US-Canada Tariffs Currently Do Not Apply to MOST Aircraft Parts

The United States has imposed new “section 338” tariffs on products of Canada. These tariffs are currently active. Canada plans to impose reciprocal tariffs that will go into effect on September 8, 2026. Most aircraft parts are outside of the scope of each set of tariffs, but a small minority of aircraft parts may fall within the scope of these two sets of tariffs, so it is important to properly identify your tariff codes and to assess the correct duty rates that apply to them.

The U.S. section 338 tariffs on products of Canada were originally announced in Proclamation 11046, Proclamation 11047, and Proclamation 11048 and then formally announced in the Federal Register. Implementation was delayed until August 19, 2026 and then delayed again for three more days, until August 22.

The good news for the aviation industry is that articles subject to the Agreement on Trade in Civil Aircraft are excluded from this tariff, under operative clause two of each of the three proclamations. This does NOT exempt ALL aircraft parts – aircraft parts that are not protected under the Agreement on Trade in Civil Aircraft (such as fasteners) may be subject to the additional tariffs on products of Canada; if you examine the list of affected products, though, you will see that most aviation articles excluded from the Agreement on Trade in Civil Aircraft are also left off of the list of affected goods (a few things – like textiles, hand tools and certain navigational equipment, may be covered by the Canadian tariffs but outside of the protections of the Agreement on Trade in Civil Aircraft).

Canada has announced its own tariffs on U.S. goods. Most aircraft parts seem to be outside of the scope of the Canadian tariffs, but certain products, like pumps and air conditioning machines, may be subject to the Canadian tariffs. It is therefore important for any Canadian importer to run the tariff codes for their imported U.S. goods through the table of reciprocal Canadian tariff information to ensure you are paying the right tariffs on your imports of U.S. goods.

About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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