December 11th, 2025 – Significant regulatory and trade changes are on the horizon for Canadian importers, including new RPP financial security requirements and major adjustments to steel-related tariffs and quotas. Here’s an overview of what you need to know.
RPP Security Update
The Canada Border Services Agency (CBSA) has announced an important deadline for all importers participating in the Release Prior to Payment (RPP) program:
Action Required by January 15th, 2026
Importers using RPP through the CBSA Assessment and Revenue Management (CARM) system must ensure their posted financial security meets the newly recalculated requirement by January 15th, 2026.
The CBSA has completed its annual review—now conducted in October rather than July—using import activity from October 2024 through October 2025. Any changes to your required security amount will be communicated directly through your CARM Client Portal.
Importers who do not meet the updated (and in many cases, higher) security amount by the deadline risk having their RPP privileges suspended.
Key Changes Affecting Steel Importers
New federal measures taking effect in late December 2025 and January 2026 will significantly impact Canadian businesses importing steel and steel-related products.
- Increased Costs and Tighter Restrictions on Foreign Steel
To encourage demand for domestically produced steel, the government is reducing access to tariff-free imports and imposing new duties on certain products.
Reduced Tariff Rate Quotas (TRQs) – Effective December 26th, 2025
Importers will face sharply reduced tariff-free quotas based on 2024 import volumes:
- Non-FTA Countries: Tariff-free quota reduced from 50% to 20%; over-quota imports subject to a 50% surtax
- FTA Countries (excluding U.S./Mexico): Tariff-free quota reduced from 100% to 75%; over-quota imports subject to a 50% surtax
New 25% Tariff on Steel Derivative Products
Beginning December 26th, 2025, a 25% tariff will apply to a list of steel-intensive derivative products from all countries, including:
- Doors and windows
- Wire, ropes, cables, chains
- Fasteners (nails, screws, etc.)
- Structures such as prefabricated buildings and bridges
These changes will increase costs and require closer monitoring of import volumes and classifications.
- Expiration of Temporary Tariff Relief on U.S. Goods
Importers currently benefiting from temporary counter-tariff remission on U.S. steel must plan for upcoming changes:
- Horizontal Remission Ends January 31st, 2026
Relief will no longer apply to U.S. steel used in manufacturing, processing, food/beverage packaging, or agricultural production. - Relief Continues for Certain Sectors
Tariff exemptions will remain for U.S. steel used in automotive, auto parts, and aerospace manufacturing, as well as for all U.S. aluminum products. - Narrower Relief Framework Going Forward
After January 31st, importers must apply for remission on a case-by-case basis—typically only when domestic sourcing is unavailable.
What This Means for Importers
These combined measures introduce considerable complexity for Canadian importers. Reduced TRQs, new derivative tariffs, and the phase-out of broad U.S. tariff relief will require businesses to:
- Reevaluate supply chain strategies
- Adjust cost and pricing models
- Strengthen compliance and import-monitoring processes
If you have any questions or need further assistance, please contact our Import Compliance team or give us a call at 518-785-6000.
