RB3 Expiry Review Kicks Off — What Rebar Importers Need to Know Before June

The Clock Started April 20

CITT opened the RB3 expiry review on April 20, 2026. This covers concrete reinforcing bar from Algeria, Egypt, Indonesia, Italy, Malaysia, Singapore, and Vietnam — the same basket that’s been subject to dumping duties since the NQ-2020-004 finding in June 2021. The Tribunal has to decide whether letting those duties expire would likely resume or continue injury to the Canadian industry. Expect the finding by Q2 2027.

If you’ve been importing subject goods from any of these origins, your landed cost structure for the next five years hinges on this review. CBSA will keep collecting SIMA duties through the review period, but if the Tribunal rescinds the finding, you’ll see retroactive refunds. If they extend it, you’re locked in for another five years at current rates — or higher, if CBSA reassesses normal values during the cycle.

What Actually Changes at the Border

Nothing, yet. Your broker still files the CAD with the same SIMA codes, same provisional duties, same release mechanics. If you’re bringing in rebar under 7214.20.00.00 or 7308.40.00.90 from a subject country, CBSA applies the dumping duty at time of accounting. That’s been the case since 2021 and it stays that way through the review.

But two things matter right now: classification certainty and supplier declarations. If you’ve been sloppy about whether your product is actually “concrete reinforcing bar” under the SIMA definition — hot-rolled, deformed, in coils or straight lengths, meeting CSA G30.18 or ASTM A615 — now is a bad time to find out CBSA disagrees. The expiry review will draw attention. Tribunal counsel and domestic producers will be all over import data. If your HS code drifted or your product description on the commercial invoice is vague, expect a compliance verification letter.

Get your classification tight. If you’re borderline on whether your rebar is subject goods, file for an advance ruling now. D11-4-2 rulings take 120 days, but that’s better than a retroactive SIMA assessment two years from now when someone at CBSA Trade Programs finally reads the tribunal record.

Supplier Declarations and Origin Games

SIMA applies to goods originating in or exported from the named countries. That “exported from” part catches a lot of people. If your Vietnamese supplier is actually trans-shipping Indonesian billet, the dumping duty still applies — and CBSA has been very interested in rebar routing since the original investigation. We’ve seen several NRIs in the last 18 months where the importer thought they were clean because the commercial invoice said Vietnam, but the mill test certificate showed an Indonesian heat number.

You need a clean supplier declaration that states country of manufacture, not just country of export. If your supplier won’t give you one, or if the declaration is generic boilerplate, that’s a red flag. The CBSA Form BSF415 is still the cleanest way to document this, even though it’s not mandatory for SIMA. Attach it to your CAD. If CBSA opens a review, you want the paper trail showing you did due diligence at time of import.

One more thing: if you’ve been claiming CUSMA origin to avoid MFN duty and then layering SIMA on top, double-check your math. Rebar from Mexico or the U.S. isn’t subject to RB3, but if you’re importing Mexican rebar made from subject-country billet, you might not have valid CUSMA origin. The steel transformation rules in Chapter 72 are specific. If your supplier can’t prove the billet melted in a CUSMA country, you’re back to MFN duty — and if the billet came from a subject country and got re-melted in Mexico, you’re technically not subject to SIMA, but you lose the CUSMA rate. It’s a mess. Get a ruling.

What Happens If the Finding Gets Rescinded

If CITT decides the domestic industry is no longer at risk, the finding expires and CBSA stops collecting SIMA duties. You file for a refund on everything you paid during the review period — potentially 12 to 18 months of provisional duties. That’s real money if you’re moving volume.

But refunds are not automatic. You need to file a CBSA adjustment request under section 74 of the Customs Act within four years of accounting. If your broker has been filing your CADs with the wrong SIMA transaction codes or didn’t flag subject goods properly, the refund process gets ugly. CBSA will want proof that you actually paid the duties you’re claiming back. If your accounting records don’t tie to your CAD transaction numbers, you’re doing archaeological digs through CARM portal exports and commercial invoices from 2026. Not fun.

If the finding gets extended, you’re paying these duties until at least 2032. Budget accordingly. If you’ve been treating SIMA as a temporary cost, stop. It’s structural now.

The Participation Question

Importers can participate in expiry reviews. You can file submissions, give evidence, cross-examine domestic producers. Most don’t, because the cost of retaining trade counsel and preparing a brief outweighs the benefit unless you’re importing serious tonnage.

But if you’re bringing in more than 500 tonnes a year from subject countries, it’s worth a conversation. The Tribunal’s injury analysis hinges on price suppression and volume effects. If you can show that your imports serve a different market segment — say, small-diameter bar for residential vs large-diameter for infrastructure — or that domestic mills can’t meet your delivery timelines, that’s useful evidence. The deadline for importer submissions is usually 60 days after initiation, so you’re already tight for RB3. Check the CITT website for the procedural schedule.

Practical Steps Before June

Review every rebar shipment you’ve imported since January 2025. Pull the CADs, check the HS codes, verify the origin declarations match the supplier docs. If you spot discrepancies, file voluntary corrections now. CBSA’s penalty calculation under D22-1-1 gives you credit for self-disclosure before they catch it.

If you’re working with a freight forwarder or warehouse provider who handles your customs documentation, make sure they’re flagging SIMA goods correctly. We’ve seen cases where warehouse staff at a Montreal sufferance facility marked goods as non-SIMA on the cargo control document because they didn’t understand the product scope. That flows through to the CAD and you’re stuck fixing it later.

If you’re not confident in your current compliance setup, this is a good checkpoint. SIMA isn’t going away, and the expiry review cycle is predictable. The next one will be 2031. Build the process now.

If you’ve got rebar flowing from any of the seven subject countries and you’re not sure how the expiry review affects your duty exposure, we can walk through your shipment history and spot the gaps. Get in touch.

Source: CSCB