China Surtax Canada 2026: Is Your HS Code Affected? (Steel 25%, EVs 100%)

A Canadian importer brings in $50,000 of Chinese steel pipe and assumes the duty bill is the standard 6.5% MFN rate ($3,250). They're wrong. The actual stack: 6.5% MFN ($3,250) + 25% surtax under SOR/2024-202 ($12,500) + 5% GST on the whole thing ($3,288). Total at the border: $19,038 — almost 6x the expected duty. If the steel is melt-and-poured in China, SOR/2025-154 adds another 25% on top.

Canadian retaliatory surtaxes on Chinese goods are layered, complex, and easy to underestimate. This guide is the current state in 2026: which orders are in force, which HS codes are covered, how the rates stack, and what to do if your code is on the list.

Active Chinese-origin surtax orders (2026)

These are separate legal instruments enforced by CBSA. They can stack — a single shipment of melt-and-pour Chinese steel can trigger both SOR/2024-202 (25%) and SOR/2025-154 (25%) for a 50% combined surtax burden.

SOR/2024-202: China steel and aluminum 25%

Issued via Order in Council under section 53 of the Customs Tariff. Covers approximately 188 specific 10-digit tariff items in:

• Chapter 72 (iron and steel) — primary forms, semi-finished, flat-rolled, long products
• Chapter 73 (articles of iron or steel) — pipes, tubes, structural shapes, fasteners, fabricated articles
• Chapter 76 (aluminum and articles) — alloys, plates, sheets, foil, bars, rods, structural products

Notably excludes pig iron, ferroalloys (Chapter 72.01-72.02), most aluminum dust and powder, and articles past Chapter 7616.

The scope was revised in March 2025 to add downstream products (Chapter 7229-7326 fasteners and fabricated steel items) that had been initially excluded. If your tariff item is in this range and origin is China, surtax applies regardless of supplier intermediate (US distributor, Mexican manufacturer using Chinese steel, etc.).

SOR/2024-187: China EVs, batteries, solar 100%

Targets emerging clean-tech sectors. Covers:

• Electric vehicles (specific items in heading 8703)
• Hybrid and plug-in hybrid vehicles
• Lithium-ion batteries (Chapter 8507) — specific cell and module items
• Photovoltaic modules and cells (Chapter 8541) — solar panel imports

Removed in 2025: certain motors, motorcycles, and battery components originally on the list. Added in 2025: hybrid vehicle categories. The list has been actively revised — check the current SOR text for your specific item.

SOR/2025-154: Melt-and-pour rules

Different mechanism. Targets steel that's "finished" outside China but contains Chinese-origin melt-and-pour material. The rationale: Chinese steel routed through a third country (Vietnam, Korea, Mexico) for minor processing was avoiding SOR/2024-202.

If the importer can document that the melt-and-pour origin is NOT China — typically via a steel mill certificate from the actual production facility — the order doesn't apply even if the country of finishing is also a CBSA-flagged country. Without that documentation, CBSA can apply the surtax on origin uncertainty.

Combined with SIMA and existing duties

These surtaxes do NOT replace anti-dumping or countervailing duties under SIMA. A single shipment of Chinese aluminum extrusions sees:

• MFN duty: 0% (Chapter 7604)
• SOR/2024-202 surtax: 25%
• SIMA AD: 101% on customs value
• SIMA CVD: 15.84 CNY/kg (specific rate in foreign currency)
• GST: 5% on the whole stack

For a 20-tonne shipment at $50,000 CAD invoice value:

• MFN: $0
• Surtax: $12,500
• SIMA AD: $50,500
• SIMA CVD: 20,000 kg × 15.84 CNY/kg = 316,800 CNY ≈ $61,800 CAD
• Subtotal duties: $124,800
• GST 5% on (VFD + all duties): $8,740
• Total at border: $133,540 on a $50,000 invoice — 267% effective rate.

This is what makes Chinese aluminum extrusion imports economically prohibitive without exporter-specific normal value documentation that lowers SIMA AD.

Order of application

CBSA applies duties in this order:

1. MFN (or applicable preferential rate from a trade agreement)
2. Surtaxes (SOR/2024-202, SOR/2024-187, SOR/2025-154 — all stack)
3. SIMA AD and CVD
4. Excise (if applicable)
5. GST/HST/QST/PST on the cumulative total

This stacking matters for landed cost modeling. See the landed cost guide for the full formula.

How to check if your HS code is affected

Each SOR has a schedule listing the affected 10-digit tariff items. The schedules are published in the Canada Gazette Part II and on laws-lois.justice.gc.ca.

The faster check: enter your HS code in TariffCalc. The calculator flags applicable surtax orders and shows the stacked total in real time.

If you're sourcing via a US distributor and the goods have Chinese origin, see how Section 301 cascades into Canadian landed cost for the supply chain implications.

Common compliance mistakes

1. Assuming country of shipment = country of origin. A Chinese product shipped from a US warehouse retains Chinese origin under CUSMA Chapter 4 and is still subject to Canadian Chinese-origin surtaxes.

2. Missing the melt-and-pour rule. Steel finished in Vietnam from Chinese billets is still subject to SOR/2025-154 unless documented otherwise.

3. Confusing surtax with SIMA. Surtaxes are political (set by Order in Council). SIMA duties are quasi-judicial (set by CITT after dumping investigation). Both can apply to the same product.

4. Not modeling stacked landed cost. A "25% surtax" sounds manageable until you add MFN + SIMA + GST. Always model the full stack before committing to a purchase order.

Tools

• TariffCalc duty calculator — flags applicable Chinese-origin surtaxes by HS code
• HS Code Directory — Canadian classification
• SIMA anti-dumping guide — separate but stackable duties
• Section 301 cascade — when Chinese-origin goods come via US distributors
• Canada Gazette Part II — official source for new SORs

Bottom line

Canadian Chinese-origin surtaxes are stacked, frequent, and economically punitive by design. Three orders in force in 2026 cover steel (25%), aluminum (25%), EVs/batteries/solar (100%), and melt-and-pour rules (25% additional). Combined with SIMA exposure on certain products, the effective rate on Chinese imports can exceed 200% of invoice value. The compliance question isn't whether one of these applies; it's how to document origin so the right combination of orders applies — and to model the stacked landed cost before committing.

For the Canadian retaliation against US tariffs, see US retaliatory surtaxes.