Let's be straight with you: Canada–China tariffs are one of the most confusing things a Canadian importer has to track in 2026, because the rules have changed four times in the last eighteen months and most of what you read online is already out of date. This guide walks through exactly what's in force right now — the steel and aluminum surtaxes, the EV quota system that replaced the old 100% surtax, the de minimis crackdown, and the CARM changes that made every importer personally liable for duties — so you can price your landed cost correctly and stop guessing at the border.
What is a surtax? A surtax is an extra duty Canada applies on top of the normal Most-Favoured-Nation (MFN) tariff rate, usually as a retaliatory or protective trade measure against a specific country or product category. Unlike a standard customs duty, which is set by tariff classification alone, a surtax is triggered by the country of origin (or, for steel and aluminum, the country where the metal was melted, poured, smelted, or cast) regardless of where the goods were finished or shipped from. Canada's surtaxes on Chinese-origin steel, aluminum, and (until recently) electric vehicles are the clearest example currently affecting Canadian importers.
If you've been importing from China for a few years, you've watched the relationship shift from "complicated but predictable" to "complicated and reactive." Since late 2024, Canada has layered a series of surtaxes onto Chinese-origin goods, largely mirroring — though not identically matching — moves made by the United States. The initial wave targeted electric vehicles and, separately, steel and aluminum. Through 2025, those measures expanded, tightened, and in some cases were partially walked back through remission orders that carve out exceptions for specific goods and importers.
For a Canadian eCommerce seller or SME brand owner, none of this happens in isolation. The Canada Border Services Agency (CBSA) has also overhauled how it verifies country-of-origin claims, ended several transition periods that used to give importers breathing room, and shifted financial liability for duties much more heavily onto the importer of record — meaning you, not your customs broker, are now the one CBSA comes looking for if something's wrong. At the same time, Ottawa's December 2025 "Buy Canadian" procurement policy has changed how Canadian-content requirements factor into anything touching a federal contract, which matters more than people expect if your customers include government buyers.
None of this means sourcing from China stopped making sense in 2026 — for the vast majority of product categories, it still does. But the math changed, the paperwork changed, and the penalty for getting either wrong went up substantially. This guide is meant to get you current, not scare you off.
It's also worth saying plainly: most of what's changed hits a fairly narrow band of product categories hard — steel, aluminum, and their derivatives, plus electric vehicles and adjacent battery-powered goods — while leaving the broader universe of Chinese-sourced consumer products, textiles, plastics, electronics accessories, and home goods largely untouched by these specific surtax measures. If you're importing silicone kitchenware, printed apparel, or injection-molded plastic housings, none of the steel, aluminum, or EV measures below apply to you directly. What has changed for every importer, regardless of product category, is the CARM compliance and liability framework covered in Section 7 — that part applies whether you're shipping raw aluminum extrusions or phone cases.
Read this guide with that distinction in mind: some sections (steel, aluminum, EVs, remission) are relevant only if your product category is exposed; the CARM, de minimis, and landed-cost sections apply to essentially every Canadian importer bringing goods in from China in 2026.
Canadian importers often use "tariff," "surtax," and "duty" interchangeably, and honestly, most of the time it doesn't matter — until it does, usually at the worst possible moment, like when a shipment is held at the Port of Vancouver and your broker is asking which order applies.
A standard customs duty is the baseline rate tied to your product's HS (Harmonized System) tariff classification, looked up through the CBSA Customs Tariff schedule. It applies regardless of where the shipment shipped from, though preferential rates can apply under a trade agreement like CUSMA or CPTPP if your goods qualify by origin.
An anti-dumping or countervailing duty (AD/CVD) is imposed after a formal Canadian International Trade Tribunal (CITT) investigation finds that a foreign producer is selling into Canada below fair market value (dumping) or benefiting from foreign government subsidies (countervailing), and that this is harming a domestic industry. These are product- and even exporter-specific, sometimes running well over 100% of the goods' value, and Canada has an unusually large number of active AD/CVD measures against Chinese-origin goods — everything from certain steel products to fasteners to some furniture components.
A surtax, the newest tool in the box, is a blanket additional duty applied by Order in Council, typically for retaliatory or strategic-industry-protection reasons, without going through the CITT investigation process AD/CVD requires. The China Surtax Order (2024) and the Steel Derivative Goods Surtax Order are both surtaxes in this sense — fast to impose, and just as fast to amend, which is exactly why the rules keep shifting under importers' feet.
