Canada Section 338: What Changes Sept 15 and Sept 29, 2026
Q: What changes on September 15 and September 29, 2026?
A: On September 15, 2026 at 12:01 a.m. ET the 50% Section 338 list is re-scoped — specialty cheeses, modified fats and oils, bovine hides and upholstery leather, certain furskins, recreational motorboats, specialty paper, some steel and aluminum items, metal fittings and welding inputs, golf carts, furniture and lamps, ATVs and additional dairy go on the list, while rock salt, cement, toilet paper, fishing-rod parts and whiskies, liqueurs and cordials over 4 litres come off. On September 29, 2026 import bans begin on Canadian beer, wines, cider and other fermented drinks, high-proof beverage alcohol, many major spirits categories, non-alcoholic beer, whey and molasses, motorcycles and mopeds over 800 cc, and certain dairy products — under $1 billion in trade value. Covered goods pay the 50% duty regardless of USMCA origin and in addition to Section 232 duties.
Key takeaways
- Two effective dates, not one. Product additions and removals: September 15, 2026, 12:01 a.m. ET. Import bans: September 29, 2026.
- The 50% rate is already live — covered Canadian goods have carried the 50% Section 338 duty since August 22, 2026. Sept 15 is a scope change, not a rate change.
- USMCA origin does not exempt covered goods, and Section 338 duties stack on Section 232 duties.
- Unentered goods keep the 50% rate: goods subject to a ban that were imported but not entered before Sept 29 remain at the Proclamation 11048 rate.
- GSA Multiple Award Schedules are cleared of Canadian-origin products (over $50B in federal procurement) — a procurement consequence that goes beyond duty cost.
- Canada's side is unchanged: the C$27.6B counter-tariff list (629 items, revised Aug 26) has been in force since Sept 8, 2026 and no new Canadian instrument has been issued. Carney said Sept 11 that Ottawa is still studying a response.
- Not in force: the announced 50% U.S. increase on Canadian autos, auto parts and steel from January 1, 2027, and the U.S.-Mexico interim deal being negotiated ahead of the November 3, 2026 midterms.
Timeline: from the July proclamations to the September bans
| Date | What happened |
|---|---|
| Jul 20, 2026 | Proclamations 11046/11047/11048 signed — first use of Section 338: 50% additional duties on ~$20B of Canadian alcohol, dairy and motor-vehicle goods |
| Aug 18, 2026 | Proclamation 11056 temporarily suspends the duties for three days; the suspension expires without a deal |
| Aug 22, 2026, 12:01 a.m. EDT | The 50% Section 338 duty takes effect on covered Canadian goods |
| Aug 26, 2026 | Canada revises its counter-tariff list (874 → 629 items): fish and seafood out; copper wire, wood charcoal, glass containers, printed images and gypsum tiles in at 50% |
| Sept 8, 2026, 12:01 a.m. ET | Canada's C$27.6B counter-tariffs come into force (US-origin goods only; in-transit exempt) |
| Sept 8, 2026 | U.S. response: Section 338 proclamations signed — import bans on named alcohol, dairy and motorcycle/vehicle products, and a re-scope of the 50% list. USTR + GSA directed to remove Canadian-origin products from GSA Multiple Award Schedules |
| Sept 15, 2026, 12:01 a.m. ET | Product additions and removals to the 50% list take effect |
| Sept 29, 2026 | Import bans take effect for the named Canadian products |
September 15, 2026: the 50% Section 338 list is re-scoped
The September 8 proclamations modify the scope of the July 20 Section 338 actions. The motor-vehicle scope proclamation runs the clock explicitly: the changes "shall be effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on September 15, 2026." The fact sheet describes the swap as "removing certain products, such as rock salt and cement, from the scope of the Section 338 tariffs and replacing those products with new ones, ranging from all-terrain vehicles (ATVs) to additional dairy products."
