Before the worldwide derivative surtax, there was the US one. Since March 2025, Canada has applied a 25% surtax to US-origin steel and aluminum under the United States Surtax Order (Steel and Aluminum 2025) (SOR/2025-95). If you have been importing American steel or aluminum products for the past year and a bit, this surtax has been on your entries the whole time.
The relief: SOR/2025-122
The government followed the surtax with the United States Surtax Remission Order (2025) (SOR/2025-122), which relieves qualifying goods from the surtax. As with the steel derivative remission order, the relief is real law but entirely claim-driven: future entries receive it through a special authority code on the CAD, and past entries receive it through corrections that refund what was overpaid. The Department of Finance remission process remains available for goods no existing order reaches.
Why these refunds are the most urgent on the board
Refund claims must be made within two years of each importation, and the US surtax is the oldest of the steel measures. Entries from March 2025 become unclaimable in March 2027; the conveyor of expiries starts there and never stops. An importer of US steel who waits a year to look at this will have lost the entire first year of claims, permanently, regardless of how strong they were. The arithmetic, with worked examples, is on the two-year window page.
What about a trade deal?
US-Canada trade measures are political weather; they can change. Two facts hold either way. If the surtax is lifted, past overpayments remain refundable within the two-year window; a deal stops future surtax, it does not return what you already paid. And if the surtax stays, the entries keep accumulating and the oldest keep expiring. In both futures, the recoverable money is the same money, and the deadline is the same deadline. Our page on whether the surtaxes end soon goes deeper.
How recovery proceeds
The same way as for derivative goods: an audit of your CARM entries identifies surtax-paying lines that qualify under SOR/2025-122, drawback, or another route (the comparison is here); corrections and claims are filed by licensed customs brokers; refunds post to your CBSA account, applied first against anything you owe.
Whether specific goods qualify under SOR/2025-122 depends on the order's terms applied to your actual entries. Both orders above link to their official Justice Laws texts.
Common questions
Is SOR/2025-122 the surtax or the refund?
The refund side. The surtax on US-origin steel and aluminum is SOR/2025-95, in force since March 2025. SOR/2025-122 is the remission order that relieves qualifying goods from it.
When do US surtax refunds start expiring?
The first US steel and aluminum surtax entries date from March 2025, so claims on them expire from March 2027, one month of entries at a time.