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Country of melt and pour updates for steel imports

Recent updates

November 5, 2024 – Amendments to General Import Permits No. 80 and No. 81 in force 

The regulatory amendments to General Import Permits (GIPs) No. 80 and No. 81 came into force on November 5 and importers are required to report the country of melt and pour (COM) for all applicable steel goods when using the Single Window Integrated Import Declaration (SW IID). The final amendments will be published in the Canada Gazette Part II.

For updated administrative guidance, including information on exemptions for the COM requirement, please refer to the Notice to Importers – Steel General Import Permits No. 80 and 81 – Carbon and Specialty Steel Products – Serial No. 1133.

August 24, 2024 – Consultations on regulatory changes

The proposed regulatory changes to require the provision of COM information were published in the Canada Gazette Part I on August 24, 2024.

Interested parties have until September 23, 2024, to review the proposed regulatory amendments to GIPs No. 80 and No. 81 and submit their comments in the Canada Gazette Part I using the following links:

Global Affairs Canada (GAC) will review and consider the feedback, and the final regulatory changes will be published in the Canada Gazette Part II.

The regulatory changes will come into force on November 5, 2024.

February 21, 2024 – News Release  

The Honourable Mary Ng, Minister of Export Promotion, International Trade and Economic Development announced a two-phased approach to collecting COM information for imports under the Steel Import Monitoring Program.

In phase one, beginning February 21, 2024, steel importers have the option to provide COM information to the Canada Border Services Agency (CBSA) when completing their customs declaration, through the SW IID.

The second phase, beginning November 5, 2024, will introduce regulatory amendments requiring steel importers to report COM data as a condition of using the GIPs No. 80 and 81.

Frequently asked questions

What is country of melt and pour?

Generally, COM is the original location where raw steel is first produced in a steel-making furnace in a liquid state and then poured into its first solid shape. The COM may be different from the country of origin.

Where can country of melt and pour information be found?

COM information may be found in a variety of import documentation, such as:

Importers may also request documentation containing COM information directly from the supplier or manufacturer of the goods. Any documentation containing the heat number or code of the mill that first melted and poured the steel in the imported goods can also be used to determine the COM.

What are the recordkeeping requirements for documents containing country of melt and pour information?

Section 4 of GIP No. 80 and No. 81 has been amended to require importers to retain documentation containing COM information as a term and condition of using the GIPs. Importers must also provide documents confirming the declared COM to GAC upon request for data verification purposes. Further information is available in the Notice to Importers (SER 1133).

Why is Canada collecting and publishing country of melt and pour data?

The collection and publication of COM data is a part of the Government of Canada’s ongoing commitment to increase transparency in the domestic supply chain for steel imports and to provide a more comprehensive picture of the origins of imported steel goods.

What informed Canada’s approach to country of melt and pour collection?

The approach for the collection and future publication of COM data was informed through public consultations. In spring of 2022, stakeholders provided feedback regarding the use and value of COM information, the definition of COM, the method to collect the information, and the overall impact of collecting and publishing the information for importers and the public. Draft regulations were published in late summer 2024 in the Canada Gazette Part I for further stakeholder consultation. Subsequently, the regulations were refined and came into force on November 5, 2024.

How will country of melt and pour information be used?

Following the implementation of the collection of COM information, the data will be analyzed and subsequently, public reports containing aggregate data on COM will be published on the Steel import monitoring reports webpage to increase transparency in the steel supply chain and enable government and external users to identify and track potential trends.

What does it mean that the provision of country of melt and pour data is “optional”?

During the first “optional” phase, beginning February 21, 2024, the provision of COM information was not a requirement to import steel into Canada and importers could choose to provide COM information for their steel imports. The second phase, which began on November 5, 2024, follows regulatory amendments and steel importers are required to report this data to the CBSA when using the SW IID for applicable steel imports as a term and condition of using the GIPs No. 80 and No. 81.

What is the Single Window Integrated Import Declaration?