To make this concrete: imagine two Canadian importers bringing in nominally similar steel shelving units. One sources from a factory using domestically-melted Vietnamese steel and pays only the standard MFN duty, roughly in the low single digits. The other sources from a factory using Chinese-melted steel routed through the same Vietnamese factory for final assembly, and pays the standard MFN duty plus the 25% China surtax on top, despite both shipments showing "Made in Vietnam" on the commercial invoice. The finished-goods paperwork looks nearly identical; the actual duty bill is dramatically different, and the only thing separating them is a mill certificate neither importer may have thought to ask for. This is why "country of origin" and "country of melt and pour" are not the same question, and why importers who only check the former get caught out.
📌 Note: These three duty types stack. A shipment can be subject to a standard MFN tariff, an anti-dumping duty from an older CITT ruling, and a China-specific surtax all at once. Always ask your broker to confirm the full duty stack for your specific 10-digit HS code — not just the headline surtax rate.
The China Surtax Order (2024) came into effect in October 2024, applying a 25% surtax on steel and aluminum products where the country of melt and pour (steel) or smelt and cast (aluminum) is China — regardless of which country the goods were physically shipped from. This "melt and pour" / "smelt and cast" test matters enormously for Canadian importers who source finished goods from Vietnam, Malaysia, or Mexico that may still contain Chinese-origin raw metal.
Because the surtax created real hardship for importers who had no realistic way to avoid Chinese-origin metal in their supply chain on short notice, CBSA introduced the China Surtax Remission Order, administered through Customs Notice 25-05, which grants relief for specific goods listed in Schedule 1 and Schedule 2. CBSA updated this notice twice in 2026 — first on February 4, then again on March 19 — refining eligibility periods, adding additional steel, aluminum, and select hybrid vehicle products to the schedules, correcting technical errors, and detailing the special authorization codes importers need to cite on their B3 customs coding form to actually claim the remission.
As of the March 2026 update, several Schedule 2 items remain eligible for remission through December 31, 2026 — but this is being reviewed on a rolling basis, and there is no guarantee the relief extends into 2027. If your business relies on remission-eligible goods, treat every quarter as the potential end of that relief, and build your costing models with both scenarios in mind.
💡 Pro Tip: Remission isn't automatic. You (or your broker) have to actively claim it using the correct special authorization code at time of import, and retroactive claims are far harder to process than getting it right the first time. If your product might qualify under Schedule 1 or 2, confirm this with your broker before your next shipment leaves origin — not after it lands in Halifax or Vancouver.
Beyond the original China Surtax Order, Canada layered on the Steel Derivative Goods Surtax Order, effective July 31, 2025, extending 25% surtax coverage to a wider list of downstream steel and aluminum products — not just raw billets and coils, but derivative goods manufactured using Chinese-melted steel or Chinese-cast aluminum as an input.
The proof-of-origin requirements tightened materially in September 2025. Before September 22, 2025, a commercial invoice or supplier report stating the country of melt and pour was generally sufficient. After that date, CBSA stopped accepting standalone commercial invoices and reports as proof — importers now need a proper certificate documenting the country of melt and pour or smelt and cast, typically issued by the mill or smelter itself, not just the trading company or factory that finished the product.
This has real consequences for Canadian brand owners sourcing metal-containing products — appliances, furniture hardware, tools, outdoor equipment, automotive parts — through Chinese factories or trading companies who themselves may not know (or may not want to disclose) where their raw steel or aluminum actually came from.
