Surtax refunds now accepted in CREDITS — separate batch required

If you’ve been sitting on surtax refund claims waiting for CBSA to accept them through the CREDITS program, you can file now. Customs Notice 25-26 (updated October 1, 2026) confirms that CREDITS participants can submit refund claims where surtax was paid at importation, as long as the claims meet all other program requirements.

The requirement: claims with surtax must go in a separate batch. You can’t bundle them with your regular refund claims.

What this changes

CREDITS — the Casual Refund Electronic Data Interchange Transaction System — has been CBSA’s electronic channel for duty refund and drawback claims for years. It’s faster than paper, tracks better, and integrates with the CARM Statement of Account. But until this update, surtax claims were either excluded or handled case-by-case, which meant most brokers filed them on paper or held them pending clarification.

Now the door is open. If you paid surtax on steel imports under the old Section 53 measures, or on Chinese goods under SIMA, or under any of the other tariff actions CBSA has layered on over the past few years, and you have grounds for a refund (wrong classification, successful appeal, overpayment), you can file through CREDITS.

The separate-batch requirement is administrative overhead, but it’s not surprising. Surtax claims often involve different verification steps: CBSA needs to confirm the tariff action was in force, the goods were subject, the rate applied was correct, and the refund basis is legitimate. Batching them separately keeps that review stream clean.

When surtax refunds are real

Not every surtax payment is wrong, but a lot of importers overpay because the rules changed mid-shipment, or because their broker misread the tariff order, or because CBSA applied a SIMA rate that later got revised down after a CITT review.

Common scenarios we see:

• Goods classified under an HS code that triggered surtax, but the classification was wrong. You win the ruling, the surtax comes off, and you claim back what you paid on the original entries.
• SIMA duty assessed at the interim rate, then the final rate came in lower. The delta is refundable under section 74 of the Customs Act, four-year window.
• Tariff action exclusions that your broker missed at the time of import. A lot of the steel surtax exclusions were product-specific and required documentation CBSA didn’t always ask for up front. If you can prove the goods qualified for exclusion, you can claim the surtax back.

The CREDITS update doesn’t change the substantive refund rules. It just gives you a cleaner filing path.

What the separate batch means in practice

Every CREDITS batch gets a unique ID and goes into the CBSA review queue as a unit. If you mix surtax claims with regular duty overpayment claims, CBSA’s system won’t route them correctly, and the whole batch can get kicked back for re-submission.

Separate batching also means separate timelines. Regular CREDITS claims generally process within 60 to 90 days if the documentation is clean. Surtax claims will likely run longer — CBSA has to verify the underlying tariff action, cross-check the CITT record if it’s a SIMA case, and confirm the refund basis. Expect 90 to 120 days, longer if CBSA sends a request for information.

If you’re filing volume (say, a dozen entries over six months where you overpaid because of a classification error that applied surtax), batch them all together in one surtax-only CREDITS submission. Don’t dribble them out one at a time. CBSA reviews them faster when the fact pattern is consistent across the batch.

Filing discipline matters more now

The CBSA notice doesn’t say this explicitly, but the separate-batch rule is a signal: CBSA expects the claim package to be tight. That means transaction-level backup (the original CAD, the RPP accounting record or Statement of Account line, proof of payment), documentation showing why the surtax shouldn’t have applied (ruling, CITT decision, tariff exclusion certificate), and a clear narrative in the claim file.

We run duty recovery work on volume every quarter, and the difference between a 60-day approval and a 180-day RFI loop is almost always the quality of the initial package. If you’re not sure what CBSA needs to see, ask before you file. A bad CREDITS batch doesn’t just delay your refund, it flags your account for closer review on future claims.

The four-year clock still runs

Section 74 of the Customs Act gives you four years from the accounting date to claim a refund. CREDITS makes filing easier, but it doesn’t extend that window. If you paid surtax in late 2022 and you’re still deciding whether to file, you’re six months from the drop-dead date.

A lot of importers sit on small refund claims because the paperwork feels like more trouble than it’s worth. That math changes when you aggregate. If you overpaid CAD 800 on one entry, maybe you let it go. If you overpaid CAD 800 on fifteen entries because your broker misclassified a product line for eight months, that’s CAD 12,000. File the claim.

What happens next

CBSA will process the claims in the order they come in, same as any other CREDITS batch. You’ll get a confirmation when the batch is accepted, and then silence until the review is done. If CBSA needs more information, you’ll get an RFI through the CARM Client Portal or directly from the CBSA reviewer assigned to the batch.

If the claim is approved, the refund posts to your CARM Statement of Account as a credit. You can apply it against future entries or request a payout. If it’s denied, you get a written decision and the right to appeal, same process as any section 60 review.

Surtax refunds have been in limbo long enough. If you paid surtax in 2022 or 2023 and haven’t filed a claim, you’re running into the four-year section 74 limit. We run these file reviews every week. Get in touch.

Source: CSCB