Aluminum Importers Need Smelt-and-Cast Data Before GIP 83 Goods Arrive

Canadian importers of aluminum covered by General Import Permit No. 83 now need to treat smelt-and-cast information as import data, not as a record to retrieve after release. The underlying reporting requirement took effect October 1, 2026, and CBSA’s updated Memorandum D19-10-2, published October 16, set out the reporting requirements for covered goods. CBSA Memorandum D19-10-2

For importers in Mississauga, Toronto, Brampton and elsewhere in the GTA, the key operational question is not simply whether a shipment contains aluminum. It is whether the transaction has the product, permit and supply-chain information needed to make the applicable declaration when the goods are imported.

What information is now relevant

For products containing primary aluminum imported under item 83 of the Import Control List, the reporting requirements include the country of largest smelt and, where applicable, the country of second-largest smelt. For all aluminum covered by GIP 83, the country of most recent cast must also be reported at importation through the applicable CBSA and Global Affairs Canada electronic declaration process. CBSA Memorandum D19-10-2

This creates a data-dependency between the commercial description of the goods and their production history. A supplier invoice may identify an alloy, shape or finished product without answering where the primary aluminum was smelted or where the most recent casting occurred. Those details may need to be obtained separately from the exporter, producer or upstream supplier before the import declaration is submitted.

The related Global Affairs Canada notice identifies the measure as General Import Permit No. 83 for aluminum products. Global Affairs Canada Notice to Importers, Serial No. 1170

Where the requirement can be missed

The risk is greatest when purchasing, transportation and customs data are maintained by different teams. A procurement record may contain the supplier’s product code, while the customs file contains the tariff classification and value for duty. Neither record necessarily contains the smelt and cast countries required for the GIP 83 declaration.

Importers who handle aluminum through GTA airports or other Canadian commercial points of entry are generally expected to provide the applicable information at importation and retain supporting records. The requirement therefore belongs in the shipment-information collection process, rather than only in a post-entry audit checklist. CBSA Memorandum D19-10-2

A practical intake control is to identify potentially covered aluminum products early and request the relevant production-origin information before the commercial documents are finalized. The file can then distinguish between:

• the country of largest smelt;
• the country of second-largest smelt, where applicable; and
• the country of most recent cast.

The records supporting those data points should remain connected to the import file. The updated memorandum states that supporting records must be retained. CBSA Memorandum D19-10-2

Check the exemptions before building the control

The reporting exemptions identified in the research are important to the scope of the review. The requirement does not apply to goods with a total value for duty of $5,000 or less, or to goods released by an eligible Customs Self-Assessment importer under a CSA service option. CBSA Memorandum D19-10-2

Importers should therefore avoid applying one blanket data request to every aluminum shipment. A better review separates the shipment’s value for duty, the applicable GIP 83 coverage and the release program used. An eligible CSA release may be treated differently from a shipment that falls outside that exemption, while a shipment above the value threshold may require the relevant smelt-and-cast information.

Where the requirement applies, missing or unsupported information can create compliance exposure. The CBSA memorandum identifies possible administrative monetary penalties and potential enforcement under the Export and Import Permits Act for non-compliance. CBSA Memorandum D19-10-2

What import teams should change first

1. Flag affected products. Review aluminum product records against the goods covered by item 83 of the Import Control List.
2. Assign data ownership. Decide whether the importer, supplier or broker will obtain and validate smelt-and-cast information before declaration.
3. Separate the three country fields. Do not combine smelt and cast information into a single generic country-of-origin field.
4. Document the exemption review. Record the value-for-duty and CSA-release analysis for shipments treated as exempt.
5. Retain supporting records. Keep the evidence used to prepare the electronic declaration with the customs file.

The October 16 memorandum did not create a new GTA-only border rule. It documented a requirement already effective October 1. For aluminum importers routing goods through the GTA, the immediate change is upstream: shipment readiness now depends on obtaining production-stage information before the declaration reaches the electronic filing process.