The chain-of-custody problem compounds when your supply chain has more than one tier. A Canadian importer buying finished patio furniture from a factory in Guangdong may assume that factory's own steel supplier can confirm melt and pour — but that steel supplier may itself be buying coil from a trading company that blends material from multiple mills, some domestic and some imported, without tracking origin lot by lot. Getting a clean, defensible certificate in this situation sometimes means asking your factory to commit to a single, traceable steel or aluminum supplier for your orders specifically, rather than whatever coil happens to be cheapest that week. This is a real conversation to have during supplier negotiation, not an afterthought once a shipment is already at the border.
| Product category | Surtax exposure | Typical proof required |
|---|---|---|
| Raw steel coil / billet (China melt & pour) | 25% | Mill certificate of melt and pour |
| Finished steel goods (e.g. shelving, brackets) | 25% if Chinese steel input | Mill certificate passed through supply chain |
| Raw aluminum extrusion (China smelt & cast) | 25% | Smelter certificate of smelt and cast |
| Finished aluminum goods (e.g. cookware, frames) | 25% if Chinese aluminum input | Traceable smelter documentation |
| Non-China melt/smelt goods, China-assembled | 0% (surtax doesn't apply) | Proof of non-China melt/pour or smelt/cast |
Not sure where to start? Book a free 30-minute consultation with Epic Sourcing's Canadian team → Book a call
Chinese-made electric vehicles carried a blunt 100% surtax from October 2024 through the end of February 2026 — effectively pricing them out of the Canadian market entirely. Effective March 1, 2026, Canada repealed that flat surtax and replaced it with a permit-and-quota system administered jointly with Global Affairs Canada: Chinese EVs can now enter Canada again, but every shipment requires an import permit, and the total annual volume allowed into the country is capped.
For most Epic Sourcing clients this shift is more relevant as a signal than a direct concern — very few Canadian SMEs are importing complete electric vehicles. But it matters if you're in adjacent categories: e-bikes, e-scooters, golf carts, low-speed EVs, and certain battery-electric equipment can get caught up in classification disputes about whether they count as "vehicles" under the relevant Order. If your product has a battery, a motor, and wheels, get your HS classification confirmed in writing by your broker before you assume you're outside the EV measures.
⚠️ Watch out: Permit-and-quota systems tend to reward importers who apply early in the annual cycle and penalize those who wait — once the annual volume cap is reached, later applicants are shut out regardless of how compliant their paperwork is. If your product category could plausibly fall under this measure, don't leave the permit application until your goods are already on the water.
For years, Canada's de minimis framework let low-value shipments — particularly through courier and postal channels — clear customs with minimal formal documentation, which is part of why platforms like Temu, AliExpress, and Shein could ship individual parcels directly to Canadian consumers so cheaply. Through 2025 and into 2026, CBSA tightened this considerably, and the simplified low-value entry processes many importers and platforms relied on are no longer valid in the way they used to be.
In practice, this means a few things for Canadian importers and eCommerce sellers who source in bulk and then ship individual orders to Canadian customers from a Canadian warehouse (rather than drop-shipping direct from China): first, don't assume that splitting a large order into many small parcels still gets you simplified treatment — CBSA is actively watching for exactly this pattern. Second, if any part of your fulfillment model depends on low-value courier entry, get current guidance from your broker or freight forwarder before you build a 2026 pricing model around it, because the thresholds and documentation requirements have shifted more than once in the past twelve months. Third, this shakeup is partly a response to concerns about de minimis being used to route around the steel, aluminum, and EV surtaxes described above — so expect continued scrutiny, not a rollback.
The businesses least affected by this are the ones already importing in bulk under formal commercial entries with a customs broker and a CARM-registered account — which is, not coincidentally, the model Epic Sourcing's Canadian clients typically use through freight forwarding and consolidated ocean or air shipments rather than parcel-by-parcel courier entry.
There's a practical port-level angle here too. Shipments arriving through the Port of Vancouver — still the entry point for the large majority of Canadian ocean freight from China — have seen more intensive CBSA examination activity tied to exactly this de minimis and origin-verification scrutiny, which can mean longer dwell times for containers flagged for inspection. Halifax, as the primary East Coast alternative, has generally seen less congestion pressure but a longer transit time from most Chinese ports, which matters if your business is trying to build slack into a shipping schedule specifically to absorb potential CBSA holds. If your product category carries any steel, aluminum, or origin-verification risk, building an extra one to two weeks of buffer into your shipping timeline for 2026 — regardless of which Canadian port you're routing through — is a reasonable planning assumption, not paranoia.
The CBSA Assessment and Revenue Management (CARM) system finished its transition period at the end of 2025, and the practical effect for every Canadian importer kicked in on January 1, 2026: your customs broker's business number can no longer be used to release or account for your commercial goods with CBSA. You — the importer of record — must register your own CARM Client Portal (CCP) account, and your broker cannot create that account on your behalf. You register yourself, then formally delegate authority to your broker to act for you.
