Canada counter-tariff relief just became available on the surtax that started biting five days ago. On 11 September 2026 the Canada Border Services Agency updated Customs Notice 25-19, and the United States Surtax Remission Order (2025) now reaches goods hit by the United States Surtax Order (2026) — the counter-tariffs that came into force on 8 September 2026 at rates of 15, 25 and 50 per cent. If you import American-origin inputs, that changes what you should be coding on entries filed this week. The relief is claimed on the declaration, not requested afterwards, and every entry you file without the code is a refund you will have to chase later.
What changed on 11 September 2026?
Until last week there were two separate facts sitting awkwardly beside each other. Canada’s new counter-tariffs applied from 8 September. The standing remission order, which forgives surtax on goods used in Canadian manufacturing and in health and safety work, was written against the 2025 surtax orders. Importers were left guessing whether relief would follow the new surtax, and Finance had signalled an extension was coming but was subject to Governor in Council approval.
The update to Customs Notice 25-19
CBSA’s notice now carries an updated date of 11 September 2026, and the operative paragraphs name the United States Surtax Order (2026) directly. Paragraph 4 (public health, public safety and national security) covers it. Paragraph 5 (health care) covers it. Paragraph 6 — manufacturing, processing and packaging, the category most Canadian importers actually use — covers it as well. That is the whole story in one line: the remission categories you already knew now apply to the 8 September surtax.
One practical warning when you read the notice yourself. The introductory list of covered orders near the top of the notice still reads against the earlier 2025 instruments. The category paragraphs are the operative text. Read paragraphs 4 through 6 and the schedule paragraphs, not the opening summary, when you are deciding whether a line qualifies.
What Canada counter-tariff relief does not do
Two limits on Canada counter-tariff relief are worth stating before anything else. Relief is not an exemption, and it is not a CUSMA question. Canada’s counter-tariffs apply to United States-origin goods precisely because they are United States-origin, so no origin certificate moves a good out of the surtax. Nor does relief cover the American duties running the other way: the Section 338 measures on Canadian goods are a separate regime with their own dates, and our note on the Section 338 import ban covers the 15 September scope change now two days away and the 29 September import prohibition now 16 days away. Canada counter-tariff relief is a Canadian import measure only.
It also does not stack. The notice is explicit that no other surtax relief may have been granted on the same good, and that you must hold documentation substantiating the qualifying use for CBSA inspection.
Which goods qualify for Canada counter-tariff relief?
Canada counter-tariff relief is use-based. The remission order relieves surtax on goods put to defined uses, not on goods defined by who imports them. Your eligibility turns on what the good is for once it lands.
The categories and their special authority codes
| Remission category | Special authority code | Covers the 2026 counter-tariffs? |
|---|---|---|
| Public health, public safety, national security | 25-0466A | Yes — named at paragraph 4 |
| Health care | 25-0466B | Yes — named at paragraph 5 |
| Manufacture, processing or packaging | 25-0466C | Yes — named at paragraph 6 |
| Aircraft, spacecraft, motor vehicles and parts | 25-0466S01 | Steel and aluminum order only |
| Schedule 1 goods | 25-0466D | Check the schedule paragraph against your line |
| Schedule 2 goods | 25-0466M | Check the schedule paragraph against your line |
| Schedule 4 goods | 25-0466Q01 | Check the schedule paragraph against your line |
| Motor vehicles (Schedule 5) | 25-0466N | Check the schedule paragraph against your line |
| Schedule 6 goods | 25-0466T01 | Check the schedule paragraph against your line |
Schedule 3 items run from 25-0466E through 25-0466P02, and Schedule 4.1 items from 25-0466R01 through 25-0466R23. The correct code depends on the specific item, so read the notice against your eight-digit classification rather than picking the nearest-looking code.
