RB4 Expiry Review Live — What Changes for Rebar Importers and How to Handle CAD Filings Under SIMA Orders

The Clock Started April 20

CITT initiated the expiry review for hot-rolled deformed steel concrete reinforcing bar originating in or exported from Oman and the Russian Federation. The original finding came down July 2, 2021 in NQ-2020-005. That’s the five-year mark, so we’re now in the standard expiry review cycle under subsection 76.03(1) of SIMA.

CBSA’s parallel investigation is underway to determine whether dumping and subsidization are likely to continue or resume if the finding expires. The full CBSA SIMA page lays out the procedural steps, but the operational reality is simpler: the order stays in force during the review, and if you’re importing subject goods right now, nothing changes until CITT issues a new decision — likely Q2 2027.

What This Means for Your CAD Filings

If you’re bringing in rebar from Oman or Russia, your broker is still coding the CAD with the applicable SIMA case number and you’re still paying provisional duties on top of the normal MFN rate and GST. The SIMA deposit rate depends on the specific exporter — some are named, some fall under the all-others rate. Check the original finding and subsequent normal value reviews. If your supplier isn’t on the exporter list by name, you’re paying the residual rate.

Post-CARM, the SIMA deposit hits your GST account at the time of CAD release just like normal duties. That means your RPP bond math needs to accommodate the combined exposure. We’ve seen importers who sized their bond pre-CARM based on MFN duties alone and then got surprised when the first few rebar shipments pushed them up against their ceiling. If you’re importing subject goods regularly, your bond should cover at least two payment cycles of combined duty and SIMA deposits — three if your pay cycle is monthly and you’re releasing twice a week.

One trap: if you’re filing under release prior to payment, the SIMA deposit is still owing on the original due date. The payment deferral under RPP doesn’t change the fact that CBSA expects the deposit in your account on settlement. Miss that and you’re looking at a penalty that scales with the amount owing and the delay. D17-1-10 is unforgiving on SIMA arrears because CBSA treats them as duties owing, not as contingent amounts.

Expiry Review Process and Importer Participation

CBSA will issue questionnaires to known importers, exporters, and foreign governments. If you’ve been importing rebar from Oman or Russia in the last three years, expect a letter. The questionnaire is detailed — volume, pricing, supplier relationships, market conditions. Responding is voluntary, but if you have a stake in the outcome, participation matters. CBSA’s likelihood determination hinges on actual trade data, and silence from importers tilts the record toward domestic producers and their injury arguments.

The deadline for questionnaire responses is typically 37 days from receipt. That’s tight if you need to pull data from your ERP, reconcile supplier invoicing, and coordinate with your compliance team. Start gathering your records now if you think you’ll participate. CBSA wants transaction-level detail: commercial invoices, supplier pricing history, volume by HS code, country of origin documentation. If your rebar is coming in under multiple suppliers or you’re mixing origins, the data pull gets messy fast.

CITT will hold a hearing sometime in Q1 2027. Domestic producers will argue that expiry would lead to resumed dumping and material injury. Importers and end-users — construction companies, fabricators — can argue the opposite if the data supports it. If you’re a major rebar buyer and the SIMA duties are materially affecting your project costs, consider intervening. Legal counsel for CITT hearings isn’t cheap, but if you’re importing containers every month, the duty exposure over the next five years justifies the spend.

HS Classification and Origin Documentation

Rebar falls under 7214.20.00.00 and 7213.10.00.00 depending on whether it’s in coils or straight lengths. Classification isn’t usually contentious for rebar, but if you’re importing cut-to-length pieces or coated bar, CBSA will look closely at whether the coating or fabrication changes the tariff treatment. The SIMA order is specific to hot-rolled deformed bar, so if your product has epoxy coating or galvanizing, confirm with your broker that the SIMA case number applies. Some coated rebar products fall outside the scope, and filing a CAD with the wrong SIMA flag triggers a correction and potential penalty if CBSA catches it post-release.

Origin matters more than usual here. If your rebar is Russian but shipped through a third country, CBSA will ask for mill certificates and proof of manufacture. If you can’t produce a mill cert showing the melt and roll occurred in Russia, CBSA may apply the SIMA deposit anyway under the all-others rate or open a compliance file. The same goes for Omani rebar transshipped through UAE or other Gulf ports. HS classification mistakes compound the problem if you’re also mis-declaring origin.

One more thing: if you’re importing rebar under CUSMA or another FTA and trying to claim preferential treatment, forget it. SIMA duties apply regardless of FTA origin claims. Preferential duty rates might drop the MFN component, but the SIMA deposit is additive. We’ve had clients assume that CUSMA origin on Mexican rebar would shield them from SIMA, but the order is origin-specific to Oman and Russia — Mexican bar isn’t subject goods, but if your Mexican supplier is sourcing billets from Russia, CBSA will dig into the substantial transformation rules and you could end up with a SIMA liability you didn’t budget for.

Practical Advice for the Next 12 Months

If you’re actively importing rebar from Oman or Russia, treat this year as business as usual but keep your documentation tight. CBSA compliance reviews during an expiry review period tend to focus on subject goods, and if your CAD filings have been sloppy on SIMA coding or your mill certs are missing, expect a request for information. The Montreal and Toronto CBSA trade offices have been particularly active on SIMA compliance in the past six months, and rebar is a high-visibility product because of the domestic industry lobby.

If you’re considering switching suppliers to avoid the SIMA deposit, make sure the new origin is clean and the pricing makes sense post-duty. Turkish and Chinese rebar have their own SIMA orders, so you’re not escaping duty exposure by switching to those origins. Mexican, Brazilian, and U.S. bar are clear, but supply and lead times are different. Run the landed cost model before you commit to a new supplier, and factor in the brokerage and freight cost changes if you’re shifting from container to truck or changing discharge ports.

If your shipments are landing at the Port of Montreal and you’re using a sufferance warehouse for release, make sure your warehouse partner understands the SIMA deposit timing. FENGYE’s Montreal sufferance facility handles a lot of steel product and they’re used to the CARM payment flow, but if you’re working with a smaller warehouse, confirm they’re not holding your goods waiting for deposit confirmation when the CAD has already been paid.

If you’ve got questions about how the expiry review affects your duty exposure or you want a second look at your SIMA coding on past CADs, get in touch. This is the kind of file we work every month.

Source: CSCB