New Section 338 import bans and tariff scope changes on Canadian goods, effective mid/late September 2026.

1. What changed

The President signed five Proclamations under Section 338 of the Tariff Act of 1930 targeting imports from Canada. These actions:

• Impose new import bans on certain Canadian alcoholic beverages, dairy, and other products that were previously subject to 50% Section 338 tariffs under Proclamations 11046 and 11047.
• Modify the July 20, 2026 Section 338 tariff actions by removing some Canadian products (including rock salt and cement) from the tariff list and adding new products (including all-terrain vehicles (ATVs) and additional dairy products).
• Clarify that Section 338 tariffs apply to all covered Canadian-origin goods regardless of USMCA originating status and are in addition to any Section 232 tariffs.

2. Affected products

The fact sheet provides product categories but not specific HTS codes. Affected categories include:

• Newly banned imports from Canada:
• Certain alcoholic beverages of Canadian origin that were previously subject to 50% tariffs under Section 338 in Proclamation 11046.
• Certain dairy and other Canadian products that were previously subject to 50% tariffs under Section 338 in Proclamation 11047.
• Products removed from the July 20, 2026 Section 338 tariff list:
• Rock salt of Canadian origin.
• Cement of Canadian origin.
• Products newly added to the July 20, 2026 Section 338 tariff list:
• All-terrain vehicles (ATVs) of Canadian origin.
• Additional dairy products of Canadian origin.

Because the fact sheet does not list HTS numbers, importers must consult the actual Proclamations and any accompanying annexes to identify the precise HTS subheadings and product descriptions.

3. Rate changes

• Products subject to new import bans:
• Previously: Subject to 50% ad valorem tariffs under Section 338 (per Proclamations 11046 and 11047).
• Now: Importation into the United States is prohibited (effective ban; duty rate becomes irrelevant because entry is not permitted).

• Products removed from the Section 338 tariff list (e.g., rock salt, cement):
• Previously: Subject to Section 338 tariffs (fact sheet references 50% tariffs for the earlier lists; specific rates must be confirmed in the Proclamations).
• Now: No longer subject to Section 338 tariffs as of the effective date of removal. Any other applicable duties (MFN, Section 232, ADD/CVD, etc.) still apply.

• Products newly added to the Section 338 tariff list (e.g., ATVs, additional dairy products):
• Previously: Subject only to normal MFN rates and any other applicable measures (e.g., Section 232, ADD/CVD) but not Section 338 tariffs.
• Now: Subject to Section 338 tariffs (the fact sheet references 50% tariffs for the earlier Section 338 actions; importers must confirm the exact ad valorem rate and any Chapter 99 provisions in the Proclamations).

• Relationship to other measures:
• Section 338 tariffs apply in addition to any Section 232 tariffs on the same goods.
• Section 338 measures apply regardless of whether the goods qualify as originating under USMCA.

4. Dates

• July 20, 2026: Original Section 338 tariff actions on certain Canadian products were announced.
• September 15, 2026: Effective date for product additions and removals from the July 20, 2026 Section 338 tariff list.
• From this date, rock salt and cement are removed from the Section 338 list.
• From this date, ATVs and additional dairy products are added to the Section 338 list and become subject to the applicable Section 338 tariffs.
• September 29, 2026: Effective date for new import bans on certain Canadian alcoholic beverages, dairy, and other products previously subject to 50% Section 338 tariffs under Proclamations 11046 and 11047.

Importers should verify whether the Proclamations include any special transition rules (e.g., goods exported before a certain date, goods in transit, or entries under warehouse/bond) and adjust entry timing accordingly.

5. Required actions for importers, brokers, and compliance teams

a) Identify exposure to Canadian-origin products

• Review all current and planned imports from Canada, focusing on:
• Alcoholic beverages.
• Dairy products and dairy-containing goods.
• Rock salt and cement.
• All-terrain vehicles (ATVs) and related vehicles.
• Map these products to their HTS classifications and confirm whether they appear in the annexes to the new Section 338 Proclamations and the July 20, 2026 action.

b) Determine whether products are now banned or newly tariffed

• For products previously subject to 50% Section 338 tariffs under Proclamations 11046 and 11047:
• Check whether they are now listed as subject to an import ban effective September 29, 2026.
• If banned, plan to cease importation from Canada by that date and identify alternative sourcing.