The financial security side matters just as much. Every importer must post their own Release Prior to Payment (RPP) bond — a surety bond covering at least 50% of your peak month's duties and taxes, or a cash deposit covering 100%, with a $5,000 minimum and a $10 million maximum per import program account. CBSA recalculates your required minimum every year on October 20 based on the preceding 12 months of activity, and if your required security increased, you have until January 15 to top it up — a deadline that now recurs annually, not just as a one-time transition requirement.
The transition-period leniency on late payment penalties and interest also ended on January 31, 2026. Overdue balances on your Statement of Account are now subject to real penalties and accruing interest from that point forward, the same as any other CBSA debt.
Picture a typical Epic Sourcing client scenario: a Vancouver-based home goods brand that has been importing through the same customs broker for six years, always assuming the broker's own bond and business number covered their shipments. Under the current model, that assumption is simply no longer true. If that business hasn't personally logged into the CARM Client Portal, registered its own account, delegated authority to its broker, and confirmed its own RPP bond is active and sized correctly for its current volume, its next container can sit at the terminal — accruing storage fees — while the paperwork gets sorted out. This isn't a hypothetical; CBSA has been actively enforcing these requirements since the transition period ended, and "my broker always handled this" is not a defence that holds up anymore.
| Requirement | Old model (pre-2026) | Current model (2026) |
|---|---|---|
| Who's liable for duties/taxes | Broker's BN could be used | Importer of record, personally |
| CARM account setup | Broker could often manage this | Importer must self-register, then delegate to broker |
| Financial security | Broker's bond often covered clients | Importer posts own RPP bond ($5,000 min) |
| Late payment penalties | Transition-period waivers applied | Full penalties and interest apply |
💡 Pro Tip: If you haven't personally logged into the CARM Client Portal and confirmed your own RPP bond status, do it this week — not when your next shipment gets held at the border because your broker's old arrangement no longer covers you.
The Policy on Prioritizing Canadian Suppliers and Canadian Content in Strategic Federal Procurements took effect December 16, 2025. In its current form, it applies most directly to major federal procurements — contracts valued at $25 million and above, expanding to $5 million and above by spring 2026 — and requires that certain materials used in federal contracts, notably steel, aluminum, and wood products, be Canadian-produced. Canadian suppliers also receive a price-based evaluation credit when bidding against foreign competitors.
For most Canadian eCommerce sellers and SME brand owners, this doesn't apply directly — you're not bidding on federal contracts. But it's worth understanding for two reasons. First, if any part of your customer base is a government department, Crown corporation, or a contractor supplying one, Canadian-content rules may start showing up in your own sales conversations even if you're not the prime contractor. Second, it's a directional signal: Ottawa is actively trying to shift demand toward Canadian-made goods and Canadian-melted steel and aluminum, which is the same policy current running underneath the surtax measures in Sections 3 and 4. If your product roadmap has any path toward domestic manufacturing or Canadian-sourced inputs, 2026 is a reasonable time to start exploring it, even if China sourcing remains your primary model for now.
There's also a marketing dimension worth naming honestly. "Buy Canadian" sentiment among Canadian consumers has measurably strengthened alongside these policy changes, and brand owners selling direct-to-consumer are increasingly finding that transparent, accurate labelling — being upfront that a product is manufactured in China but quality-verified and imported by a Canadian company, for instance — lands better with shoppers than it did a few years ago, while overstating "Canadian-made" claims that don't hold up carries real reputational and, in some cases, Competition Bureau risk. If Buy Canadian sentiment is something your brand wants to lean into authentically, that's a positioning conversation, not just a sourcing one — and it's one where accuracy matters more than ever given how much more scrutiny origin claims are getting across the board in 2026.
Not sure where to start? Book a free 30-minute consultation with Epic Sourcing's Canadian team → Book a call
Every conversation about surtaxes eventually turns into a conversation about alternatives, and two trade agreements come up constantly: CUSMA (the Canada-United States-Mexico Agreement) and CPTPP (the Comprehensive and Progressive Agreement for Trans-Pacific Partnership). Neither is a magic fix for China-origin surtax exposure, but both matter for a well-built 2026 sourcing strategy, and it's worth understanding what each actually does.
