Steel TRQ Quarter Rollover: File Your Permits Starting June 13

The Steel TRQ Clock Resets June 28

Canada’s tariff-rate quotas for steel goods under the Amended Surtax Order roll into the first quarter of year 2 on June 28, 2026. The quota allocation window opens 15 days earlier: shipment-specific import permit applications covering goods with an expected entry date of June 28 or later can be submitted starting June 13, 2026, at 00:00 a.m. Eastern Time.

If you’re importing steel products subject to the safeguard regime, your broker should already be tracking your quarterly allocation and lining up permit applications for late-June arrivals. The 15-day advance window exists so the permit is in hand before the container crosses the border. CBSA will not release subject goods without a valid import permit tied to the CAD. No permit, no release.

What the Steel TRQ Regime Actually Controls

The steel safeguard measures apply to seven product categories: heavy plate, concrete reinforcing bar, energy tubular products, hot-rolled sheet, pre-painted steel, stainless steel wire, and wire rod. These goods carry a 25% surtax when imported above the in-quota volume. The CBSA administers the TRQ framework through Global Affairs Canada’s import permit system.

Each importer gets a quarterly allocation based on historical import performance and the overall quota pool. If you stay within your allocation, the goods clear at MFN duty rates. Go over, and the surtax applies on the excess volume. The quota year runs in four quarters, and unused allocation does not roll forward. You either use it or lose it.

The quarterly reset matters because it’s the only time you get a fresh allocation. Missing the window at the start of a quarter can mean scrambling to source within-quota steel mid-period or paying the surtax on overage tons. Neither option is cheap.

The 15-Day Advance Filing Window

Global Affairs allows permit applications up to 15 days before the expected date of entry. The expected entry date is the date you reasonably anticipate the goods will arrive at the CBSA port of entry and be reported. It is not the sailing date, the estimated time of arrival at the foreign port, or the date the truck crosses into Canada. It is the date CBSA expects to see a cargo control document with your steel on it.

For ocean freight into Montreal or Vancouver, expected entry usually means the container discharge date plus one or two days for drayage to the sufferance warehouse. For truck freight from the U.S., it’s the date the carrier crosses the border. Your broker should be coordinating with your freight forwarder or drayage provider to pin down that date before submitting the permit application.

The permit application itself requires the importer’s BN15, the HS classification at the ten-digit level, the quantity in kilograms, the country of export, and the FIRMS code for the expected port of entry. If any of those details change after you submit, you may need to cancel and reapply. CBSA does not accept permit amendments on the fly.

Once Global Affairs approves the permit, it gets issued with a unique permit number. That permit number goes on the CAD when your broker files the entry. CBSA’s release system cross-checks the permit number, the quantity, and the HS code. If they don’t align, the entry gets held for manual review, and your release timeline blows out.

What Happens If You Miss the Window

If the goods arrive before the permit is issued, they sit. CBSA will not release subject steel goods without a valid permit on file, even if you have a permit application pending. The container goes to sufferance, and dwell charges start accumulating. Most Montreal-area sufferance warehouses bill around CAD 35 to CAD 50 per day for a standard dry container, and you’re also paying demurrage to the steamship line if the free time expires.

The other risk is quota exhaustion. Steel TRQs are first-come, first-served within each quarter. If you wait until late in Q1 to file your permit applications and the quota pool is already spoken for, your permit gets denied and the goods clear at the surtax rate. For heavy plate or energy tubular products, that 25% surtax can run into five figures on a single container.

We routinely see importers underestimate their quarterly volume and run out of allocation mid-period. The fix is either to source non-subject steel from a CUSMA or CETA origin (Mexico, EU member states) where the safeguard measures don’t apply, or to pay the surtax and eat the cost. Neither is a decision you want to make under time pressure while the container is sitting at the port.

Filing Strategy for the June 28 Transition

If you have steel shipments scheduled to arrive in late June, start the permit application process now. Your broker needs the commercial invoice, the packing list, the HS classification, and the estimated discharge date. Global Affairs typically processes permit applications within a few business days, but there’s no SLA, and we’ve seen applications sit for a week during high-volume periods.

For importers with regular steel programs, the cleanest approach is to batch permit applications at the start of each quarter for your anticipated volume over the next 90 days. You can always cancel unused permits if a shipment gets delayed or canceled. You cannot retroactively permit goods that have already arrived.

The other operational detail: make sure your customs broker has your current TRQ allocation data and is tracking your usage in real time. The CBSA portal shows your quota balance, but it updates on a lag. If you’re filing multiple entries per week, you need an internal tracker so you don’t accidentally over-allocate and trigger a surtax charge you weren’t expecting.

Cross-Border Coordination

Steel TRQ management is one of the areas where broker-forwarder coordination actually matters. The forwarder controls the shipping schedule and knows when the container is getting discharged. The broker controls the permit filing and the CBSA release. If those two timelines don’t sync, the goods sit.

For Montreal inbound, we work directly with sufferance warehouse operators who handle the interim storage and notify us the moment the container is available for exam or release. That visibility cuts a day or two off the release cycle and keeps dwell costs contained. If your current setup doesn’t have that kind of real-time coordination, you’re leaving time and money on the table.

Most CBSA delays on TRQ entries come from permit mismatches or missing documentation, not from exam holds. If the permit, the commercial invoice, and the CAD all tell the same story, the release is usually automatic. If they don’t, the entry gets referred to a trade officer for manual review, and you’re looking at 48 to 72 hours minimum before you get an answer.

What to Do Before June 13

Pull your Q2 steel import data and forecast your Q1 Year 2 volume. If you’re importing heavy plate, rebar, or any of the other six product categories under the safeguard order, you need a permit for every entry starting June 28. Build a 15-day lead time into your shipping schedule so the permit is in hand before the goods arrive.

If you’re not sure whether a particular steel product is subject to the TRQ, check the HS classification against the product descriptions in Notice to Importers Serial No. 1163. The notice lists the specific ten-digit codes and the applicable surtax rates. If your product is on the list, you need a permit. If it’s not, you don’t.

The quarterly rollover is predictable. The permit filing window is generous. The cost of missing it is not. If your late-June shipments don’t have permits lined up yet, that’s the call to make today. Get in touch.

Source: CSCB