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

August 25, 2026 by Leave a comment

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.

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NEW: 50% Tariff on Goods of Canada Will Not Apply to Aircraft Parts

July 20, 2026 by Leave a comment

The United States government has announced a plan to impose a new tariff on goods of Canada. The new tariffs are authorized under Section 338 of the Tariff Act of 1930 (19 U.S.C. § 1338) and will apply a 50% duty to imported goods of Canada based on the value of the import.

TLDR: These new Canadian tariffs will not apply to aircraft parts.

Section 338 is a nearly century-old U.S. trade statute granting the President unilateral authority to impose up to 50% tariffs or completely exclude imports from any foreign country that discriminates against U.S. commerce. The United States has alleged that Canada is discriminating against U.S. alcohol, automobiles and dairy.

The USMCA was specifically supposed to address U.S. concerns over all three of these markets. The USTR published a report addressing the positive effect on automobile trade. Dairy has continued to be a sore subject, with the U.S. winning disputes over the interpretation of the dairy provisions in 2022 and 2023. The US Distilled Spirits Council has complained that “U.S. spirits exports to Canada have plummeted by 85%, dropping below $10 million in the second quarter of 2025, largely due to the majority of Provinces continuing to ban the sale of U.S. spirits.” Many of these bans arose in response to U.S. tariffs and U.S. rhetoric about annexing Canada.

The 50% tariff on Canadian goods is identified under HTSUS 9903.03.14, but that tariff will only apply to a limited set of tariff codes, and most aircraft parts should be outside of the scope of those codes. The language of the note that interprets the new tariff code specifically states that it applies to a list of specific goods “unless they are subject to import restrictions imposed pursuant to section 232 of the Trade Expansion Act of 1962, [e.g. steel and aluminum] as amended (18 U.S.C. 1862), or articles of civil aircraft or aircraft parts that meet the criteria of General Note 6 of the HTSUS.” If you think that your aircraft parts may be within the scope of the 9903.03.14 list of affected tariff codes, then please contact us.

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