Several CBSA D-Memoranda and customs notices were revised between July and September 2026. The practical issue is not simply identifying the new document. Importers should determine which evidence, declaration data or shipment controls are affected by each revision, then align those requirements with the importer’s accounting records and broker instructions.
This article focuses on the evidence and process consequences of the revisions—not on creating another general change register. The most direct change is in D11-6-8, which now reflects CARM Release 3 and the Commercial Accounting Declaration (CAD) in CBSA verification work. Other revisions affect regulated energy-using products and automotive goods where product information or actual end use can determine the treatment claimed.
What changed in the D-Memoranda
D11-6-8: verification records now reference the CAD
CBSA revised D11-6-8 on September 9, 2026. The memorandum replaces references to the former B3-3 and B2 forms with the Commercial Accounting Declaration in the context of verifications of origin, tariff classification and value for duty. The memorandum covers records, questionnaires, verification visits, re-determinations and further re-determinations. CBSA D11-6-8
For a commercial importer, the operational consequence is a records-mapping exercise. Historical files may still contain B3-3 or B2 terminology, while newer accounting records use CAD data. The importer’s evidence should allow the reviewer to connect the transaction, commercial documents, classification decision, origin support and value-for-duty calculation to the applicable accounting declaration.
This does not create a new classification or valuation rule by itself. It changes the form and system context identified in the verification memorandum. Importers and customs agents should discuss whether their document-retention and retrieval process can produce a complete file using the current CAD terminology.
D19-6-3: regulated energy-using products
D19-6-3 was revised July 24, 2026, following Amendment 18 to the Energy Efficiency Regulations and related housekeeping changes. It also restates the information commercial importers provide to CBSA through the Integrated Import Declaration under the Single Window Initiative. The memorandum applies to commercial importations of regulated energy-using products, not personal importations. CBSA D19-6-3
Importers of covered appliances, equipment and other regulated products should therefore compare their product master data with the information transmitted through the import declaration. A broker can only transmit the information supplied or made available to it, so the importer’s product records, supplier specifications and regulatory data should be consistent before shipment.
For a company receiving equipment into a Mississauga or Brampton warehouse and distributing it across Ontario, this is a product-data control rather than a warehouse-location rule. The relevant question is whether the goods fall within the regulated product scope and whether the required information is available for the import declaration.
D10-15-15: automotive end-use evidence
D10-15-15 was updated August 14, 2026. It consolidated the former D10-15-15 and D10-15-21 guidance concerning tariff items 9958.00.00 and 9959.00.00. The revised memorandum addresses duty-free treatment for certain parts, accessories and materials used in manufacturing specified vehicles and emphasizes substantiating actual end use. CBSA D10-15-15
The evidence question is therefore broader than whether a part appears automotive in nature. Importers claiming the relevant treatment should be able to connect the imported goods to the qualifying manufacturing use. That may require coordination between purchasing, customs, receiving and production records. The claim should not rest only on a supplier’s description or a tariff code copied from a prior entry.
This is particularly relevant to Ontario automotive supply chains serving facilities in or around Toronto and the wider GTA. Before continuing an existing claim, an importer should discuss with its broker whether the revised memorandum changes the supporting records or the way the actual end use is documented.
Related customs notices that affect the evidence trail
Tariff treatment and surtax exposure
The 2026 notices also include changes where classification, origin or the value for duty affects the amount accounted for. Effective September 8, 2026, the United States Surtax Order (2026) applies a 15%, 25% or 50% surtax, depending on the tariff item, to specified U.S.-origin goods. The surtax is calculated on value for duty, and the notice identifies specified circumstances in which relief may be available, including certain CUSMA-related situations. Customs Notice 26-23
A separate provisional safeguard surtax of 25% applies from July 31, 2026 to specified wood cabinets, vanities and subassemblies, including listed tariff items in the notice. The notice includes exceptions for certain countries and goods in transit before the measure took effect. Customs Notice 26-17
For these measures, the evidence file should support the specific tariff classification, origin, value for duty and any claimed exception or relief. An importer using a Peel Region warehouse or a Toronto distribution operation should make sure the same product and origin information is available to the broker before the goods are accounted for, rather than trying to reconstruct it after an entry is questioned.
United Kingdom preferential treatment
Eligible goods from the United Kingdom became eligible for Comprehensive and Progressive United Kingdom Tariff treatment on September 1, 2026. CBSA issued tariff version T2026-2 to reflect the change. Importers claiming the treatment should review classification, origin documentation and any existing rulings for U.K.-origin goods. Customs Notice 26-22
The evidence risk is a mismatch between a preferential claim and the supporting origin record. A revised tariff opportunity does not, on its own, establish that every U.K.-supplied product qualifies. Importers should identify which products are being claimed and confirm the available origin documentation with their broker.
Rail movements through the United States
Customs Notice 26-16 clarifies reporting procedures for rail cargo moving Canada–United States–Canada and United States–Canada–United States. Depending on the circumstances, rail carriers may use ACI/eManifest reporting with the “Rail In-transit Manifest” movement type or the BSF708 Rail in Transit Manifest paper process. The notice also addresses timing, port of report and sealing requirements, and states that the changes will later be incorporated into D3-6-6. The notice is dated July 10, 2026 and the CBSA page was updated July 24, 2026. Customs Notice 26-16
The primary responsibility rests with rail carriers, but importers and freight forwarders whose cargo uses U.S. routings should confirm that the movement information supplied to the carrier is accurate. This is relevant to Ontario cargo using Buffalo–Niagara or Detroit–Windsor routings before moving onward to GTA facilities.
What importers should discuss with their broker
A useful review can be organized around four questions:
- CAD linkage: Can the importer retrieve the current accounting declaration and connect it to the commercial invoice, classification analysis, origin support and value-for-duty records?
- Product data: For regulated energy-using goods, does the product file contain the information needed for the Integrated Import Declaration?
- End use: For automotive claims under tariff items 9958.00.00 or 9959.00.00, can the importer substantiate the actual manufacturing use rather than only the product description?
- Measure-specific support: For surtax or preferential-treatment claims, can the importer support the tariff item, origin, value for duty and any exception or relief relied on?
Importers should also flag goods affected by the August 6, 2026 description change for tariff item 8507.60.20. The description changed from “electrically-powered motorcycles” to “motorcycles or cycles with an electric motor.” Importers of affected battery-related products should assess whether the revised description affects an advance or national customs ruling. Customs Notice 26-21
Finally, importers handling tariff-rate-quota goods through a customs bonded warehouse should review the clarification in Customs Notice 26-20. To receive the within-access duty rate when goods leave the warehouse, the goods are described as requiring a valid shipment-specific Global Affairs Canada import permit covering the date of withdrawal. The notice also explains the treatment of goods entering under a General Import Permit and the amendment process for the Type 10 CAD. CBSA states that this notice clarifies existing policy and process rather than changing the policy. Customs Notice 26-20
Practical conclusion
The 2026 revisions are best handled as evidence controls attached to particular claims and products. Importers should not assume that a prior B3-3-based file, an old end-use record, or a product master entry automatically supports a current CAD, tariff preference, surtax exception or regulated-product declaration. A focused review with the broker can identify which files require updated terminology, product information, origin support or end-use evidence before the next shipment is accounted for.