CUSMA governs preferential tariff treatment between Canada, the United States, and Mexico. For Canadian importers, this matters most when you're considering Mexico as a second country of production for surtax-exposed goods. Mexican-manufactured products that meet CUSMA's rules of origin — which, for many goods, require a minimum percentage of North American content and, for steel and aluminum specifically, increasingly reference the same melt-and-pour and smelt-and-cast logic Canada uses for its China surtax — can qualify for preferential (often duty-free) treatment entering Canada. The catch is that "assembled in Mexico" is not the same as "qualifies under CUSMA rules of origin," and Chinese-melted steel routed through a Mexican finishing plant will still typically fail the origin test and can still attract Canada's China surtax if the CBSA traces it back to Chinese melt and pour. CUSMA rewards genuine regional content, not transshipment.
CPTPP is more relevant for importers considering Vietnam, Malaysia, or other Asia-Pacific CPTPP member countries as an alternative to China for finished goods, particularly apparel, footwear, and certain consumer goods where CPTPP's tariff schedule phases out duties over time for qualifying originating goods. As with CUSMA, qualification depends on genuine rules-of-origin compliance — typically requiring that key manufacturing steps (cutting and sewing for apparel, for example) actually happen in the CPTPP member country, not just final packaging.
The practical takeaway for a Canadian brand owner: if you're evaluating Vietnam, Mexico, or another CPTPP or CUSMA country as a second source specifically to reduce China surtax exposure, get the rules-of-origin qualification confirmed before you commit volume, not after. A factory that says "yes, we can make this in Vietnam" is not the same as a factory that can document CPTPP-qualifying origin — and the difference between those two things is often exactly the difference between a 0% and a 25% landed cost outcome.
Consider a Canadian apparel brand currently sourcing jackets from a Chinese factory that also operates a smaller production line in Vietnam. On paper, shifting the order to the Vietnam line looks like an easy win. In practice, if the fabric is cut in China and only sewn and finished in Vietnam, that may not satisfy CPTPP's rules of origin, which for many textile categories require the cutting step itself to happen within a member country. The brand ends up with goods that look Vietnamese on the label but don't qualify for preferential treatment, and pays standard MFN duty with none of the tariff benefit it was expecting. This is a common and avoidable mistake — one more reason origin qualification needs to be confirmed with documentation, not assumed from a factory's sales pitch.
Almost every surtax dispute, remission claim, and CBSA audit Epic Sourcing has seen a client go through in 2026 traces back to the same root cause: an HS tariff classification that was assumed rather than confirmed. The Harmonized System groups goods into 10-digit codes for Canadian import purposes, and the difference between two plausible-sounding codes for the same product can mean a materially different duty rate, a different surtax exposure, and a different remission eligibility.
The CBSA Customs Tariff tool lets you search classifications yourself, and it's a reasonable starting point — but for anything metal-containing, battery-powered, or otherwise touching an active surtax or AD/CVD measure, self-classification is genuinely risky. CBSA can (and does) reclassify goods after the fact during an audit, and if the correct classification carries a higher duty or surtax rate than the one you used, you're on the hook for the difference plus interest, potentially years after the goods already sold through.
For anything ambiguous or high-volume, a National Customs Ruling (NCR) — a formal, binding classification decision from CBSA — is worth the wait. It takes longer than guessing, but it means CBSA has already agreed with your classification before you place a large order, not after. Epic Sourcing routinely helps clients work through this step during onboarding, particularly for new product categories that haven't been imported into Canada before under the client's business number. Processing times for an NCR request can run several weeks to a few months depending on CBSA's current volume, so this is a step to build into your product launch timeline early, not something to request the week your container is scheduled to leave port.
📌 Note: A product's HS classification is about what the item is, not what it's made of or where it's from — country of origin and country of melt/pour are separate questions layered on top of classification, not substitutes for it. You need both right.
Every one of the measures above ultimately shows up in one place: your landed cost per unit. If you're still pricing products off a simple FOB cost plus a rough duty estimate, you're almost certainly underpricing anything touching steel, aluminum, or a battery-and-motor category, and possibly overpricing categories that qualify for CUSMA or CPTPP preferential treatment you're not claiming.
