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Canada Import Bans and Section 232 Pharma Tariffs: CBP Guidance

Published: September 29, 2026  ·  5 min read
Canada Import Bans and Section 232 Pharma Tariffs: CBP Guidance
Photo: Lipot Repaszky / Pexels

Key Points

On this page

  1. What changed: Canadian product import bans under Proclamations 11061, 11062, and 11063
  2. New ACE and FTZ error codes for restricted Canadian goods
  3. Dates and applicability for Canadian restrictions
  4. Section 232 pharmaceutical tariffs: updated guidance under Proclamation 11020
  5. Interaction with FTZ admissions and warehouse withdrawals
  6. What importers, brokers, and compliance teams should do
  7. Key references

On September 28, 2026, CBP issued three separate guidance messages covering two major trade actions: a set of presidential proclamations excluding certain Canadian products from importation into the United States, and updated implementation guidance for Section 232 tariffs on pharmaceutical articles and ingredients. Importers and brokers with Canadian-origin supply chains or pharmaceutical product lines need to act before the September 29, 2026 effective date for the Canadian restrictions and review current HTS classifications for pharma entries immediately.

The links in this article go to the primary documents: the proclamations, Federal Register notices, and official CBP guidance pages themselves. Read the source.

What changed: Canadian product import bans under Proclamations 11061, 11062, and 11063

CSMS #70050970 provides CBP's guidance on three presidential proclamations that exclude designated Canadian goods from entry into the United States. The proclamations are:

These are import exclusions, not additional tariffs. Designated goods originating from Canada are barred from importation, meaning they cannot be entered for consumption or admitted to a Foreign Trade Zone under the standard admission procedures that would ordinarily apply.

New ACE and FTZ error codes for restricted Canadian goods

To enforce the proclamations in the Automated Commercial Environment, CBP has introduced new system error codes. CSMS #70050117 details these additions:

Filers who receive these new error codes on Canadian-origin shipments should not attempt to re-file without first confirming that the specific HTS classification and product are not within the scope of the proclamations. The error codes are not system glitches; they are enforcement mechanisms.

Dates and applicability for Canadian restrictions

The restrictions apply to goods originating from Canada that are:

on or after 12:01 a.m. Eastern Time on September 29, 2026. Goods already in a bonded warehouse that have not yet been withdrawn are caught by this date as well. The proclamations cover specific products under designated Harmonized Tariff Schedule provisions; consult CSMS #70050970 and the proclamations themselves for the precise HTS coverage.

Section 232 pharmaceutical tariffs: updated guidance under Proclamation 11020

CSMS #70054007 provides updated implementation guidance for Proclamation 11020, "Adjusting Imports of Pharmaceuticals and Pharmaceutical Ingredients Into the United States," dated April 2, 2026. The update incorporates a September 23, 2026 Federal Register notice that covers two matters:

Section 232 duties on pharmaceuticals apply in addition to any other applicable duties. Misclassification or failure to apply the correct Section 232 rate will result in underpayment of duties, creating potential penalty exposure and the need for post-entry corrections or protests.

Interaction with FTZ admissions and warehouse withdrawals

Both actions intersect with FTZ and bonded warehouse operations in important ways. For Canadian goods, the prohibition applies on withdrawal from warehouse for consumption as of September 29, 2026, meaning goods already bonded are not grandfathered. For pharmaceutical articles subject to Section 232, FTZ operators and importers should confirm that the updated HTS classifications and duty rates in the September 23 Federal Register notice are reflected in their admission and entry documentation going forward.

What importers, brokers, and compliance teams should do

Key references


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About the Author

Franz Brotzen, CustomsGenius CEO & Founder. Franz is a published researcher on U.S. trade policy. He has worked at think tanks in Washington DC and Tokyo, where his academic publications focussed on tariffs and legal compliance. Franz received his JD from Harvard Law School.

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