Recent CBSA customs notices and D-memorandum revisions do not create one general compliance task. They create different checks for different shipments: origin and value for U.S.-origin goods, tariff treatment for UK goods, CAD coding for excise products, and warehouse or carrier controls for goods moving under special procedures. Importers in Toronto, Mississauga and Brampton can reduce avoidable corrections by matching each affected shipment to the right review before the entry is finalized.
Start with the shipment, not the notice
The most useful first step is to identify whether a shipment falls into one of the specific product or movement categories covered by the recent changes. A single blanket instruction to “review the new CBSA notices” is unlikely to work because the notices address different obligations and different data fields.
| Shipment characteristic | Check to route first | CBSA source |
|---|---|---|
| Specified goods originating in the United States | Origin, tariff classification, value for duty and applicable surtax treatment | Customs Notice 26-23 |
| Qualifying goods originating in the United Kingdom | Origin, classification and eligibility for CPUKT treatment | Customs Notice 26-22 |
| Wood cabinets, vanities or covered subassemblies | Scope, origin, in-transit evidence and the CAD safeguard field | Customs Notice 26-17 |
| Excise-taxable goods | One correct excise exemption code per CAD line | Memorandum D18-5-1 |
| TRQ goods leaving a bonded warehouse | Permit coverage on the warehouse exit date and any required adjustment | Customs Notice 26-20 |
This routing approach is particularly useful where a Peel Region warehouse receives mixed inventory. A shipment may be physically consolidated with other goods, but the compliance review should still follow the goods’ origin, classification, accounting treatment and movement type.
Checks for tariff treatment and surtaxes
U.S.-origin goods: separate origin from transit
For specified U.S.-origin commercial goods, a new surtax of 15%, 25% or 50%, depending on the goods, applies from September 8, 2026. The surtax is calculated on value for duty and is in addition to other applicable duties. Coverage depends on origin; goods do not become covered merely because they transit through the United States. These points are set out in Customs Notice 26-23.
Before a broker prepares or adjusts the CAD, an importer may want to match the commercial invoice and origin evidence to the tariff classification used for the product. The review should distinguish a U.S. supplier, a U.S. shipping point and U.S. origin. Those are not interchangeable facts. Where a product is sourced through a U.S. distribution network, the importer should discuss the origin determination and any remission or exemption provision with the broker rather than relying on the route shown in the freight documents.
UK goods: verify the preference before changing instructions
Effective September 1, 2026, the United Kingdom, Channel Islands and Isle of Man were added to the applicable tariff treatment for the Comprehensive and Progressive United Kingdom Tariff. The tariff consolidation was updated with applicable rates across Chapters 1 to 99. Importers of qualifying goods should verify both origin and classification before claiming the preferential treatment, as explained in Customs Notice 26-22.
This is a good example of why broker instructions should not be changed solely by supplier country. A business that previously entered UK goods under MFN or another treatment may need to review its standing instructions, but the preferential treatment should be claimed only where the goods meet the applicable origin and classification requirements.
Electric motorcycles and cycles: reopen classification records
On August 6, 2026, the description for tariff item 8507.60.20 changed from “electrically-powered motorcycles” to “motorcycles or cycles with an electric motor.” Importers should review classification databases, broker instructions and existing advance rulings to determine whether the revised description affects their goods. CBSA specifically advised holders of classification rulings to assess the impact, according to Customs Notice 26-21.
Checks for CAD coding and CARM records
Verification files: remove legacy terminology
CBSA revised D11-6-8 on September 9, 2026, to reflect CARM Release 3. The revision describes the Commercial Accounting Declaration, or CAD, as replacing the former B3-3 accounting form and B2 adjustment request. The memorandum applies to commercial importers and customs agents subject to verification of origin, tariff classification or value for duty. The revised procedure is described in Memorandum D11-6-8.
For an importer responding to a verification, the practical control is consistency. Records, adjustment procedures and internal response templates should use the current CAD and CARM terminology. A review file that still describes every correction as a B2 may create avoidable confusion, even where the underlying transaction records are complete. Importers should ask their broker which documents and transaction references should accompany a proposed adjustment.