The manufacturing category is broader than most importers assume
The order defines processing to include adjustment, assembly or modification of the goods, and the category extends to agricultural production and to food and beverage packaging. A brand that imports United States-origin components and kits, labels or repacks them in a Canadian fulfillment centre is doing something the order recognises. What it will not accept is a general statement that your company manufactures. The burden is showing that a specific imported line entered a qualifying activity, which means production records, bills of material or packing records tying the line to the finished output.
How do you claim Canada counter-tariff relief on a CAD?
This is where Canada counter-tariff relief is won or lost. Qualifying is not claiming, and the counter-tariff surtax stays on the entry until the relief code is in the right field.
Coding the Commercial Accounting Document
Declare the surtax and claim the relief in the same accounting. Under Customs Notice 26-23, the surtax itself is reported using code 26186A for the 15 per cent rate, 26186B for 25 per cent and 26186C for 50 per cent, with the amount entered in field 85 of the Commercial Accounting Document. The remission is then claimed by entering the relevant special authority code in the Special Authority OIC field. You are not omitting the surtax. You are declaring it and relieving it on the same entry. If your CARM account structure is still settling, our guide to CARM requirements for non-resident importers covers the account layer this sits inside, and our walkthrough of Canada surtax declaration codes covers the surtax side of the same entry.
Fixing an entry you already filed
Entries filed between 8 and 11 September were almost certainly coded without relief, because relief was not yet documented as covering the 2026 order. Those are recoverable. A claim can be made within two years after the date of importation. Corrections before the CAD payment due date use reason code R5-00-COT. After the payment due date, adjustments use reason code R2-74-1-GR-53, and non-commercial adjustments use Form B2G.
What deadlines apply to the relief?
Canada counter-tariff relief runs on windows, and the windows are the quiet failure mode.
A line that qualifies today can still fail on timing. A claim outside its window fails on the date alone, no matter how well the qualifying use is documented.
The dates confirmed in the notice
| Item | Date | Status as at 13 September 2026 |
|---|---|---|
| Counter-tariffs in force (United States Surtax Order 2026) | 8 September 2026 | Live — in effect 5 days |
| Customs Notice 25-19 updated to cover the 2026 order | 11 September 2026 | Live — in effect 2 days |
| General import window for remission under sections 1 and 2 | Before 1 July 2027 | Open |
| Schedule 3 goods | Dates set per item in column 3 of that schedule | Varies by line |
| Schedule 4 goods | Before 1 September 2025 | Closed |
| Window to file a remission claim | Within 2 years of the date of importation | Open |
A note on what is confirmed and what is not. The dates above are stated in CBSA’s notice. The schedule-specific windows for steel and aluminum lines are presented inconsistently enough across the notice’s schedule paragraphs that we will not restate them here as a single rule — check your own schedule paragraph directly before you code. And the amending order behind this update had not yet appeared in Canada Gazette, Part II at the time of writing, so CBSA’s notice is the operative guidance today; confirm the order text when it publishes.
Your action list for the next two weeks
A dated checklist
Work the counter-tariff relief review in this order. Each step below assumes Canadian entries carrying the 8 September surtax.
- Today, 13 September: pull every entry accounted for on or after 8 September that carried surtax codes 26186A, 26186B or 26186C. That is your review population.
- By 15 September (2 days): decide, line by line, whether the goods enter manufacturing, processing, packaging, health care or public safety use in Canada. Assign the category code before your next accounting run.
- By 15 September (2 days): separately confirm whether any of your outbound United States-bound lines are caught by the Section 338 scope revision taking effect at 12:01 a.m. eastern time that day. Different regime, same week.
- By 19 September: brief your customs broker in writing on which of your part numbers now carry a remission code, so it is applied at accounting rather than reconstructed later.
- By 29 September (16 days): file corrections under R5-00-COT for entries still inside their payment due date, and log the rest for R2-74-1-GR-53 adjustment.
- Standing: build the evidence file now — bills of material, production or packing records, and the classification worked against the schedule paragraph. Two years is the claim window, not the memory window.
