Highlights
- CN26-23 sorts U.S.-origin goods into three surtax tiers—15%, 25%, and 50%—replacing the old single flat rate.
- Narrow exemptions exist, but importers must claim them correctly with proper documentation at time of accounting.
- CN26-23 doesn't stack with the Steel Derivative Goods Surtax Order, though separate steel and aluminum rules still apply.
On September 7, 2026, the Canada Border Services Agency issued a new order (CN26-23) that changed the surtax landscape for U.S. imports again, and it took effect the very next day, September 8, 2026. This is not a rate increase on an existing surtax. It is an entirely new one, and it reaches far beyond the steel and aluminum shipments that have dominated the conversation for more than a year.
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Why did Canada introduce a new surtax order?
What are the three rates under Canada’s surtax on U.S. imports?
What goods are exempt from CN26-23?
Does Canada’s surtax on U.S. imports stack with other surtax orders?
The case for a global trade management system that never stops reading these notices
Why did Canada introduce a new surtax order?
Canada introduced the surtax in response to the United States’ Section 338 tariffs on Canadian goods, with the list of affected products drawn from goods targeted by both Section 338 and Section 232 tariffs, and the surtax rate generally matching the U.S. rate under the United States Surtax Order (2026). Unlike the steel and aluminum order that came before it, this one applies to a much broader set of U.S.-origin goods, though it excludes goods eligible to be marked as originating from Puerto Rico, Guam, and a handful of other U.S. territories, and the complete list of affected products published by the Department of Finance runs to hundreds of tariff lines. If your team has never tracked surtax exposure outside of metals, this is the notice that changes that.
What are the three rates under Canada’s surtax on U.S. imports?
Where the original steel and aluminum surtax applied a single 25% rate, CN26-23 sorts goods into three tiers: 15% for goods listed in Schedule 1, 25% for Schedule 2, and 50% for Schedule 3, each declared under its own CARM surtax code, 26186A, 26186B, and 26186C. The surtax is calculated on the value for duty first. This is in addition to any other duties owing (e.g., any applicable anti-dumping duties). GST will be applied on that total duty amount, so a manual calculation that applies GST before adding the surtax will come up short every time.
On an identical shipment, moving from the 25% tier to the 50% tier roughly doubles the total surtax and tax owed, even though nothing about the product itself has changed. Assign the wrong tariff classification and, by extension, the wrong tier, and the landed cost of that shipment can move by dozens of percentage points before anyone catches it. Multi-tier duty structures like this one are becoming the norm across active trade actions, not the exception, and each new structure adds its own thresholds for a trade team to track alongside the surtax exposure it already manages.
What goods are exempt from CN26-23?
The order carves out goods classified under Chapters 98 and 99 of Canada’s tariff schedule, unless the specific tariff item also appears on a separate Schedule 4 list, and it exempts goods that were already in transit to Canada when the surtax took effect, provided the importer can produce a bill of lading or other cargo control documents on request. Low-value courier and postal shipments get no such break: the order applies even to goods that would otherwise qualify for relief under the Postal Imports Remission Order or the Courier Imports Remission Order, so de minimis thresholds will not shield a small e-commerce shipment from the surtax.
A narrow personal exemption also covers Campobello Island residents returning from short trips across the border, alongside longstanding exceptions for returned goods, goods repaired or altered abroad, non-resident baggage, and ships’ stores. None of these exceptions apply automatically. Each one has to be claimed correctly at the time of accounting, with the right documentation in hand, or it does not apply at all, an obligation that sits squarely inside the reasonable care standard importers are already held to for every other part of a customs declaration.
Does Canada’s surtax on U.S. imports stack with other surtax orders?
CN26-23 includes a useful clarification: where a good would otherwise be caught by both this order and the Steel Derivative Goods Surtax Order, only the surtax imposed under CN26-23 applies, so the two are not cumulative. That is worth reading closely, because the Steel Derivative Goods Surtax Order is not the same measure as the original steel and aluminum surtax that took effect in March 2025 under the United States Surtax Order (Steel and Aluminum 2025). The Steel Derivative Goods Surtax Order is a separate, later measure that took effect in December 2025, applies to steel derivative products such as prefabricated steel buildings and wind tower sections, and reaches imports from every country of origin, not only the United States.
The notice itself says nothing about how CN26-23 interacts with that original steel and aluminum surtax specifically. The government addressed it separately: the Order Amending the United States Surtax Order (Steel and Aluminum 2025), registered September 4, 2026 and in force alongside CN26-23, restructures the original steel and aluminum surtax into its own 25% and 50% tiers. Most existing steel and aluminum tariff lines stay at 25%, while a separately listed set of additional lines moves to 50%, so the older order ends up mirroring CN26-23’s own tier logic rather than stacking on top of it. Importers moving steel or aluminum goods should check which specific tariff line they fall under in the amended schedule rather than assume a single flat rate still applies across the board.
The case for a global trade management system that never stops reading these notices
Every moving part above, correct tier assignment, exemption eligibility, in-transit proof, accurate CARM coding, and knowing which of two similarly named orders actually governs a shipment, has to be right at the moment of import, not weeks later when a CBSA officer asks for proof. ONESOURCE Global Trade Content keeps the underlying tariff and surtax data current the day a notice like this takes effect, often delivered through the same API connections trade teams already use to move that data into their own systems, instead of waiting for someone to notice the change.
ONESOURCE Global Classification powered by CoCounsel narrows the highest-risk step in the whole process, assigning the right HS code, and by extension the right schedule and surtax tier, to goods that may never have needed this level of scrutiny before this order existed. ONESOURCE Import Management recalculates landed cost across a product mix that now looks nothing like the steel and aluminum shipments this all started with, and ONESOURCE Government Connectivity carries the correct surtax code straight into a CARM filing, so the distinction between 26186A, 26186B, and 26186C, or between two orders that share a family resemblance but not a scope, does not come down to memory under deadline pressure.
For businesses that cannot easily source affected goods outside the U.S., the same visibility into which tariff lines are hit makes it easier to flag which shipments are worth assessing against the government’s U.S. Remission Framework for transitional relief. Canada’s existing Duties Relief and Duty Drawback Programs also remain available for surtax paid or payable, and CUSMA-origin goods are not held to the usual limit on relief, so some shipments may qualify for full relief if they meet CUSMA’s criteria, one more reason accurate origin and classification data matters as much as getting the tier assignment right.
Orders like CN26-23 will keep arriving with almost no lead time, and they will keep interacting with each other in ways the text does not always spell out. The businesses that stay compliant through this stretch will not be the ones that read every notice the fastest. They will be the ones that already built a tariff-resilient compliance program before this order landed.
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