the Canada Gazette on November 4, 2026. It replaced the single schedule with three, replaced the conditions in section 5, and came into force on the day it was registered. On November 11, 2026 the Justice Laws consolidation was still current only to October 19, 2026, so the amended text has to be read from the Gazette.

Who qualifies, and which code goes on the CAD?

CBSA Customs Notice 26-07, updated November 2, 2026, assigns one special authorization code per ground of relief:

Three conditions apply to every ground. Paragraph 5(d): no other claim for relief of the surtax has been granted under the Customs Tariff for the good. Paragraph 5(e): the importer claims remission within two years after the date of importation. And Customs Notice 26-07, paragraph 10, asks that each claim be supported by documents such as the CAD, purchase order, commercial invoice and bill of lading.

How do the schedules work?

Schedule 1 is the broad one. It names goods by a tariff classification number, sometimes eight-digit and sometimes ten-digit, together with a product description. The Gazette statement says goods in Schedules 1 and 2 have been found not to be currently produced in Canada, and that the amendment added 204 products to Schedule 1, including certain chains, fasteners and garage doors. Matching is two-part: the tariff number and the description. A roller chain under 7315.11.00 qualifies only if it matches the column 2 description (for example, roller chain to specification ANSI/ASME B29.1 within the stated pitch, plate height and pin diameter ranges). Another roller chain under the same tariff item does not.

Schedule 2 is time-limited. Items 1 and 2 cover goods imported before March 31, 2027. Item 3, grinding balls of 7326.11.00, was in the original schedule; the amendment moved it to Schedule 2 with the date "Day on which this Schedule comes into force", which is October 23, 2026. Grinding balls imported from that day pay the surtax with no remission under this order.

Schedule 3 is importer-specific. It covers 47 products for named businesses facing, in the Gazette statement's words, exceptional circumstances such as pre-existing contracts. The most common period is December 26, 2025 to May 31, 2027; other items run to dates as late as March 31, 2029, and a few start later, such as November 1, 2026 or January 1, 2028. Each item maps to one of nine codes, 26-0145F01 to F09, listed in Customs Notice 26-07, paragraph 27.

The wind-tower ground has its own guidance in Appendix A of Customs Notice 26-07. A deposit, a power purchase agreement or a notice of a winning bid is not a purchase order; a binding contractual commitment signed before December 26, 2025 is, and it can run through an intermediary if each link was signed before that date.

Does the claim deadline really run from importation?

Yes, and it is the date that is easiest to get wrong. The deadline in paragraph 5(e) of the amended Order is two years after the date of importation. It is not the four years after accounting that applies to an ordinary refund under section 74 of the Customs Act, and it is not counted from the date the good was added to a schedule. Customs Notice 26-07 lists the same two-year condition among its conditions of relief. A surtax line released on December 26, 2025, the first day of the surtax, must be claimed by December 26, 2027 at the latest.

The window matters most for goods added on October 23, 2026. Paragraph 5(a) gives Schedule 1 goods no import-date condition, so a chain or fastener added in October qualifies for every importation since December 26, 2025, as long as the claim for each one is made within two years of that importation. The Gazette statement describes importers submitting refund requests "for goods already imported prior to the entry into force of this Order". The CBSA, it says, strives for a 90-day processing standard for those refunds.

How is remission claimed on the CAD?

Customs Notice 26-07 sets out three cases:

1. At accounting. Declare surtax code 25267A and the surtax in field 85 (the number CBSA's notices use; D17-1-10 calls the same field 68, see the CAD field by field), and enter the special authorization code in the Special Authority OIC field. The notice is explicit that "surtax must be declared in addition to the applicable remission".
2. After filing, before the payment due date. File a correction with reason code R5-00-COT. The surtax owing is relieved.
3. After the payment due date. File an adjustment with reason code R2-74-1-GR-53. The surtax paid is refunded. The steps are in CBSA Memorandum D17-2-1, and the wider correction and refund routes in correcting a Canadian entry.

Non-commercial goods cannot be adjusted in CARM and go through Form B2G instead (Customs Notice 26-07, paragraph 31).

A worked line: roller chain imported in March, added to Schedule 1 in October

The figures are illustrative. A CAD line of roller chain to ANSI/ASME B29.1, within the dimensions in Schedule 1, tariff item 7315.11.00, Japanese origin, released March 10, 2026, value for duty CAD 60,000. The Customs Tariff 2026 lists 7315.11.00 as free under the MFN tariff and every preferential tariff, so the customs duty is zero.

The arithmetic: CAD 60,000 × 25% = CAD 15,000. In March 2026 the line was correct: roller chain was not in the schedule of the original remission order, so the importer owed the surtax. On October 23, 2026 the amendment added it to Schedule 1, with no import-date condition, so the March surtax became recoverable. The CAD payment due date has passed, so the route is an adjustment, not a correction. The deadline is two years after the March 10, 2026 importation.

The GST on the line was charged on value plus duty plus surtax, CAD 75,000 × 5% = CAD 3,750, following the method in Customs Notice 25-33. What a surtax refund does to that GST and to an input tax credit already claimed is covered in GST on imports after a CAD correction.

Two variations show the edges of the rule. A second line of grinding balls under 7326.11.00 released on September 15, 2026 is also recoverable, under Schedule 2 item 3 and code 26-0145E02, because it was imported before October 23, 2026. The same grinding balls released on November 2, 2026 are not: the surtax of 25% is owed and no code under this order relieves it.

What does an audit of remission lines look for?

Money left on the table:

• Lines that paid the surtax on goods now in Schedule 1. Run every 25267A line since December 26, 2025 against the current schedule, description and all.
• Lines for health, safety or defence buyers, or for health care, where the importer did not know the end use qualified.
• Wind-tower lines with a pre-December 26, 2025 contract chain on file.

Claims that do not hold:

• A 26-0145C code on a good that matches the tariff number but not the description.
• 26-0145E02 on grinding balls imported from October 23, 2026.
• A Schedule 3 code on a CAD whose importer is not the business named in column 1, or outside the column 4 period.
• A remission code with no surtax declared, which Customs Notice 26-07 says is not how relief is claimed.
• A remission claim on goods whose surtax has already been relieved through drawback or duties relief (paragraph 5(d)).

Deadlines: every unclaimed line ages toward its two-year limit from importation. Sort findings by import date and file the oldest first.

TariffSense reads CAD/B3 lines and broker accounting exports, matches each steel derivative line against the remission schedules in force, by tariff number and by description, flags paid lines that qualify and claimed lines that do not, and shows how long each line has left in its two-year window. Filing stays with your broker or your own CARM account. The same check across all of Canada's surtax remission orders is in special authority codes on the CAD, and the full post-entry audit is in auditing CAD/B3 entries after accounting.

What should you do next on your own entries?

Pull every line with surtax code 25267A since December 26, 2025. Compare each one, tariff number and product description, against Schedules 1 to 3 of the amended order in the Gazette. File the qualifying lines from the oldest importation date first, with the right code and reason code, and keep the documents that show the description match. Where the goods may also have been exported, decide between remission and drawback before filing either, because only one relief can be granted. Confirm any filing with a licensed customs broker.