| Change on Sept 15, 2026 | Products (per the White House fact sheet and proclamation reporting) |
|---|---|
| ADDED at 50% | Specialty cheeses; Modified fats and oils; Bovine hides and upholstery leather; Certain raw and dressed furskins; Recreational motorboats; Specialty paper; Some steel and aluminum items; Metal fittings and welding inputs; Golf carts; Furniture and lamps; All-terrain vehicles (ATVs); Additional dairy products |
| REMOVED | Rock salt; Cement; Toilet paper; Fishing-rod parts; Whiskies, liqueurs and cordials in containers over 4 litres |
Two practical notes. First, a removal is relief only for goods entered on or after September 15 — entries dated earlier in September still pay the duty at the rate that applied on the entry date. Second, the additions land in product families importers may not have modelled as "Section 338 goods": metal fittings and welding inputs, golf carts, furniture and lamps, and ATVs sit outside the alcohol/dairy/vehicle framing that dominated July coverage. Model both sides of the date before quoting a landed cost.
September 29, 2026: import bans on Canadian alcohol, dairy and motorcycles
The bans are a different instrument from the duty: instead of paying 50%, the named goods may not be imported at all. The proclamations signed September 8, 2026 cover:
- Beer, wines, cider and other fermented drinks
- High-proof beverage alcohol and many major spirits categories
- Non-alcoholic beer
- Whey products and molasses
- Motorcycles, mopeds and cycles with internal-combustion piston engines over 800 cc
- Certain dairy products
The banned products total less than $1 billion in trade value, a small share of the roughly $20 billion of Canadian goods already carrying the 50% duty. Two details decide how much this costs an importer:
- Unentered inventory keeps the 50% rate. The motor-vehicle ban proclamation states that products subject to the ban "that were imported, but not yet entered for consumption, or withdrawn from warehouse for consumption, prior to September 29, 2026, will remain subject to the 50 percent duty rate established by Proclamation 11048." Goods already in a U.S. warehouse but not entered are not banned — they are dutiable.
- Entry date governs. As with the scope change, the operative date is the entry (or warehouse withdrawal) date on the customs paperwork, not the ship date. A shipment that leaves Canada in September and is entered in October faces the ban, not the duty.
The rules that decide your rate: USMCA origin, and Section 232 stacking
Two sentences in the September 8 White House fact sheet carry most of the practical weight for importers:
- "These Section 338 tariffs apply to all covered goods regardless of whether a good originates under the U.S.-Mexico-Canada Agreement (USMCA)" — a USMCA certificate of origin does not remove a covered good from the 50% duty or from a ban. Section 338 is a discrimination remedy, not a preferential-trade question, so origin-qualification work does not produce relief here.
- "and apply in addition to tariffs imposed under Section 232 of the Trade Expansion Act of 1962" — the duties stack. A covered good that also falls under a Section 232 action pays the Section 232 rate plus 50%. Steel and aluminum articles, which sit under Section 232 measures, are the sharpest example: the Section 338 layer is added on top of the sectoral duty rather than replacing it.
The original July scope excluded energy products, potash, fish, critical minerals and items already under Section 232 from the three Section 338 baskets. The September 8 proclamations re-scope the product lists but do not create a USMCA carve-out.
GSA Multiple Award Schedules: the procurement consequence
Alongside the tariff measures, the President directed USTR and the General Services Administration to "remove Canadian-origin products from GSA's Multiple Award Schedules which manage over $50 billion in federal procurement." AP reported the effect as Canadian products becoming ineligible for large, long-term federal contracts until Canada allows what the President called "full and fair reciprocity" for American products.
For a Canadian exporter this can matter more than the duty: losing Multiple Award Schedule eligibility removes a route to federal buyers that a tariff rate, however high, leaves open. For U.S. buyers using GSA schedules, the practical question is whether a Canadian-origin line item still carries an eligible schedule contract for the period being purchased. Confirm with the contracting officer — the directive is a procurement-eligibility action, and this page does not state its contract-level implementation mechanics.
Canada's side: the C$27.6 billion list is unchanged since September 8
Canada's counter-tariff package took effect at 12:01 a.m. ET on September 8, 2026 and no Canadian instrument has modified it since. The list as revised on August 26, 2026 runs 629 tariff items in three tiers — 413 at 50%, 195 at 25%, 21 at 15% — covering about C$27.6 billion (~US$19.9 billion) of U.S. imports:
- Removed in the Aug 26 revision: fish and seafood (HS Chapter 03) — the entire seafood block came off the list.
