Request for LVL Products Tariff Relief

Re: The Request to have HTS Code 4412.49.00 (Laminated Veneer Lumber (LVL)) Products Exempt from Counter-Tariffs on the U.S.

Dear Minister Champagne,

Canada’s building supply and forest products industry is the third largest GDP contributor generating $53.1 billon for Canada’s economy. The industry supports 561,585 full and part time jobs and represents a wide range of businesses within the supply chain including manufactures, distributors, buying groups, and retailers.[i] Many of these businesses, located in rural areas, are the social and economic heartbeat for their communities. As the industry’s largest association Supply-Build Canada helps its 1300 member businesses navigate challenging times.

Supply-Build Canada, and its members who supply Laminated Veneer Lumber (LVL) wood products to homebuilders are concerned about the Government of Canada’s recent plan to set 50% counter-tariffs on U.S. produced LVL products[ii] effective September 8th, 2026, will delay homebuilding and increase costs in Canada.

Limited LVL Production Capacity in Canada, and the Non-Substitutability of U.S. Produced LVL

Canada’s capacity to produce LVL products is limited as the wood products industry relies on a North American supply chain. North American LVL production is estimated at 73 million cubic feet. Canada’s LVL producers make up around 6 million cubic feet (8%) while the U.S. produces 67 million cubic feet (92%).[iii] Canadian producers do not have the production capacity to replace U.S. supply. With the inability to switch from U.S. suppliers’ Canadian businesses that import LVL will either have to pay the 50% counter-tariff or stop purchasing LVL.

Moreover, not all LVL products are manufactured the same. Depending on the type, company, and facility products are made with different grades and certifications to fulfill building code and design requirements in Canada linking certain LVL products to a specific producer. This means that if a LVL product produce in the U.S. is specified to be used by a building code or design it cannot be substituted by another LVL product produced in Canada. The lack of substitutability will create LVL shortages in Canada and delay building. As a result, Canada will be faced with LVL cost increases and shortages which will have broader economic impacts on homebuilding and housing affordability in Canada.

Many Canadian building-material suppliers and contractors have already entered into fixed-price contracts based on the cost and availability of LVL prior to the implementation of these counter-tariffs. These businesses may have little or no ability to pass an unexpected tariff-related increase on to their customers. Compounding this issue, as mentioned, LVL is an engineered structural product and depending on project specifications, approvals and engineering requirements, products from different manufacturers cannot always be easily and readily substituted. As a result, businesses with significant committed projects could suddenly face hundreds of thousands of dollars in additional, unrecoverable costs. This creates substantial financial risk for Canadian companies that entered into contracts in good faith based on the costs and trade conditions that existed at the time.

Our Position:

We are supportive of the Government’s position in supporting Canadian industries and signing a trade agreement with the U.S. that benefits Canada and its sovereignty. In doing so we understand the intent of counter-tariffs is to protect Canadian industry and promote the use of domestic production capacity. In this case, the 50% counter-tariffs on HTS Code 4412.49.00 (LVL) will not achieve this goal as Canada’s domestic production capacity cannot meet demand. We ask that the Government of Canada re-evaluate their decision to implement countermeasure on LVL products.

We welcome the opportunity to meet with you to further discuss our position.

Thank you.

Sincerely,

Liz Kovach
President
Supply-Build Canada

Footnotes:

[i] Numbers derived from Statistics Canada, Table: 36-10-0480-01.

[ii] Tariff Item 4412.49.00 in Government of Canada, Complete list of U.S. products subject to counter tariffs, updated August 26, 2026.

[iii] Data for LVL production capacity of North American, Canada, and the U.S. provided by industry experts.