• For rock salt and cement imported from Canada:
• Confirm that the specific HTS lines used for your products are among those removed from the Section 338 list effective September 15, 2026.
• Adjust landed cost models to reflect removal of Section 338 tariffs while maintaining any other applicable duties (MFN, Section 232, ADD/CVD).

• For ATVs and additional dairy products imported from Canada:
• Confirm whether your HTS lines are included in the new Section 338 list effective September 15, 2026.
• Update landed cost calculations to include the applicable Section 338 tariff (likely 50% ad valorem, subject to confirmation in the Proclamations) in addition to MFN and any Section 232 or other duties.

c) Update classification and entry processes

• Ensure brokers and internal customs teams:
• Have the latest HTS and Chapter 99 references from the Proclamations.
• Apply any new Chapter 99 numbers or special program indicators associated with the Section 338 measures.
• Correctly declare Section 338 duties in addition to Section 232 and other applicable duties.

• For banned products:
• Stop filing entries for covered Canadian-origin goods on or after September 29, 2026.
• Review any in-bond, FTZ, or warehouse inventory to determine whether goods can be exported or otherwise handled in compliance with the ban.

d) Contracting, sourcing, and pricing

• Review supply contracts with Canadian suppliers of:
• Alcoholic beverages and dairy products.
• ATVs and related vehicles.
• Rock salt and cement.
• For banned items:
• Negotiate termination or modification of contracts and identify alternative non-Canadian sources.
• For newly tariffed items:
• Renegotiate pricing or cost-sharing arrangements to account for Section 338 tariffs.
• Consider shifting production or sourcing to non-Canadian locations where feasible.

• Update customer pricing and quotations to reflect higher landed costs for newly tariffed products and lower costs for products removed from the Section 338 list.

e) Compliance controls and monitoring

• Implement controls to prevent inadvertent importation of banned Canadian products after September 29, 2026.
• Set up monitoring for further changes to Section 338 measures, as the Administration may continue to adjust product coverage in response to Canadian actions.
• Coordinate with trade counsel to:
• Interpret the scope of the bans and tariffs.
• Assess any potential for exclusions, waivers, or litigation.

f) Government procurement implications

• The President has directed USTR and GSA to remove $50 billion of Canadian-origin products from GSA Multiple Award Schedules.
• Vendors supplying the U.S. Government via GSA Schedules should:
• Review their product offerings for Canadian-origin content.
• Anticipate potential removal of certain Canadian-origin items from GSA contracts.
• Adjust sourcing and origin strategies to maintain eligibility for federal procurement.

6. References

Importers and brokers must consult the primary legal documents for precise HTS coverage, rates, and any Chapter 99 provisions:

• New Section 338 Proclamations (five proclamations signed September 8, 2026):
• These will be published in the Federal Register and on the White House and USTR websites. Search by date and "Section 338" and "Canada" for the full text and annexes.
• Proclamation 11046: Prior Section 338 action imposing 50% tariffs on certain Canadian alcoholic beverages and other products.
• Proclamation 11047: Prior Section 338 action imposing 50% tariffs on certain Canadian dairy and other products.
• July 20, 2026 Section 338 action: Original list of Canadian products subject to Section 338 tariffs, now being modified.

Representative starting points (URLs subject to change; users should navigate to the latest versions):

• White House fact sheets and proclamations: https://www.whitehouse.gov/briefing-room/
• Federal Register (search by proclamation number and date): https://www.federalregister.gov/
• USTR announcements: https://ustr.gov/

7. HTS metadata

The fact sheet does not provide explicit HTS headings or subheadings. All HTS analysis must therefore be based on the annexes to the Proclamations and any subsequent CBP guidance. Until those are reviewed, importers should:

• Flag all Canadian-origin alcoholic beverages, dairy products, ATVs, rock salt, and cement for detailed HTS review.
• Cross-check their internal HTS assignments against the official lists once published.

Because no specific HTS codes are stated in the source text, the hts_codes array for this briefing remains empty and must be populated later based on the official annexes and CBP implementation instructions.