- Added in the Aug 26 revision at 50%: copper wire, wood charcoal, glass containers, printed images and gypsum tiles.
- Rules: U.S.-origin goods only (CUSMA marking test), and U.S. goods already in transit to Canada on September 8 are exempt.
- Not covered: U.S. autos and auto parts (separate existing 25% order) and U.S. alcohol (absent from the list).
Carry-forward: the U.S.-Mexico sprint and Ottawa's open decision
Two threads from the September 11, 2026 reporting sit alongside the September 15 ramp:
- U.S.-Mexico interim deal sprint. Reuters reported on September 11, 2026 that Mexico and the United States "are racing to reach a bilateral trade deal before the U.S. midterm elections in less than eight weeks," targeting an interim bilateral bargain giving Mexico relief from some U.S. tariffs in exchange for movement on automotive content and Chinese investment; Mexico's economy ministry said "There are no specific deadlines at this time." One auto-industry source framed the timing as an effort to isolate Ottawa before major new Canadian tariffs take effect on January 1. No U.S. tariff instrument changes on this account — the September 15 and September 29 dates are unaffected.
- Canada has not responded. Prime Minister Mark Carney told reporters on September 11 that Ottawa is "still studying the United States' latest tariffs and import bans as it considers whether to adjust its own retaliatory tariffs," calling the new U.S. measures "relatively modest" compared to earlier moves. Canadian cabinet met in Banff on September 10–11. Until a Canadian instrument is issued, the 629-item list stands as published.
What this is not: dates that are not in force
Coverage of this file routinely collapses announced intentions into current law. Three things are not in force and should not be modelled as current rates:
- The January 1, 2027 increase to 50% on Canadian autos, auto parts and steel. It is a stated intention recorded by the September 2026 C.H. Robinson Edge Report as a threat; no instrument implements it. Model it only as a scenario, never as the default rate.
- A U.S.-Mexico interim bilateral deal. No agreement, no text, no effective date as of September 11, 2026.
- Federal Register publication of the September 8 proclamations. As of September 11, 2026 the newest Canada and Section 338 Presidential Document in the Federal Register is still the August 24, 2026 temporary-suspension notice (FRN 2026-17294). The White House texts govern until publication lands.
FAQ
Q: What changes on September 15, 2026?
A: The scope of the 50% Section 338 tariffs on Canadian goods changes at 12:01 a.m. ET on September 15, 2026. Added: specialty cheeses, modified fats and oils, bovine hides and upholstery leather, certain raw and dressed furskins, recreational motorboats, specialty paper, some steel and aluminum items, metal fittings and welding inputs, golf carts, furniture and lamps, all-terrain vehicles (ATVs) and additional dairy products. Removed: rock salt, cement, toilet paper, fishing-rod parts, and whiskies, liqueurs and cordials in containers over 4 litres. The White House fact sheet states the product additions and removals take effect on September 15, 2026.
Q: What takes effect on September 29, 2026?
A: Import bans. From September 29, 2026, certain Canadian goods may no longer be imported into the United States at all: beer, wines, cider and other fermented drinks, high-proof beverage alcohol, many major spirits categories, non-alcoholic beer, whey products and molasses, motorcycles, mopeds and cycles fitted with internal-combustion piston engines over 800 cubic centimeters, and certain dairy products. The banned products total less than $1 billion in trade value. Goods that were imported but not yet entered for consumption before September 29, 2026 remain subject to the 50% duty rate set by Proclamation 11048 — the ban is not retroactive to unentered inventory.
Q: Does USMCA origin exempt covered goods from Section 338?
A: No. The White House fact sheet states that these Section 338 tariffs apply to all covered goods regardless of whether a good originates under the U.S.-Mexico-Canada Agreement (USMCA). A USMCA certificate of origin does not remove the duty for a covered good.
Q: Do Section 338 duties stack on Section 232 tariffs?
A: Yes. The fact sheet states the Section 338 tariffs apply in addition to tariffs imposed under Section 232 of the Trade Expansion Act of 1962. A covered good that also falls under a Section 232 action pays both, so the combined rate is the Section 232 rate plus the 50% Section 338 duty.
