Steel TRQs and the 50% over-quota surtax: permits, quarters, and checking past CADs

How does Canada's steel tariff-rate quota work?

The Order Imposing a Surtax on the Importation of Certain Steel Goods (SOR/2025-148) came into force on June 27, 2025. It does not charge a surtax on every steel import. It sets a quarterly quota, in tonnes, for each class of steel goods, and a surtax of 50% of value for duty applies to goods that go over it. There are two separate quota tables:

• Schedule 1 for goods that do not originate in a country listed in Schedule 3 (the "no trade agreement" table, section 2); and
• Schedule 2 for goods that originate in a Schedule 3 country (the "trade agreement" table, section 2.1). Schedule 3 lists 49 countries, including the EU member states, the United Kingdom, Japan, Korea, Vietnam, Australia, Chile, Peru, Ukraine and Switzerland.

Goods originating in Canada, the United States or Mexico are outside the order altogether (paragraph 3(b)), and origin follows the marking rules, so steel made elsewhere and shipped through the US is still caught. Global Affairs Canada (GAC) runs the quota through import permits under item 82 of the Import Control List; the CBSA collects the surtax.

Each table has 23 classes, from carbon steel ingots and billets through hot-rolled, cold-rolled, coated and pre-painted sheet, plate, rebar, bar, wire rod, structural steel, wire, to line pipe, oil country tubular goods, standard pipe, piling pipe and hollow structural sections. Each class lists its tariff classification numbers (column 4), a quarterly total (column 2) and a percentage per country (column 3).

When does a line go over quota?

Under subsections 2(1) and 2.1(1), as in force since December 26, 2025, a line pays the 50% surtax if, in the same quarterly period, either:

1. imports under the tariff classification numbers in that class exceed the quarterly total; or
2. imports in that class from the same country exceed the class total multiplied by that country's percentage.

The test an importer actually meets is the permit. Subsections 2(4) and 2.1(4) say goods are "considered to be imported in excess" of the limits unless they are imported under a shipment-specific import permit issued under section 8 of the Export and Import Permits Act that is valid when the goods are accounted for. Notice to importers No. 1163 explains the mechanics:

• Permits are issued first come, first served, until the class total or the country share is used up.
• A request can be made up to 15 days before the expected date of entry.
• A permit is valid for 30 days: 5 days before and 24 days after the expected date of entry. Its validity must cover the day the CBSA releases the goods.
• Quota counts as used as soon as a permit is issued, and is returned only if the permit is cancelled.
• Quantities above the quantity on the permit pay the surtax.
• Permits can be issued retroactively for shipments already accounted for, if quota remains.
• Every shipment also cites General Import Permit No. 80 or 81. Without a valid shipment-specific permit the goods still enter under the general permit, and pay the surtax.

Which quarter does a line fall in?

The quarters were reset twice. The dates in the order and in Notice No. 1163 are:

Section 4 repeals the order on the second anniversary of its coming into force, June 27, 2027; the extension came from SOR/2026-119. The quota volumes changed with each amending order, so a past line has to be tested against the schedule in force on its own date. CBSA Customs Notice 25-24 sets out which schedule applies to which window, and the point-in-time versions on Justice Laws hold the text of each.

Three rule changes inside those windows matter for audits:

What happens when another surtax could also apply?

From August 1, 2025, section 3.1 settles it: if a good subject to the quota surtax is also subject to any other surtax under the Customs Tariff, "only the surtax under this Order is applicable". A Chinese-origin steel good over quota pays 50%, not 50% plus the China surtax. Between June 27 and July 31, 2025, the two applied together; Customs Notice 25-24 works an example with both. The quota surtax also sits ahead of the steel derivative surtax, which excludes goods subject to it (paragraph 2(a) of SOR/2025-267). How the other steel orders rank is set out in why your CAD shows the wrong surtax.

