Canada Matches Section 338 Dollar for Dollar: 15%, 25% and 50% Counter-Tariffs on $27.6 Billion of US Goods From 12:01 a.m. September 8, 2026 — US-Marked Origin Is the Trigger, and Goods Already In Transit Are Exempt
After the United States imposed an additional 50% Section 338 duty on Canadian goods on August 22, Prime Minister Mark Carney announced Canada would retaliate dollar for dollar, and on August 25 the Department of Finance published the product list. Effective 12:01 a.m. on September 8, 2026, Canada applies counter-tariffs of 15%, 25% or 50% on US-origin goods, with each product's rate set to match the corresponding US rate on the equivalent Canadian good. The list covers $27.6 billion in imports from the US and is concentrated in steel, dairy, appliances, agricultural equipment, pulp and paper, and electronics. For Amazon sellers this is the mirror image of the Section 338 problem: anything you buy in the US and import into Canada for Amazon.ca — whether that is FBA inventory going into a Canadian fulfillment center or replacement stock for an FBM operation — needs its marking origin checked against the published list before the deadline.
Real-World Impact
At the 25% rate, a $10,000 shipment of US-origin goods entering Canada picks up $2,500 in surtax on top of any ordinary duty and GST. At 50% the same shipment picks up $5,000. On a per-unit basis, a US-origin item with a $20 dutiable value carries $5.00 of surtax at 25% and $10.00 at 50%.
Key Points
- Counter-tariffs take effect at 12:01 a.m. on September 8, 2026 on goods imported into Canada from the United States
- Three rates apply — 15%, 25% and 50% — and the rate for each product is set to match the corresponding US rate on the equivalent good, rather than a single flat retaliation rate
- The product list is drawn from goods targeted by the US Section 338 and Section 232 actions, and covers $27.6 billion in imports from the US. Reuters and CNBC reported the figure as roughly US$20 billion, which is the same trade flow expressed in US dollars
- Finance Canada names steel, dairy, appliances, agricultural equipment, pulp and paper, and electronics as the sectors the list concentrates on
- Origin is determined by marking rules: the surtax applies to goods eligible to be marked as a good of the US under the Determination of Country of Origin for the Purpose of Marking Goods (CUSMA Countries) Regulations. Shipping from a US warehouse is not by itself the test, and CUSMA preference does not exempt a US-origin good from the surtax
- Goods that are in transit to Canada on the day the measures come into force are not covered — the same in-transit carve-out Canada used in its earlier retaliation rounds, and one the US did not offer on August 22
- Canada's existing tariff remission framework stays open to assess requests for exceptional relief, and Ottawa paired the measures with business support through the Canada Strong Diversification Fund administered via the Strategic Response Fund and added flexibilities to the Large Enterprise Tariff Loan facility
- CBSA is expected to publish the administrative detail — surtax order number, HS-level classification and accounting instructions — through its Customs Notices, so the operational rules for brokers land separately from the Finance Canada list
What You Should Do Now
- 1Pull marking origin — not supplier location — for every SKU you import into Canada, then check the eight-digit classification against the Finance Canada list published on August 25 rather than judging by sector name
- 2If you have US-origin inventory you were planning to move into Canada anyway, look hard at whether it can be in transit before 12:01 a.m. on September 8, because the in-transit carve-out is the only timing relief on offer
- 3Re-run landed cost for Amazon.ca on every affected SKU before you reprice. A 15-point swing and a 50-point swing are very different decisions, and the rate is per-product, so do not assume one number across the catalog
- 4Watch the CBSA Customs Notices page for the administrative instructions, and confirm with your broker which surtax order your entries will be accounted under
- 5If a covered input has no practical non-US substitute, review the remission framework — it remains open for exceptional relief requests and is the documented route to an exemption
- 6Check both directions of exposure. Many sellers now have US-origin goods going north under this order and Canadian-origin goods going south under the August 22 Section 338 duty, and the two are separate compliance problems