How Transway Xpress Global solves this
Relief only works if it reaches the declaration
Canada counter-tariff relief is an operations problem more than a customs problem. Most importers who lose it do not lose it on eligibility. They lose it because nobody connected the receiving record to the customs entry, and the code went unclaimed. Transway Xpress Global runs D2C and B2B fulfillment, Amazon FBA prep, warehousing and cross-border shipping out of warehouses in Oakville and Etobicoke, Ontario and Buffalo, New York, with an office in Pendleton, Indiana, backed by trucking parent Transway Transport, operating in Oakville since 2014.
That matters here for one reason: when the kitting, labelling and repacking happen in our fulfillment centre, the records that substantiate a manufacturing, processing or packaging claim are generated as a by-product of the work, tied to the receiving line and the part number. Inventory and order management give you the trail from imported line to finished output rather than a reconstruction six months later. If your inbound United States-origin volumes are large enough that the surtax now changes your landed cost, our note on the counter-tariff list update and our duty deferral guide cover the other levers worth pulling in the same review.
Summary
The one thing to take away
On 11 September 2026, CBSA’s updated Customs Notice 25-19 confirmed that the standing remission categories — public health and safety, health care, and manufacturing, processing and packaging — now apply to the surtax imposed by the United States Surtax Order (2026). Canada counter-tariff relief is therefore available on entries from 8 September onward, claimed with a special authority code on the Commercial Accounting Document, correctable for two years, and worth nothing at all if it never reaches the entry. Our fuller Canada surtax remission guide walks through the categories in more depth, and the commercial invoice guide covers getting the origin and description fields right at source so the claim survives review.
Frequently asked questions
What is Canada counter-tariff relief?
It is remission — the legal forgiveness of a surtax — applied to Canada’s counter-tariffs on United States goods. It runs through the United States Surtax Remission Order (2025), administered by CBSA and explained in Customs Notice 25-19. Relief is not automatic and not granted at the border case by case. You claim it at the time of accounting by entering a special authority code, and you keep documentation showing the goods went into a qualifying use.
Does Canada counter-tariff relief now cover the 8 September 2026 surtax?
Yes, for the main categories. CBSA updated Customs Notice 25-19 on 11 September 2026, and the paragraphs covering public health, public safety and national security, health care, and manufacturing, processing and packaging all name the United States Surtax Order (2026). The schedule-based categories are mixed, so check the schedule paragraph that matches your tariff classification rather than assuming the whole order carried across.
Does CUSMA exempt my goods from Canada’s counter-tariffs?
No. Canada’s counter-tariffs target United States-origin goods, so qualifying as North American origin does not move a good out of the surtax. Nor does CUSMA help goods of Indian or other non-North-American origin entering Canada or the United States — CUSMA preference applies to North-American-origin goods only. On the American side, Section 338 duties apply regardless of whether goods qualify as USMCA-originating.
I filed entries on 9 and 10 September without a remission code. Is that money gone?
No. A remission claim can be made within two years after the date of importation. If the entry is still inside its payment due date, correct it using reason code R5-00-COT. If payment is already due or made, adjust using reason code R2-74-1-GR-53, with Form B2G for non-commercial adjustments. Two conditions apply throughout: no other surtax relief may have been granted on the same good, and you must hold the documentation substantiating the qualifying use.
What if my goods do not fit any remission category?
The Department of Finance runs a separate request framework for exceptional relief, considered where inputs cannot reasonably be sourced domestically or from non-United States suppliers, or in other exceptional circumstances with severe adverse economic impact. The bar is deliberately high. Submissions come from companies registered in Canada and need the eight-digit classification, import volumes and values, sourcing evidence and a competitive impact analysis.
Primary sources: CBSA Customs Notice 25-19: United States Surtax Remission Order (2025), updated 11 September 2026, and CBSA Customs Notice 26-23: United States Surtax Order (2026).
If you import United States-origin goods into Canada and want the remission code applied at accounting rather than reconstructed later, book a consultation and we will review your inbound lines against the categories in Customs Notice 25-19. You can also compare landed cost scenarios first with our ecommerce fulfillment Canada overview.
