2026 Canadian Trade & Customs Outlook: Trade Remedies

Why It Matters

The changes raise compliance costs and legal uncertainty for businesses while signaling a more protectionist Canadian market that could reshape supply‑chain strategies and pricing dynamics.

Key Takeaways

• CBSA shifted to annual administrative reviews as default
• Record AD/CVD investigations in 2025, new products added
• Federal budget allocates CAD 617.7M for enforcement
• Expanded subject goods include thermoformed tableware and thermal paper
• Judicial review limited to post‑injury decisions

Pulse Analysis

The Canadian Border Services Agency’s 2024 procedural overhaul, which made annual administrative reviews the default mechanism for updating normal values, export prices and subsidy amounts under the Special Import Measures Act, has reshaped the trade‑remedies landscape. By granting officers broader discretion to initiate reviews, the CBSA can react faster to price fluctuations and market distortions, but it also reduces transparency for businesses that previously relied on the publicly‑available SIMA Handbook. Companies now must monitor written representations and be prepared to submit evidence to influence review outcomes, a shift that adds compliance complexity to supply‑chain planning.

In 2025 the CBSA launched a record‑breaking nine anti‑dumping and countervailing duty investigations, seven of which targeted products never before subject to measures, such as forged grinding media and oil‑and‑gas well casing. The 2026 federal budget earmarks CAD 617.7 million over five years to bolster enforcement, reinforcing protection for the domestic steel sector amid U.S. Section 232‑induced diversion risks. The scope of subject goods continues to widen, now encompassing thermo‑formed molded‑fibre tableware and thermal paper rolls, while existing steel safeguards like tariff‑rate quotas and surtaxes are being fine‑tuned. These developments signal a more aggressive posture that could reshape import volumes and pricing dynamics.

The courts have clarified that judicial review of CBSA decisions is unavailable until a positive injury finding is issued, limiting challenges to pre‑injury administrative reviews. This jurisprudence forces importers and exporters to exhaust the SIMA redetermination and appeal process before seeking tribunal or court relief. Practically, firms should assess exposure to retroactive duties, accrue potential liabilities, and diversify sourcing away from newly listed subject countries. Proactive engagement—such as requesting normal‑value data, filing written representations, and monitoring pending expiry reviews—will mitigate disruption. As trade‑remedy measures expand, strategic risk‑management becomes essential for maintaining supply‑chain resilience in Canada’s increasingly protectionist environment.