The table below is an illustrative example only — your actual HS classification, country of melt/pour or smelt/cast, and remission eligibility will change every number here. Always confirm exact rates through the CBSA Customs Tariff tool or your broker before pricing a real order.
| Cost component | Example: steel bracket, China-melted (per unit) | Example: same bracket, Vietnam-melted (per unit) |
|---|---|---|
| FOB unit cost | $4.20 CAD | $4.60 CAD |
| Freight & insurance (allocated) | $0.55 CAD | $0.55 CAD |
| Standard MFN duty (est. 6.5%) | $0.27 CAD | $0.30 CAD |
| China steel surtax (25%, if applicable) | $1.19 CAD | $0 CAD |
| GST (5%, on duty-paid value) | $0.31 CAD | $0.27 CAD |
| Customs brokerage & RPP carrying cost (allocated) | $0.18 CAD | $0.18 CAD |
| Estimated landed cost | $6.70 CAD | $5.90 CAD |
Notice that the Vietnam-melted version has a higher FOB cost but a lower landed cost once the surtax is factored in — a gap that only shows up if you're actually tracking country of melt and pour through your supply chain, not just country of shipment. This is precisely the kind of calculation Epic Sourcing runs for clients through our verification reports before they commit to a factory or a purchase order.
The same logic scales differently depending on category. For a lower-value product like our steel bracket example, a 25% surtax adds roughly a dollar per unit — meaningful, but potentially absorbable depending on your margin. For a higher-value aluminum product, such as a set of cookware retailing at $180 CAD with an FOB cost of $28 CAD per unit, the same 25% surtax on the aluminum content can add $5–7 CAD to landed cost once freight, brokerage, and GST are factored through — a gap that's much harder to quietly absorb across a full product line without either raising retail price or moving volume to a non-China smelter. This is why category-by-category landed cost modelling matters more than a single blanket assumption about "how much the surtax costs us."
Once you know your real landed cost, you generally have three honest options, and most businesses end up using a blend of all three depending on the product line.
Absorb the surtax. For lower-volume or higher-margin categories, sometimes the simplest answer is to eat the extra cost, adjust your retail pricing modestly, and move on. This makes sense when switching suppliers would cost more in requalification, tooling, or quality risk than the surtax itself.
Reclassify or requalify, carefully. Some importers look at their HS classification and wonder if a different (still accurate) classification would reduce exposure. This is legitimate when your product genuinely fits a different code better than the one you've been using — but it is not a workaround for gaming the surtax, and CBSA audits aggressively in exactly this area. Any reclassification should be backed by a proper ruling or your broker's written opinion, not a guess.
Diversify your supply base. This is where most of Epic Sourcing's client conversations land in 2026 — not necessarily leaving China entirely, but adding a second country of melt/pour, smelt/cast, or final assembly for surtax-exposed categories, so you're not fully dependent on Chinese-origin metal for products where that origin is now taxed at 25%. Vietnam, Malaysia, India, and Mexico all come up regularly as alternatives, though each carries its own qualification timeline, MOQ realities, and quality learning curve.
⚠️ Watch out: Diversifying too quickly, without proper factory vetting, is how importers end up trading a 25% surtax problem for a 100% quality-defect problem. If you're moving production to reduce surtax exposure, budget time and money for a proper supplier verification and a pilot order before you commit full volume.
There's a fourth, less obvious option worth naming: renegotiate with your existing factory rather than replace it. Chinese suppliers who understand they're at risk of losing a Canadian account over surtax exposure will sometimes agree to shift final assembly, or even source raw steel or aluminum inputs, from a non-China mill or smelter specifically to preserve the relationship — particularly for higher-volume accounts. This can be faster and lower-risk than qualifying an entirely new factory in a new country, though it depends heavily on your leverage and order volume with that specific supplier. It's a conversation worth having before you assume diversification means starting from zero with a brand-new factory relationship.
These two roles get confused constantly, and in 2026's environment, the distinction matters more than ever. A licensed customs broker handles your CBSA-facing compliance: classification, duty calculation, CARM account delegation, release, and accounting. They are essential, and under the current CARM rules, you legally need one working correctly with your own registered account.
