GAC Steel Monitoring COM Code Exclusions Just Changed for 2026 — Check Your CAD Logic Now

The Change

Global Affairs Canada quietly revised the HS code exclusion list for the Steel Monitoring Program’s Country of Melt and Pour (COM) requirement, effective April 23, 2026. HS 7308.90.00.60 — bridge sections and tower/lattice mast sections, previously excluded — is off the exclusion list because the tariff line no longer exists after the 2026 Customs Tariff update. In its place, GAC added new successor codes that inherit the exclusion.

If you’re filing Integrated Import Declarations (IIDs) via EDI and your broker or internal team built CAD logic based on last year’s steel monitoring rules, you’ve got two weeks to update templates. If you don’t, you’ll be triggering conditional COM data requirements on goods that should pass clean, or worse, filing incomplete declarations on goods that now do need COM and getting flagged for missing PGA data.

What This Actually Means for Your CAD Filings

The Steel Monitoring Program under Global Affairs Canada requires importers to report COM when importing certain steel products. The conditional logic is simple: if your HS code is on the exclusion list, you don’t file COM data even if the good is steel. If it’s not on the list and it’s a monitored product, COM is mandatory.

The problem is that most brokers and in-house teams hard-coded the exclusion list into their CAD templates or their broker’s EDI mapping when the program went live in January 2025. HS 7308.90.00.60 was on that list. Now it’s not — because the code itself is gone. The 2026 Customs Tariff restructured Chapter 73, and a handful of lines shifted or split. GAC’s update reflects those shifts, but your CAD logic doesn’t know that unless someone manually updates the table.

If you’re still auto-excluding 7308.90.00.60, CBSA won’t reject the transmission — the code is invalid, so it won’t even match. You’ll either default to a parent code (7308.90.00.00) that is monitored, or you’ll mis-declare and get caught in a post-release verification. Either way, you’re now filing wrong.

The Real Risk: PGA Holds and Late Adjustments

GAC steel monitoring isn’t SIMA. There’s no provisional duty, no subject goods determination, no CBSA reference number. It’s a data collection exercise. But it’s still a Participating Government Agency requirement, and under CARM, incomplete PGA data means your CAD can be held at the border until corrected. If your shipment is time-sensitive and your broker has to resubmit the CAD with COM data you thought was optional, you’re looking at a minimum 24-hour delay while the correction cycles through the Single Window.

Worse, if the declaration is accepted but later audited, you’re explaining to CBSA why you omitted mandatory data. It’s not a SIMA penalty, but it’s still a compliance file you don’t want open.

The flip side is just as annoying: if you’re filing COM data on goods that are now properly excluded under the new codes, you’re doing extra work for no reason and risking data validation errors if your COM fields don’t match CBSA’s country tables. We’ve already seen CADs rejected because someone reported “China” when the system expected “CHN” or because they populated COM on an excluded code and CBSA’s validation logic flagged it as extraneous.

What to Do This Week

If you’re working with a broker, ask them directly: did they update their steel monitoring exclusion table for the 2026 Customs Tariff? If they say “what table,” you have a problem. If they say “we updated it in February,” you’re probably fine, but spot-check a recent steel entry just to confirm.

If you’re filing your own CADs in-house, pull the updated exclusion list from the CSCB bulletin or request it from CBSA. Cross-reference it against your EDI mapping or your CAD template logic. If you’re importing anything in Chapter 73, this matters. The most common traps are going to be structural steel (73.08), tubes and pipes (73.04–73.06), and wire products (73.12). Those chapters saw the most line-level changes in 2026.

If you’re using a third-party compliance tool or trade management system that auto-populates PGA data, log in and check the steel monitoring rule tables. A lot of these platforms don’t auto-update when GAC or CBSA changes exclusion lists — they wait for the vendor’s next release cycle, which could be months out. If your platform still shows 7308.90.00.60 as excluded, flag it with your vendor now and override manually in the meantime.

Why This Keeps Happening

CBSA and GAC operate on different schedules. Customs Tariff updates happen annually, usually around January or April. PGA program rules, like steel monitoring or CFIA manifesting requirements, update when the agency decides. The two don’t always sync. When a tariff code splits or merges, someone at GAC has to manually update the program logic, and that update doesn’t always land before the tariff change goes live.

The January 2025 steel monitoring rollout was relatively clean because GAC built the exclusion list against the 2025 Customs Tariff. But 2026’s tariff restructuring in Chapter 73 happened after the program was already in production, so GAC had to issue a mid-year correction. This is the second time in 18 months we’ve seen a PGA program lag behind a tariff update. It won’t be the last.

If you’re managing trade compliance in-house, this is exactly the kind of thing that falls through the cracks unless someone is actively monitoring CBSA and GAC bulletins every week. Most supply chain teams don’t have the bandwidth, which is why missed PGA updates are one of the top causes of post-release CBSA requests for information.

One More Thing: HS Classification Pressure

If you’re still treating HS classification as a one-and-done exercise, this is your reminder that it’s not. Every time the Customs Tariff updates, you need to re-validate your top 20% of SKUs by import value. A code that was valid in 2025 might not exist in 2026, or it might have split into two new codes with different duty rates, different PGA requirements, or different CUSMA rules of origin.

We’ve already had two clients this quarter discover they were filing against deprecated codes because their ERP system wasn’t updated after the January tariff refresh. CBSA doesn’t bounce the CAD — it just defaults to the parent code, which could have a higher duty rate or trigger monitoring you didn’t expect. You don’t find out until the assessment posts and you’re over budget.

If you want a second set of eyes on your steel monitoring logic or your post-tariff HS validation, we do that kind of review every week. Get in touch.

Source: CSCB