As a reminder, the Steel Goods and Aluminum Goods Surtax Order came into effect on July 31, 2025. Importers of subject steel and aluminum goods must provide proof of the country where the goods were melted and poured or smelted and cast.
Effective September 22, 2025
Beginning on this date, commercial invoices alone will no longer be accepted as proof of the country of melt and pour or smelt and cast.
To comply, importers must provide one of the following formal documents issued by the producer at the time of accounting:
Mill Test Certificate (MTC)
Mill Certificate of Origin
Other producer-issued reports or certificates that clearly identify the country of melt and pour or smelt and cast
The CBSA has clarified that distributor-issued statements are not acceptable. Documentation must come directly from the producer and clearly identify both stages of production, which may occur in the same or different countries.
Definition and Proof Requirements:
Steel Goods: Considered to Originate from China if:
Any portion of the raw steel was initially produced and solidified there
If the importer cannot provide proper documentation (e.g., a certificate or report) to prove otherwise, the goods will be deemed to contain Chinese steel and therefore the surtax will be applied
Aluminum Goods: Deemed to be from China if:
The largest or second-largest volume of primary aluminum was produced in China, or
The aluminum was most recently liquified and cast into a solid form in China
Importers must provide evidence (e.g., a certificate or report) showing otherwise. Failure to do so results in the surtax being applied
Background:
The surtax order was introduced in response to U.S. trade measures and applies a 25% surtax on certain steel and aluminum products. Proof of melt and pour or smelt and cast is required to establish traceability and ensure compliance.
Next Steps for Importers:
Confirm with your suppliers that you will receive producer-issued certificates or reports before shipping.
Ensure that these certificates or reports are provided to Omnitrans along with the standard import documentation.
Failure to provide these documents will result in clearance delays, the surtax being applied, and potential penalties to the importer.
For more details, see CBSA Customs Notice 25-28
For a full list of subject tariff items, see Steel Goods and Aluminum Goods Surtax Order