A sourcing agent — what Epic Sourcing does — works upstream of that: finding and vetting factories, negotiating price and MOQ, managing quality control and sample approval, verifying country of melt/pour or smelt/cast at the supplier level before goods ever ship, and structuring your purchase orders and freight forwarding so your broker has clean, accurate documentation to work with at the border. The two roles work best in tandem — your broker can't fix bad documentation your factory never provided, and your sourcing agent can't clear your goods through CBSA. Most surtax-related headaches Canadian importers hit in 2026 trace back to a gap between these two functions: a factory that didn't disclose Chinese-origin steel, or a broker who received documentation too late to claim remission.
Think of it as a relay, not a handoff. The sourcing agent's job ends when goods leave the factory with clean, complete documentation; the broker's job is to translate that documentation into a correct, compliant customs entry. When Canadian importers run into surtax disputes, remission denials, or CARM-related delays, it's rarely because either the broker or the sourcing agent did their individual job poorly — it's because nobody owned the handoff between the two, and information that existed at the factory level (like a mill certificate) never made it into the broker's hands before the goods hit the water. Building a sourcing process where verification happens before shipment, not after arrival, is the single highest-leverage fix available to most Canadian importers in 2026.
This is exactly the gap Epic Sourcing Canada exists to close. Through The Epic Suite, our end-to-end sourcing and project management service, we vet factories on country-of-origin and melt/pour or smelt/cast documentation before you commit to a supplier — not after a shipment gets held at the Port of Vancouver. Our verification reports document exactly what CBSA and your broker will need to support a remission claim or confirm your goods sit outside a given surtax measure. And through Hot Source, our faster-turnaround sourcing service, we can help you pilot an alternative country of production for surtax-exposed categories without the trial-and-error most businesses go through on their own.
If you're not sure whether your current product line is exposed to the steel and aluminum surtax, whether your factory can actually document country of melt and pour, or whether your business should be diversifying part of its supply base in 2026, that's a conversation worth having before your next purchase order — not after.
In practice, this usually starts with a straightforward audit: Epic Sourcing reviews your current product catalogue against HS classification, checks which lines touch steel, aluminum, or battery-electric categories, and flags where your existing supplier documentation is thin or missing entirely. For clients already exposed to the surtax, we then map out realistic alternatives — whether that's negotiating non-China metal sourcing with an existing factory, qualifying a second factory in Vietnam or Mexico, or simply confirming that a remission schedule genuinely covers your product so you're not overpaying duty you don't actually owe. None of this requires you to have a background in trade law or customs classification — that's the point of working with a sourcing partner who does this daily across the Canadian market.
The China-specific surtaxes currently in force are targeted, not blanket. The 25% surtax applies to steel goods where the country of melt and pour is China, and aluminum goods where the country of smelt and cast is China — including many downstream derivative products that use Chinese-origin metal as an input, following the July 2025 Steel Derivative Goods Surtax Order. It is not a general 25% surtax on all Chinese imports. Products outside these categories are still subject to standard MFN tariffs, any applicable anti-dumping or countervailing duties from earlier CITT rulings, and GST — but not this particular surtax. That said, Canada has an unusually broad set of AD/CVD measures against various Chinese-origin goods built up over many years, so "no surtax" doesn't automatically mean "no additional duty." Always confirm your specific 10-digit HS code against current CBSA measures, ideally with a licensed customs broker, before assuming your category is unaffected.
Since September 22, 2025, CBSA no longer accepts a standalone commercial invoice or supplier report as sufficient proof of country of melt and pour (steel) or smelt and cast (aluminum). You need a proper certificate — typically issued by the actual mill or smelter, not just the trading company or factory that finished the goods — documenting where the raw metal was originally melted or smelted. This is often the hardest part of the process for Canadian importers, because many Chinese trading companies and even factories genuinely don't track (or don't want to disclose) their upstream metal sourcing. If you're sourcing metal-containing products, build a request for this documentation into your supplier qualification process from day one, rather than trying to retrieve it after goods have already shipped.
The 100% surtax on Chinese-made EVs, in place from October 2024, was repealed effective March 1, 2026, and replaced with a permit-and-quota system jointly administered with Global Affairs Canada. Chinese EVs can enter the Canadian market again, but each shipment requires an import permit, and there's a capped annual volume allowed nationally. This mainly affects complete vehicle importers, but adjacent categories — e-bikes, e-scooters, certain battery-electric equipment — can get pulled into classification questions about whether they fall under EV-related measures, so confirm your HS classification in writing if your product has a battery and a motor.
