U.S. Counter-Tariff Bulletin
Effective September 8, 2026, Canada will impose new counter-tariffs of 15%, 25% and 50% on specified goods originating in the United States. The counter-tariffs will not apply to affected U.S. goods that are in transit to Canada on September 8.
Construction Product Exposure
Products to watch include, but are not limited to:
- 50%: many steel and aluminum products, including structural and fabricated products, pipe and fittings, and fasteners; certain LED lighting; vinyl floor coverings; plywood and laminated veneer lumber (LVL).
- 25%: softwood lumber; most carpet and textile flooring; many powered hand tools and saws; hinges and certain building fittings; iron, steel and aluminum sanitary products; and some heating and air-conditioning equipment.
- Variable rates: selected hand tools and interchangeable tooling are subject to rates ranging from 15% to 50%. Certain HVAC and heat-pump tariff items are subject to rates of 15% or 25%. Some synthetic tufted flooring is subject to the 50% rate.
These descriptions are indicative only. Coverage and rates depend on the product’s exact HS tariff classification and whether it qualifies as originating in the U.S. Click here for the the full product list.
Keep in mind that a U.S. supplier does not necessarily mean U.S. origin, and purchasing through a Canadian distributor does not necessarily mean Canadian origin. The tariff rate will also not necessarily equal a resulting dollar-for-dollar change in purchase price. Project parties should substantiate actual tariff-related cost impacts whenever a tariff is imposed, changed or removed.
Tariff Best Practices Refresher
In June 2025 WCA released a Best Practice Bulletin for reviewing and advancing potential tariff-related claims for price increases. You can find the full bulletin here, or keep reading below for an overview:
- Review contracts for tariff risk allocation. Check the prime contract, subcontracts, purchase orders and supplementary conditions, including taxes-and-duties, change-in-law, escalation, notice and claims provisions. Also review purchasing and shipping terms that assign responsibility for import duties.
- Confirm bid requirements and assumptions. Check for buy-Canadian stipulations or other sourcing requirements and clearly document the tariffs, pricing assumptions and exclusions incorporated into bids and quotations.
- Assess mitigation options. Review alternative products, suppliers and procurement timing, along with any associated cost, schedule or specification implications. Communicate available options to impacted parties promptly so the appropriate project parties can make informed decisions.
- Follow notice and approval requirements. Review the contract and Division 01 requirements for notice periods, supporting information and any required authorization before proceeding with an alternative product or supplier.
- Substantiate cost and schedule impacts. Maintain an itemized record of the original pricing basis, dated quotations and invoices, tariff amounts, origin and classification information, and related freight or other costs. Clearly establish the connection between the tariff and any claimed cost or delay. General or unsupported “tariff surcharges” may not be sufficient.
Many standard CCDC contracts provide for Contract Price adjustments when applicable tariffs change after bid. In an unamended CCDC 2 – 2020 contract, GC 10.1 addresses these adjustments. Under CCDC 5B, before the stipulated-price option is exercised, applicable tariffs are generally included in the reimbursable Cost of the Work. The treatment of tariff increases, decreases or removals remains subject to the specific contract, including any supplementary conditions.
Business and Employee Supports
Federal and provincial resources and support programs are available to businesses and workers affected by the trade dispute. Program eligibility and assistance vary. Additional information can be found at: