US goods. A new surtax, three rates, three codes.

The United States Surtax Order (2026) came into force on 8 September 2026. It puts a surtax on certain goods that originate in the US, at one of three rates, and each rate has its own code on the Commercial Accounting Declaration. The rate and the code follow the schedule the tariff item is listed in.

Which code goes on the line

CBSA sets the three codes out against the three schedules:

"for goods subject to 15% of the value for duty (items listed in schedule 1), the surtax code is 26186A; for goods subject to 25% of the value for duty (items listed in schedule 2) the surtax code is 26186B; or for goods subject to 50% value for duty (items listed in schedule 3), the surtax code is 26186C."

Which field does it go in

Field 85, and in CARM the importer does the arithmetic:

"The amount of surtax owing is entered in field 85 "Surtax" of the CAD. If importers elect to use the self-declare option in CARM, the amount of surtax owing must be calculated by the importer and entered in the Surtax field."

That is the same field as the steel derivative surtax. Canada's two 2026 safeguards, on canned vegetables and wood cabinets, go in a different one: field 87, not field 85.

Which goods count as US goods

The test is the marking rules, not the CUSMA preference rules:

"The surtax will only apply to goods that originate in the U.S., which shall be considered as those goods eligible to be marked as goods of the U.S. in accordance with the Determination of Country of Origin for the Purpose of Marking Goods (CUSMA Countries) Regulations. The surtax does not apply to goods eligible to be marked as originating from Puerto Rico, Guam, the Northern Mariana Islands, American Samoa or the U.S. Virgin Islands."

And the route the goods took does not change it:

"The surtax will apply to goods imported for commercial and casual purposes, even when exported from a country other than the U.S. into Canada."

Where it meets the steel derivative surtax

A good can be caught by both this Order and the Steel Derivative Goods Surtax Order. CBSA says only one of the two applies:

"Where goods are subject to a surtax under both this Order and the Steel Derivative Goods Surtax Order, only the surtax imposed under this Order applies. The surtaxes from these two Orders are not cumulative."

That rule is written only in the new notice. CBSA's notice for the steel derivative surtax, Customs Notice 25-33, was last modified on 22 July 2026, and its list of surtax orders that take goods out of the steel derivative surtax does not name the 2026 Order. So a line released after 8 September 2026 under 25267A, on US goods that the 2026 Order also covers, was coded to the wrong surtax. More on 25267A: Canadian steel, out of the 25%.

What is outside it

From the notice, the surtax does not apply to:

• US goods in transit to Canada on 8 September 2026, where the importer holds proof such as shipping documents, a bill of lading, report of entry documents or cargo control documents;
• goods classified under Chapters 98 and 99, unless the Chapter 98 or 99 tariff item is listed in Schedule 4 to the Order;
• goods imported under a permit issued for the Import for Re-Export Program;
• returning goods that were already duty paid in Canada, goods repaired or altered across the border, baggage and conveyances temporarily imported by non-residents under 9803.00.00, and eligible ships' stores;
• certain goods brought in for personal use by residents of Campobello Island, New Brunswick.

Low value shipments are not outside it:

"Surtax is applicable on shipments that fall under de minimis thresholds."

Remission, and why the surtax still goes on the CAD

The United States Surtax Remission Order (2025) now reaches the 2026 surtax. CBSA updated its remission notice on 11 September 2026 to name the 2026 Order in each class of relief: public health, public safety and national security, health care, goods used in manufacturing or processing, and the goods listed in the remission Order's schedules.

Relief at import is claimed with a special authorization code, and CBSA is explicit that the surtax is still declared on the same line:

"In respect of commercial goods, to obtain relief of surtax at time of import, the relevant special authorization code is to be entered in the Special Authority OIC field on the CAD. Where remission has been granted, surtax must be declared in addition to the applicable remission."

For goods not covered by that Order, CBSA says requests for remission are assessed under the Department of Finance's remission framework.

Does the surtax change the GST

Yes, and CBSA says so in this notice:

"GST payable is calculated on the value for tax, which is inclusive of surtax even when customs duties are remitted."

So a surtax charged at the wrong rate, or charged when it was not owed, also overstates the GST calculated underneath it. What happens to that GST when the surtax comes back is set out here: the GST on a refund.

If it was declared wrong

"If surtax was not correctly self-assessed or was self-assessed in error for commercial goods, then an adjustment or correction to the CAD, as applicable, may be submitted via the CCP or via EDI/API. [...] An adjustment to a CAD may only be made after the payment due date and within the legislative time frame. Changes required before the payment due date may be submitted as a correction."

The surtax itself is not open to appeal. A re-determination of origin, tariff classification or value for duty is: a request for review under section 60 of the Customs Act goes in within 90 days of the notice of re-determination, after the amounts owed are paid.