The CBSA’s SW IID is a release option available to Trade Chain Partners and enables importers and customs brokers to electronically submit their import declarations prior to the arrival of their goods at the Canadian border. This service simplifies the process and reduces the paper burden and cost of doing business. For now, COM information can only be provided by using the SW IID.

What if the incorrect country of melt and pour is declared?

To avoid potential errors, importers and brokers are encouraged to proactively review documents containing COM information and compare the information therein against the COM that is declared in the SW IID, in advance of release. 

If the incorrect COM is declared for a steel commodity, it is possible for importers to make an amendment to the COM field in the SW IID prior to the release of the goods. For more information, please contact the CBSA Border Information Service. If the error is discovered after release of the goods, please contact steel-acier@international.gc.ca.

Will any changes or adjustments be required by importers?

The CBSA has added a field to its SW IID to collect COM information, similar to the field used to provide country of origin data. Specific technical details and requirements related to the COM field are being outlined in direct communications from the CBSA to Trade Chain Partners.

As of November 5, 2024, importers must provide COM information when using the SW IID. Importers must continue to retain and provide, upon request to GAC, documents and records for any applicable steel transaction as part of the terms and conditions of the relevant GIP, including any documentation that was used to determine the COM of the imported steel.

Although the implementation of the conditional rules in the SW IID has been postponed by the CBSA, importers are still expected to comply with the terms of the conditions of the GIPs and provide the COM information for steel goods covered by the GIPs (except for in the circumstances where COM reporting is exempted).

How does the Canada Border Services Agency postponing the deployment of conditional rules to the Single Window Integrated Import Declaration impact the mandatory country of melt and pour reporting requirement?

As outlined in a recent bulletin from the CBSA's Technical Commercial Client Unit, the conditional rules for COM are not expected to be implemented in the SW IID on November 5. The conditional rules would prevent users from submitting their customs declarations without COM information when it is required. However, the COM field has been available on an "optional" basis in the SW IID since February 2024, meaning importers could submit COM information for applicable steel products but were not required to do so to import their goods into Canada. The field will temporarily continue to be in “optional” mode until January 21, 2025.

Notwithstanding the technical delays noted above, importers are required by regulation to provide COM information for non-exempt steel imports, and it is the importer's responsibility to ensure that accurate COM information is provided when using GIP No. 80 or No. 81.

Are there any exemptions for providing country of melt and pour information?

Yes, exemptions are included based on input received from stakeholders. As per the amendments to GIPs No. 80 and No. 81, importers under the CBSA’s Customs-Self Assessment (CSA) Program do not have to provide the COM for steel imports when steel goods are released under paragraph 32(2)(b) of the Customs Act.

Furthermore, the provision of COM information is not mandatory for steel products covered by GIPs No. 80 and No. 81 when the total value does not exceed $5,000 CAD.

Finally, the provision of COM information is not mandatory for certain finished steel products. A description of these products can be found under Section 3.2(b) of the GIPs. The corresponding Harmonized System (HS) classification codes of these products are available in the updated Notice to Importers (SER 1133), and the full list of HS-10 codes exempt from COM reporting can be viewed on the following page: C-8: Carbon steel and specialty steel products exempt from the country of melt and pour reporting requirement.

How will the low-dollar value (less than $5,000 CAD) exemption be calculated?

The total value for duty of all steel products covered under GIPs No. 80 and/or No. 81 that are accounted for under a single declaration must not exceed $5,000 CAD to be exempt from the COM requirement. This does not include the exempted products under Section 3.2(b) of the GIPs as providing COM will not be mandatory for these products. All line items entered in the SW IID which correspond to steel products covered by the steel GIPs that are not exempted will be counted towards the $5,000 CAD limit.

In addition to steel commodities covered by the GIPs, a shipment or transaction accounted under a single declaration may contain other non-steel commodities, exempted steel products, and/or steel commodities that are not covered by the steel GIPs. The value of those goods will not count towards the $5,000 limit.

The following are some scenarios in which providing the COM may be or may not be mandatory based on the values of the commodities accounted for under a single SW IID declaration:

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