In a recent update to Customs Notice 25-28, the CBSA confirmed that commercial invoices are no longer sufficient proof for exemption from the 25% surtax.
The Canada Border Services Agency (CBSA) has issued a key update to its surtax documentation rules on certain steel and aluminum goods imported after September 22, 2025.
In its latest revision to Customs Notice 25-28, the agency formally ended the temporary acceptance of commercial invoices as proof of melt and pour (for steel) or smelt and cast (for aluminum).
Importers must now provide specific technical certificates to qualify for surtax exemptions under the 25% measure.
The policy stems from the Steel Goods and Aluminum Goods Surtax Order, which targets goods containing steel melted and poured, or aluminum smelted and cast, in China.
This regulation places the burden of proof on the importer. All applicable goods are considered subject to the 25% surtax by default.
The only way to gain an exemption is to provide the CBSA with specific proof that the primary materials originated outside of China.
Starting September 22, 2025, importers may no longer rely on commercial invoices or generic reports alone to be exempt from the steel and aluminum surtax.
According to the notice, the acceptable documentation includes:
These documents must clearly identify the country of melt and pour for steel or the country of smelt and cast for aluminum.
Goods without the appropriate documentation may automatically be subject to the 25% surtax at the time of review.
With the end of the temporary grace period, Canadian importers must now take proactive steps to ensure compliance with the revised surtax documentation rules. These include:
At Cole International, we provide customs and compliance consulting and customs brokerage services to help you navigate changing regulations and streamline the importing of goods into Canada.
If you import steel or aluminum, reach out to one of our trade professionals to ensure your surtax documentation meets the latest CBSA requirements.