The rule is short: refund claims must be made within two years of each importation. Everything that matters about timing falls out of those two words, "each importation". There is no single deadline for "your refund". Every entry carries its own clock, started the day the goods were imported.

Worked examples

  • Imported March 15, 2025 (the first month of the US steel and aluminum surtax under SOR/2025-95): claimable until March 15, 2027.
  • Imported December 26, 2025 (day one of the steel derivative surtax under SOR/2025-267): claimable until December 26, 2027.
  • Imported June 10, 2026 (today, as this page is written): claimable until June 10, 2028.

Now picture a typical importer who has been receiving covered goods weekly since early 2025. Their claimable pool is not one amount with one deadline; it is hundreds of entries on a conveyor belt. Beginning in early 2027, the oldest entries start dropping off the end, and from then on every month of delay permanently expires roughly another month of refunds.

Why "we'll deal with it next quarter" is expensive

Suppose an importer's recoverable surtax averages a steady amount per month of entries. Waiting one quarter to start does nothing to the entries in the middle of the window, but once the conveyor reaches early 2027, those three months of delay translate directly into three months of the oldest, fully-claimable entries expiring unclaimed. The work also takes time: an audit must be done, evidence assembled, and claims filed, with adjustments typically taking two to four months to process. Starting close to the cliff means the clock can run out mid-process.

Does anything stop the clock?

Nothing you should count on. In particular, the surtaxes being lifted in a future trade deal does not extend, pause, or revive the window; past overpayments remain refundable only within two years of each importation, deal or no deal. Our page on whether the surtaxes end soon covers that scenario. The mechanics of actually filing within the window are on the CARM corrections page and the refund guide.

Dates in the examples are calendar arithmetic from the two-year rule, shown for illustration. Your own deadlines come from the import dates on your actual entries.

Common questions

Is the deadline two years from payment or from importation?

From each importation. Each entry has its own two-year clock starting on its import date.

When do the first surtax refunds start expiring?

The earliest surtax entries date from March 2025, so the first claims become unclaimable in early 2027, and another month of entries expires every month after that.