The simplified low-value (de minimis) entry processes that many importers and platforms previously relied on have been significantly tightened through 2025 and into 2026, and CBSA is actively scrutinizing shipment-splitting patterns used to route around surtax measures. If your fulfillment model depends on low-value courier or postal entry — rather than formal commercial entry through a broker — get current guidance before building a 2026 pricing or logistics model around assumptions that may no longer hold. Businesses importing in bulk under a CARM-registered commercial account and consolidating shipments through freight forwarding are generally less exposed to this shift than parcel-by-parcel courier importers.
You need to register yourself. Since January 1, 2026, a broker's business number can no longer be used to release or account for your commercial goods, and while your broker can act on your behalf once you've delegated authority to them through the CARM Client Portal, they cannot create your account for you. You also need to post your own Release Prior to Payment (RPP) bond — a surety bond covering at least 50% of your peak month's duties and taxes, or a cash deposit covering 100%, minimum $5,000. If you haven't done this yet, treat it as urgent: goods can be held at the border if your account and security aren't properly in place.
Not necessarily, and not entirely. For most product categories outside steel, aluminum, and EVs, China sourcing remains cost-competitive and the surtax measures simply don't apply. Where they do apply — particularly metal-containing goods — the right move is usually to model your true landed cost including the surtax, compare it honestly against the cost and quality risk of qualifying an alternative country of melt/pour or smelt/cast, and diversify selectively rather than relocating your entire supply chain reactively. Rushed diversification without proper factory vetting is one of the most common ways Canadian importers end up trading a tariff problem for a much more expensive quality problem.
It depends entirely on your product category and whether the alternative country can genuinely qualify under CUSMA (Mexico) or CPTPP (Vietnam and other Asia-Pacific members) rules of origin — not just physically manufacture the goods. Mexico tends to make more sense for steel- and aluminum-heavy products where genuine North American melt-and-pour or smelt-and-cast capacity exists and CUSMA qualification is achievable, plus it offers shorter transit times to Canada than ocean freight from Asia. Vietnam tends to make more sense for apparel, footwear, and certain finished consumer goods where CPTPP tariff phase-outs apply and labor-intensive manufacturing capacity is well established. Neither is a guaranteed win — both require real due diligence on origin qualification, factory capability, and quality consistency — but for surtax-exposed categories specifically, both are worth evaluating rather than dismissing.
Treat it as a serious red flag, not an administrative inconvenience. A factory or trading company that can't or won't document where its raw steel or aluminum was melted or smelted either doesn't have visibility into its own supply chain — which should concern you for quality and consistency reasons well beyond customs — or knows the answer is China and would rather you not find out until after you've committed to the order. Either way, this is exactly the kind of gap a proper supplier verification process is designed to catch before you place a purchase order, not after your broker asks for paperwork that doesn't exist. If a current supplier can't produce this documentation, it's a reasonable trigger to formally evaluate a second source, even if you're not ready to fully switch.
Both the steel and aluminum surtax measures and the CARM liability framework have moved in one direction consistently since 2024 — toward more coverage, tighter documentation standards, and more importer liability, not less. The remission orders show Ottawa is willing to carve out targeted relief where it causes clear economic hardship, but that's relief at the margins, not a signal the underlying surtax regime is going away. CARM, similarly, is a completed systemic overhaul, not a temporary policy — the transition period is over, and there's no indication of a return to the old broker-managed liability model. The safest planning assumption for a Canadian importer in 2026 is that both frameworks are now the baseline, not an emergency measure, and your sourcing, pricing, and compliance processes should be built around that reality rather than around hoping for a rollback.
Whether you're trying to figure out if your product line is exposed to the steel and aluminum surtax or you're ready to pilot a second country of production, Epic Sourcing's Canadian team is here to help.
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This guide reflects Canada–China trade measures, CBSA customs notices, CARM requirements, and federal procurement policy in force as of August 2026. Given how frequently these measures have changed since 2024, always confirm current rates, remission eligibility, and compliance deadlines with your licensed customs broker or directly through CBSA before making a sourcing or pricing decision.