Excise products: validate the line-level code
D18-5-1 was revised on June 30, 2026, to update excise and GST exemption coding in CARM. The memorandum covers products including alcohol, tobacco, cannabis, vaping products, luxury vehicles, fuel-inefficient vehicles and other excise-taxable goods. CARM permits only one excise code per CAD line, so goods subject to multiple excise charges may require the applicable combined code. These details come from Memorandum D18-5-1.
Importers can use a line-level check rather than reviewing only the total statement. For each affected product, compare the product description, tax status and selected excise code. This is especially important when a Toronto or Mississauga distribution operation imports several product types under one commercial shipment and the accounting system carries forward older exemption-code logic.
Checks for warehouses, carriers and regulated products
Wood cabinets and vanities: preserve the evidence trail
Certain commercially imported wood cabinets, vanities and subassemblies became subject to a 25% safeguard surtax on July 31, 2026. The measure can apply for up to 200 days during the provisional safeguard period. The notice also addresses inclusions, exclusions, origin, goods already in transit and CARM accounting. The safeguard amount is reported in the “Safeguard” field of the CAD using safeguard code 26169A, rather than the ordinary surtax field. See Customs Notice 26-17.
For flat-pack, unfinished, unassembled or component shipments, the importer should preserve the product description and origin evidence used for the scope decision. If relying on in-transit treatment, the importer should also retain proof that the qualifying goods were already in transit on July 31. The broker should receive those documents before the accounting is completed, not after a warehouse discrepancy has surfaced.
TRQ goods: match the permit to the warehouse exit
Customs Notice 26-20 clarified the accounting sequence for tariff-rate-quota goods entering a customs bonded warehouse. CBSA stated that this was not a policy change. To obtain the within-access rate, the shipment-specific import permit must cover the date the goods leave the warehouse. If the permit is obtained after entry, the original Type 10 CAD should be adjusted before a Type 20 or 21 ex-warehouse movement claims within-access treatment. The clarification was published August 21, 2026, and is detailed in Customs Notice 26-20.
A bonded warehouse serving GTA customers should therefore connect three records: the original warehouse entry, the permit and the ex-warehouse movement. The critical date is not simply the date the goods first entered Canada; it includes the date on which the goods leave the warehouse for the claimed treatment.
Rail movements and regulated products: confirm the handoff
For specified rail in-transit movements, including CAN–U.S.–CAN and U.S.–CAN–U.S. movements, CBSA instructed rail carriers to use the “Rail In-transit Manifest” movement type. Customs Notice 26-16 also addresses ACI/eManifest, First Port of Arrival and export-reporting requirements. Importers using rail corridors connected to Toronto-area distribution should ask carriers and brokers to confirm that cargo-control data identifies the movement correctly, rather than treating an in-transit shipment as an ordinary import. The notice is dated July 10, 2026: Customs Notice 26-16.
Two other product-specific reviews may be needed. D19-6-3, revised July 24, 2026, updates guidance for regulated energy-using products following Amendment 18 to the Energy Efficiency Regulations, including product information, certification marks and energy-efficiency reports where applicable. D19-12-1, revised September 2, 2026, updates vehicle-import guidance, including the definition of temporary residents and use of the Single Window Initiative and Integrated Import Declaration service option 911 for eligible entries. The relevant sources are D19-6-3 and D19-12-1.
What to take to the broker
For affected shipments, the most useful broker discussion is transaction-specific. Provide the commercial invoice, origin information, classification rationale, permit or transit evidence, and any existing ruling or standing instruction that may be affected. Then identify the requested decision: whether a surtax applies, whether a preferential tariff treatment is available, which CAD field or code is appropriate, or whether an adjustment is needed.
- Ask whether the product is within the exact scope of the notice or memorandum.
- Confirm which date controls: import, warehouse exit, transit, shipment or publication date.
- Confirm whether the supporting evidence belongs in the entry file, the adjustment file or both.
- Ask whether an existing broker instruction, tariff database entry or ruling should be reviewed.
The objective is not to treat every revision as a new filing requirement. It is to identify the affected shipment, apply the specific CBSA procedure and retain the evidence supporting the accounting decision.