Small Power Transformer SIMA Duties Enter Expiry Review: What Importers Need to Know

What changed

On October 2, 2026, the Canada Border Services Agency (CBSA) initiated an expiry review investigation covering certain small power transformers from Chinese Taipei and South Korea. The review follows the Canadian International Trade Tribunal’s October 1 decision to examine whether its December 24, 2021 injury finding should remain in force.

This does not remove the existing anti-dumping measure. Importers should continue treating subject goods as covered by the Special Import Measures Act (SIMA) while the expiry review is underway.

The CBSA’s task is to determine whether allowing the finding to expire would likely result in the continuation or resumption of dumping. The agency says it will make that determination no later than February 26, 2027, with its Statement of Reasons due by March 12, 2027.

For importers sourcing transformers from Chinese Taipei or South Korea, the immediate message is straightforward: the review creates a future decision point, but current SIMA exposure remains in place.

Which transformers are covered

The current measure applies to certain liquid dielectric power transformers with:

• a top power handling capacity of at least 3,000 kVA (3 MVA) but less than 60,000 kVA (60 MVA); and
• a nominal high-voltage rating greater than 34.5 kV.

The scope includes transformers that are assembled or unassembled, complete or incomplete, when they originate in or are exported from Chinese Taipei or South Korea and meet the full product definition.

CBSA currently lists the following tariff classification numbers as those under which subject goods are normally imported:

• 8504.22.00.20
• 8504.23.00.10
• 8504.23.00.20
• 8504.90.90.10
• 8504.90.90.82
• 8504.90.90.90

These tariff numbers are useful screening tools, but they are not the legal definition of the goods. A tariff item can include both subject and non-subject merchandise, and subject goods can sometimes be entered under a different tariff item. Importers therefore need to compare the actual transformer specifications against the product definition rather than relying on the HS code alone.

Existing SIMA duties continue during the review

CBSA guidance is explicit that anti-dumping and countervailing duties continue to be payable during an expiry review. The amounts continue to be determined using the values established in the investigation or the most recent administrative review.

That matters because an expiry review can run for several months. Importers should not assume that the start of the review creates a duty holiday or that future purchases can be priced as though the measure is about to disappear.

CBSA’s current measures-in-force page lists exporters in Chinese Taipei and South Korea that have specific normal values. Importers buying from those exporters should obtain current normal-value information through the exporter where appropriate.

For subject goods from exporters that have not been issued specific normal values, CBSA currently identifies all-other-exporter anti-dumping duty rates of:

• 21.3% of export price for Chinese Taipei
• 73.1% of export price for South Korea

Those rates can be commercially significant on capital equipment with a high transaction value.

CBSA also notes that the original dumping investigation was terminated for small power transformers exported from South Korea by IEN Hanchang Co., Ltd. Importers should still verify that their goods, exporter identity and transaction facts match the treatment they intend to claim.

Why the expiry review matters to importers

Expiry reviews determine whether a trade-remedy measure that would otherwise reach the end of its normal life should continue.

The CBSA first asks whether dumping is likely to continue or resume if the finding expires. If CBSA concludes that continued or resumed dumping is likely, the process moves to the Tribunal, which examines whether that dumping would likely cause injury to Canadian industry.

There are two broad outcomes.

If the measure is continued, SIMA duties remain applicable to subject imports, potentially with the order or finding continued with amendments.

If the measure is allowed to expire, SIMA duties cease to apply after the effective expiry outcome. CBSA guidance also provides for the return of SIMA duties collected after the scheduled expiry date where the review ultimately results in the measure being rescinded.

For importers, this means transactions during the review period should be documented carefully. Depending on the final outcome, the records supporting goods released during the relevant period can become important for duty recovery.

Importers can participate in the CBSA review

CBSA has sent questionnaires to Canadian producers, importers and exporters as part of the expiry review investigation.

Any Canadian importer that did not receive a questionnaire but wants to participate can contact the CBSA Trade Remedies Registry.

The response deadline identified by CBSA is November 6, 2026.

Participation can matter where an importer has meaningful purchase volumes, changing supply patterns, sourcing alternatives, pricing evidence or other market information relevant to the likelihood of resumed dumping.

Importers considering participation should not wait until the deadline to begin gathering records. Commercial contracts, purchase orders, supplier quotations, import data, product specifications and historical pricing can take time to assemble.

What importers should do now

1. Identify potentially subject transformer purchases

Review purchases from Chinese Taipei and South Korea against the complete CBSA product definition, especially transformer capacity and nominal high-voltage specifications.

2. Confirm the exporter

SIMA liability can depend heavily on the actual exporter and whether CBSA has established normal values for that exporter. Do not assume that a distributor, reseller or intermediary has the same treatment as the manufacturer.

3. Verify the tariff classification, but do not stop there

Screen the six tariff classification numbers currently identified by CBSA, then confirm whether the physical product is actually within the SIMA definition.

4. Obtain current normal-value information

Where the exporter has specific normal values, make sure the transaction is structured with enough information to assess whether the export price will create anti-dumping duty exposure.

5. Budget for the measure to continue

Until the review is completed, buyers should price purchases on the assumption that the existing SIMA measure remains enforceable.

6. Preserve records for possible refunds

If the finding is eventually allowed to expire, CBSA guidance provides a mechanism for duties collected after the scheduled expiry date to be returned. Clear entry-level records will make any reconciliation easier.

7. Consider whether to participate

Importers with material volumes or market evidence may want to assess whether responding to CBSA’s expiry review questionnaire is commercially worthwhile before the November 6 deadline.

The Vectura perspective

An expiry review is easy to misread as a signal that a SIMA measure is ending. Operationally, the opposite approach is safer: continue complying with the current measure until the authorities formally change it.

For importers of power equipment, the risk is amplified because individual shipments can have substantial values. A classification error, an incorrect assumption about exporter-specific normal values or a failure to identify a subject transformer can produce a large duty assessment on a single entry.

At the same time, importers should track the review closely because a rescission can create a refund opportunity for duties collected after the relevant expiry point.