CITT Extends Steel Duties: Check Your HS Code Before Your Next CAD

The Canadian International Trade Tribunal just extended anti-dumping and countervailing duties on corrosion-resistant steel sheet from Türkiye and Vietnam for another five years. If you’re importing coated steel coil or sheet under HS 7210.30, 7210.49, 7212.30, or 7212.50, this isn’t background noise — your next CAD needs the right NRM and export price declaration, or you’re going to get a re-determination letter three months later when CBSA runs their first verification pass.

The Finding Stays Live

The expiry review was RR-2025-004. CITT found that letting the original November 2020 finding lapse would likely cause injury again, so the anti-dumping and countervailing duties stay in place. CBSA keeps collecting.

For importers, that means:

• Turkish steel: both anti-dumping and countervailing duties apply
• Vietnamese steel: anti-dumping duties only
• The rates vary by exporter and get updated quarterly in SIMA measure updates

If you’re currently importing subject goods and paying provisional duties on release, those are now locked in for another five years. If you’ve been bringing in steel from a non-subject country and considering a supplier switch to Turkey or Vietnam for better pricing, the duty math just got worse.

Classification Precision Matters More Than You Think

The finding covers corrosion-resistant steel sheet. That’s HS headings 7210 and 7212, but not all goods under those headings are subject goods. The Tribunal’s product definition runs three pages and includes thickness minimums, coating type specifications, and end-use exclusions.

We see importers get this wrong two ways.

Over-declaration: You’re bringing in cold-rolled steel sheet under 7209.18 that happens to have a thin protective oil coating for shipping. Your freight forwarder’s commercial invoice says “corrosion-resistant” because that’s how the mill markets it. You file the CAD under 7210.49 to be safe, pay SIMA duties you don’t owe, and never realize it because the amounts are small enough to disappear into your monthly K84 statement.

Under-declaration: You’re bringing in hot-dip galvanized coil under 7210.49 that clearly falls under the product definition, but your exporter’s commercial invoice describes it as “steel coil” with no coating detail. You file at the six-digit level, CBSA releases it on minimum documentation, and six months later you get a verification request asking for mill certificates and coating specs. If you can’t prove it’s excluded, CBSA re-assesses with interest.

Both scenarios are avoidable. Get the mill certificate. Read the product definition. If you’re not sure, run it past someone who files these every week.

Origin Still Beats Duties

If you’re sourcing coated steel from Turkey or Vietnam specifically because of a free trade agreement, check whether the duties wipe out your tariff savings.

Under CUSMA, Mexican hot-dip galvanized coil enters Canada duty-free if it meets rules of origin. Even with the finding in place, switching from Turkish supply (paying SIMA duties) to a Mexican mill (paying zero) can make sense if the FOB price delta is smaller than the combined anti-dumping and countervailing duty hit.

CETA works the same way for EU supply. Polish or German coated steel enters at zero MFN if properly certified. The brokerage filing is slightly more work because you need a valid CETA origin declaration and proof of direct shipment, but the duty savings on a 40-foot container of subject goods can run into five figures.

We’ve seen importers stick with Turkish suppliers out of inertia even after the finding, because switching suppliers feels like a six-month procurement project. It might be. But if you’re bringing in six containers a quarter and paying an extra $4,000 per container in SIMA duties, that’s $96,000 a year. Most procurement projects pencil out at that number.

RPP Bond Math Changes

If you’re importing subject goods on a Release Prior to Payment arrangement, your CARM financial security calculation just got more complicated. The bond needs to cover worst-case duties and GST on 30 days of imports. SIMA duties are variable and get updated quarterly based on CBSA’s margin reviews, so your peak-month import value times your highest applicable rate is the floor.

We had a client importing Vietnamese coated coil on RPP with a bond sized for MFN duties only. They were fine until a margin review bumped their exporter’s anti-dumping rate from 18% to 34%. Their next month’s K84 statement showed financial security deficiency, and CBSA put a hold on releases until they topped up the bond. That’s a two-week lead time problem when you’ve got production schedules tied to inbound steel.

Size the bond for the high rate, not the average. If your exporter isn’t listed in the SIMA measure and you’re paying the “all others” rate, assume that rate can move. Budget conservatively.

What to Do This Week

If you’re importing corrosion-resistant steel from Türkiye or Vietnam:

1. Pull your last three months of CAD filings and confirm your HS classification matches the product definition in the SIMA measure. If you’ve been declaring at the six-digit level without subheading precision, tighten it up.

2. Check your exporter’s specific rate in the most recent SIMA update. If you’re paying provisional duties at the “all others” rate and your exporter is actually listed with a lower rate, you’re overpaying. If your exporter just got added to the measure at a higher rate, your next shipment’s duty bill is going up.

3. If you’re on RPP, run your bond math against worst-case rates for the next six months of import volume. If you’re close to the edge, top up now rather than mid-month when you’ve got inbound containers.

4. If you’re sourcing from Turkey or Vietnam for reasons other than price, ignore this. If you’re sourcing from Turkey or Vietnam because the landed cost penciled out three years ago, re-run the math with current SIMA rates and compare against CUSMA or CETA alternatives.

Most of this is table stakes customs compliance work. But we still see importers get surprised by SIMA findings that have been live for years, because the commercial invoice says “steel sheet” and nobody read the product definition until the first verification notice landed.

The finding is extended. The duties are staying. If your steel falls under it, file it right the first time.

If you’re not sure whether your coated steel is subject goods, or you want to model out what a supplier switch would actually cost landed in Canada, that’s the kind of call we take every day.

Source: CSCB