Q: What did the GSA directive do?
A: The President directed USTR and the General Services Administration to remove Canadian-origin products from GSA's Multiple Award Schedules, which the fact sheet says manage over $50 billion in federal procurement. AP reported the effect as Canadian products becoming ineligible for large, long-term federal contracts until Canada allows what the President called full and fair reciprocity.
Q: Did Canada change its counter-tariff list after the September 8 U.S. action?
A: No. Canada's C$27.6 billion counter-tariff package took effect at 12:01 a.m. ET on September 8, 2026 and has not been modified by any instrument since. The list as revised on August 26, 2026 runs 629 tariff items in three tiers (413 at 50%, 195 at 25%, 21 at 15%); fish and seafood were removed and copper wire, wood charcoal, glass containers, printed images and gypsum tiles were added at 50%. The tariffs apply only to US-origin goods, and US goods already in transit to Canada on September 8 are exempt. On September 11, 2026 Prime Minister Mark Carney said Ottawa is still studying the U.S. measures as it considers whether to adjust its own retaliatory tariffs.
Q: Are the September 8 proclamations published in the Federal Register yet?
A: Not as of September 11, 2026. The newest Canada and Section 338 Presidential Document in the Federal Register is still the August 24, 2026 temporary-suspension notice (FRN 2026-17294). The White House presidential-actions index carries the September 8-9 Canada proclamations and is the authoritative text for the September 15 and September 29 effective dates until Federal Register publication lands.
Q: Was the 50% Section 338 duty already in effect before September 15?
A: Yes. The 50% additional duty on covered Canadian goods has been in effect since 12:01 a.m. EDT on August 22, 2026, after the August 18, 2026 temporary suspension expired without a deal. September 15 changes which products are covered, not the rate, and September 29 replaces the duty with a ban for the products named in the ban proclamations.
Q: What are the next hard dates for U.S.-Canada tariffs?
A: September 15, 2026 for the Section 338 scope change and September 29, 2026 for the import bans. Beyond those, the announced increase of U.S. duties on Canadian autos, auto parts and steel to 50% from January 1, 2027 is a stated intention, not law in force; the U.S.-Mexico interim bilateral talks reported on September 11, 2026 target a deal before the November 3, 2026 midterms and are not a U.S. tariff instrument either.
Q: How do importers price a shipment that crosses September 15 or September 29?
A: By entry date. The scope changes apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on September 15, 2026, and the bans apply to goods entered on or after September 29, 2026. Goods subject to a ban that were imported but not yet entered before September 29 remain at the 50 percent rate under Proclamation 11048, so the entry date on the CBP paperwork — not the ship date — decides which rule applies.
Related: Canada 50% Section 338 explainer · Canada Tariff List 2026: counter-tariffs in effect Sept 8 · Canada retaliatory tariffs 2026 · US-Canada tariffs 2026 · Trucking & freight impact · USMCA qualification requirements
Sources (primary first, verified 2026-09-11): White House Fact Sheet: President Donald J. Trump Responds to Canada's Retaliation (Sept 8, 2026) · USTR: Ambassador Greer statement on the response to Canada's continued retaliation (Sept 8, 2026) · Proclamation: Modifying the Scope of Products of Canada (motor vehicles), Sept 8, 2026 · Proclamation: Excluding Certain Canadian Products from Importation (motor vehicles), Sept 8, 2026 · White House Presidential Actions index (checked Sept 11, 2026) · Federal Register API — Canada / Section 338, newest first (checked Sept 11, 2026) · WardsAuto (Sept 9, 2026) · Bloomberg via Business Standard (Sept 9, 2026) · AP via CityNews Toronto (Sept 9, 2026) · Reason / Volokh (Sept 9, 2026) · Reuters: Mexico, Washington sprint toward bilateral trade deal (Sept 11, 2026) · Canada's National Observer: Canada still studying Trump's latest trade attack — Carney (Sept 11, 2026) · C.H. Robinson Edge Report, September 2026 — customs page · Finance Canada — product list subject to counter-tariffs effective Sept 8, 2026 (revised Aug 26). Informational summary, not legal or customs advice — confirm entry treatment with a licensed customs broker.