Several CBSA D-Memoranda were revised between June and September 2026. The changes do not create one general documentation rule for every Canadian importer. They address specific workflows: CARM and the Commercial Accounting Declaration (CAD), vehicle imports, energy-using products, controlled imports and firearms or weapons. Importers in Toronto, Mississauga and Brampton should identify which memorandum applies to their goods before changing procedures or assuming that a new duty applies.
What the revisions have in common
The most consequential common feature is a move away from older accounting terminology and toward CARM-based processes. Revised D11-6-8, Verification of Origin, Tariff Classification, and Value for Duty, dated September 9, 2026, updates references to the former B3-3 and B2 forms and refers instead to the Commercial Accounting Declaration.
That change matters when an importer or customs agent prepares records for CBSA verification of origin, tariff classification or value for duty. Importers who maintain internal templates, broker instructions or verification files using the former terminology should generally review those materials and confirm that the records now align with the CAD process. The revision itself concerns documentation and verification procedure; it should not automatically be treated as a new tariff measure.
Four revisions requiring a targeted review
1. Verification files: D11-6-8
D11-6-8 was revised on September 9, 2026, to reflect CARM Release 3 and update references from B3-3 and B2 to the CAD. It applies to commercial importers and customs agents subject to CBSA verification of origin, tariff classification or value for duty.
For a GTA importer, the immediate review is usually procedural. A Mississauga distribution operation, a Brampton warehouse or a Toronto head office may have separate teams maintaining commercial invoices, classification records and valuation support. Those teams should compare their terminology and document references with the current memorandum. Broker instructions should also identify the CAD information and supporting records expected for the relevant accounting and verification process.
The official memorandum is the controlling reference for the revised terminology and scope: CBSA D11-6-8.
2. Controlled imports: D19-10-2
D19-10-2, Administration of the Export and Import Permits Act (Importations), was revised on July 13, 2026. It explains how goods on the Import Control List are declared through the CAD process and includes current procedures for controlled goods such as steel, aluminum and Chinese-made electric vehicles.
Importers of agricultural products, steel, aluminum, textiles, clothing and certain vehicles should therefore review whether their release instructions identify the applicable permit and permit data. The memorandum states that importers of Chinese-made electric vehicles are encouraged to use Single Window/IID for release information and permit data. It also states that an entry will be rejected without the required shipment-specific permit.
This is a shipment-control issue rather than a generic CAD conversion exercise. A broker may have the correct tariff classification and commercial invoice but still be unable to complete the release if the required permit data is absent or does not cover the shipment. Importers should discuss permit ownership, shipment matching and document retention with their broker before cargo is presented for release.
3. Energy-using products: D19-6-3
D19-6-3, Importation of Energy-using Products, was revised on July 24, 2026, following Amendment 18 to the Energy Efficiency Regulations, 2016. The memorandum updates information for regulated products and the requirements associated with the Single Window/Integrated Import Declaration process.
Commercial importers of regulated energy-using products should review the product information their purchasing, compliance and customs teams provide for the IID/SWI process. The memorandum states that prescribed information must be provided to CBSA through that process and that missing information can result in penalties.
The practical question for an importer is not simply whether a product is described as energy-using. It is whether the product falls within the regulated scope and whether the data supplied to the broker is complete for the applicable declaration. Importers should map regulated product records to purchase orders, product specifications and release instructions, especially where a GTA warehouse receives products from multiple suppliers.
4. Vehicles, firearms and related goods
D19-12-1, Importing Vehicles into Canada, was revised on September 2, 2026. The revision includes an updated definition of temporary residents and addresses safety, ownership, duties, taxes, CARM and the Registrar of Imported Vehicles program. It applies to commercial and individual vehicle imports, including vehicles imported for resale, temporary use or parts.
Businesses importing vehicles through Southern Ontario should review whether their procedures reflect the current definition and the memorandum’s requirements. The document also lists a Toronto-area contact location for the Registrar of Imported Vehicles. Importers should confirm the treatment of vehicles brought in for resale, temporary use or parts before arranging the movement and release.
D19-13-2, Importing and Exporting Firearms, Weapons and Devices, was revised on June 25, 2026. It reflects changes to applicable firearms, storage and related regulations. Commercial importers of firearms, firearm parts, weapons, devices and ammunition should review the required documentation because the memorandum states that goods may be held when the required documentation is not provided.
What to change in the import file
Importers should discuss the following points with their customs broker, based on the product category involved:
- CAD references: whether internal forms, broker instructions and verification files still refer to B3-3 or B2 where the current process uses CAD.
- Permit data: whether controlled goods have the required shipment-specific permit information and whether it is being transmitted through the appropriate Single Window/IID workflow.
- Product data: whether regulated energy-using products have the prescribed information before the declaration is submitted.
- Vehicle records: whether ownership, intended use, safety and Registrar of Imported Vehicles documentation has been reviewed for the shipment type.
- Specialized documentation: whether firearms, weapons, devices or ammunition files contain the documentation needed to avoid a hold.
For companies operating across Toronto, Mississauga and Brampton, the review should cover the whole shipment chain rather than only the customs desk. Purchasing records, product databases, warehouse receiving instructions and broker transmission data may be maintained by different teams. A mismatch between those records can delay release even when the commercial invoice appears complete.
What these revisions do not establish
These D-Memorandum revisions should not be read as a single new duty, tariff or penalty applied to all imports. Each memorandum addresses a defined subject: verification, controlled imports, energy-using products, vehicles, or firearms and related goods. The applicable obligation depends on the goods and the transaction.
Importers should also distinguish a memorandum revision from a separate tariff or surtax notice. If a shipment is affected by a duty measure, safeguard, tariff treatment or permit requirement, the relevant order or notice must be reviewed in addition to the applicable D-Memorandum. The broker discussion should therefore begin with the product, origin, intended use and release process—not with the assumption that every revised memorandum changes the duty payable.
Recommended next step
Ask your broker to identify which of the revised memoranda applies to each product family and to confirm the data or documents required before release. Then update only the affected workflows: CAD terminology for verification files, permit controls for controlled goods, IID/SWI data for regulated products, and specialized records for vehicles or weapons. Keeping the review product-specific reduces the risk of both under-documenting a controlled shipment and overhauling procedures that the revision does not affect.