Canada bans imports of Russian steel and aluminum (SOR/2023-46, Special Economic Measures (Russia) Regulations, s. 3.14)

Mechanism

Section 3.14(1) makes it an offence to import, purchase or acquire any good in column 1 of Schedule 11 from Russia or from any person in Russia; section 5 (assisting in prohibited activities) was widened to cover sections 3 to 3.14. The regulations apply from registration (2023-03-10), before publication in the Canada Gazette on 2023-03-29. Section 3.14(2) carves out goods contracted for before the coming-into-force date. Enforcement sits with the RCMP and CBSA. The Regulatory Impact Analysis Statement frames the measure as alignment with US and allied action against industries critical to Russia's war in Ukraine.

Severity basis

Severity 2 rests on the RIAS figure: Schedule 11 goods represented C$98.4 million of Canadian imports from Russia in 2022, and the RIAS states that "over the past year, Canadian imports of Russian aluminum and steel products have effectively ceased" following the March 2022 withdrawal of Most-Favoured-Nation tariff treatment for Russia. The ban therefore locks in an already-collapsed trade flow (statutory rather than tariff-based exclusion, covering all of HS 72 and aluminum) rather than cutting a live one.

Downstream implications

• Converts a tariff-driven import stop into a prohibition, removing the option

of re-entry by tariff relief or MFN restoration alone.

• Small direct Canadian trade effect; the value is alignment with the US, UK

and EU steel and aluminum measures against Russian metals.

Open questions

• The Department of Finance release cites different 2022 import figures

(C$45 million aluminum, C$213 million steel) from the RIAS's C$98.4 million for Schedule 11 goods; the two were not reconciled here and the figure recorded in magnitude: is the Gazette's.

• The Finance release does not state an effective date; the Gazette text

(coming into force on registration, 2023-03-10) is used.