Exceptions in section 3: goods in transit on or before June 27, 2025 (Schedule 1 countries) or August 1, 2025 (Schedule 2 countries); goods originating in Canada, the US or Mexico; casual goods; and goods under a Chapter 98 item. Customs Notice 25-24 states that no in-transit exception came with the December 26, 2025 or June 2026 amendments. Goods within an exception are also left out of the quota count.

How is the quota surtax coded on the CAD?

Customs Notice 25-24, paragraph 35, puts the amount in field 85, the number CBSA's notices use for the Surtax field (the CAD field by field explains why D17-1-10 calls it field 68):

A worked line: hot-rolled sheet with a short permit

The figures are illustrative. Hot-rolled sheet in coils, under 3 mm thick, tariff classification number 7208.39.00.00, Schedule 1 class 3 (hot-rolled sheet). Origin: a country not in Schedule 3. 600 tonnes, value for duty CAD 540,000, released October 20, 2026, in the quarter from September 30 to December 29, 2026. The Customs Tariff 2026 lists 7208.39.00 as free under the MFN tariff. Assume no SIMA measure applies to this product and origin; where one does, its duty is added on top.

The quarterly total for hot-rolled sheet from non-trade-agreement countries is 2,366.7 tonnes, and one country may use 41% of it: 2,366.7 × 41% = 970.347 tonnes. The importer holds a permit for 500 tonnes, valid on October 20.

Without any permit the whole line pays CAD 270,000 of surtax, and GST rises to CAD 40,500. If the permit's validity had ended before October 20, the same applies, because Notice No. 1163 treats it as unused and expired.

The 100 tonnes are not necessarily lost. The country still had 470.347 tonnes of its share available if no one else had used it. If GAC issues a retroactive permit for the 100 tonnes, the importer can ask the CBSA for a refund of the CAD 45,000, as Customs Notice 25-24, paragraph 17, describes, by an adjustment of the CAD. A permit of that kind depends on quota still being available, so the request has to be made quickly; GAC publishes daily utilization reports by class and country.

Can remission recover a quota surtax?

The Surtax on Imports of Certain Steel Goods Remission Order, 2025 (SOR/2025-287), as amended by SOR/2026-70, covers two cases. CBSA Customs Notice 26-02 gives the codes:

Each claim must be made within two years after the date of importation and fails if another relief of the surtax was granted. A schedule match is by class and description, as with any description-based remission.

How do you check the quota surtax on past CADs?

1. List every line under a tariff classification number in Schedules 1 or 2, as they read on the line's release date, with origin, tonnes, release date, surtax code and field 85.
2. Drop lines originating in Canada, the US or Mexico. Then check those origins: steel invoiced from the US is not US steel by default.
3. Match each remaining line to a permit, and check the permit's quantity and its 30-day validity against the release date.
4. Recalculate the surtax on any quantity over the permit or without one, and check the GST base.
5. Check for double surtaxes on lines from August 1, 2025: a quota line should carry no China, melt-and-pour or derivative surtax as well.
6. Look for recoveries: retroactive permits while quota is open, in-transit remission for summer and December 2025 shipments, and schedule goods under code 25-0976B.
7. Sort by direction and deadline. Underpayments go to a self-adjustment under section 32.2 of the Customs Act; overpayments to a refund adjustment or a remission claim. See correcting a Canadian entry.

TariffSense reads CAD/B3 lines and broker accounting exports, places each steel line in its quota class and quarter, checks the surtax code and amount against the permit data on file and the precedence rules, and flags lines that paid a second surtax, lines over their permit quantity and lines that may still recover surtax through a permit or remission. Filing stays with your broker or your own CARM account. For the US side, where quota status is fixed when the entry summary is presented, see tariff-rate quotas on past entries; for the full Canadian audit, auditing CAD/B3 entries after accounting.

What should you do next on your own entries?

Start with lines from the current quarter, while quota may still be open for a retroactive permit. Then work back through each quarter since June 27, 2025, checking permit validity against release dates and any line with two surtaxes after August 1, 2025. Confirm any filing with a licensed customs broker, and permit questions with Global Affairs Canada.