As of March 3, 2025, the New York Independent System Operator (NYISO) and ISO New England (ISO-NE) have both made tariff-related filings with the Federal Energy Regulatory Commission (FERC) in advance of a 10% tariff on Canadian electricity imports that is expected to take effect on March 4, 2025. [1] The tariff on Canadian energy resources is part of a broader set of duties on imports President Trump announced in January, which were subsequently paused for 30 days. [2] In a previous statement, ISO-NE said it was filing with FERC a proposed mechanism allowing it to collect customs duties related to electricity imported from Canada and sold into ISO-administered markets if directed by the federal government. [3] However, according to the filing, ISO-NE also believes that the custom duties described by the Trump administration do not appear to apply to electricity, and even if they do, ISO-NE would not be responsible for implementing them. [4] Similarly, NYISO said its own role in collecting the tariffs is uncertain. In a statement, NYISO emphasized that it is not yet clear whether imports of electrical energy from Canada are subject to the Canadian Tariff Order, or if they are, whether NYISO will be required to play a role in collecting or remitting duties. NYISO asserted that there are strong legal and policy arguments suggesting that the answer to both of those questions is “no”.

[1] https://elibrary.ferc.gov/eLibrary/docinfo?accession_number=20250228-5426

[2] https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20250228-5081&optimized=false

[3] https://www.iso-ne.com/static-assets/documents/100020/exigent_circumstances_filing.pdf

[4] https://www.nyiso.com/-/nyiso-statement-regarding-tariffs-on-imported-electricity-1