Recent Canadian customs changes require importers to test three transaction facts together: what the goods are, where they originate and how their value for duty is calculated. The September 2026 U.S. surtax measures, the new U.K. tariff treatment, the lithium-ion battery amendment and the revision to Memorandum D11-6-8 each affect a different part of that control process.
For importers operating through Toronto, Mississauga or Brampton distribution and manufacturing networks, the practical issue is not a general tariff increase. It is whether the classification, origin evidence, valuation record and CARM accounting treatment all point to the same result for the specific shipment.
What changed in the Canadian tariff and verification framework
Canada imposed surtaxes of 15%, 25% or 50% on specified U.S.-origin goods effective September 8, 2026. The listed product areas include certain steel and aluminum products, dairy, appliances, agricultural equipment, pulp and paper, and electronics. The surtax is additional to ordinary customs duties. Importers should confirm the covered tariff items and applicable CARM surtax code rather than applying a rate based only on the supplier’s country or commercial description. CBSA Customs Notice 26-23 identifies the relevant administration, including CARM codes 26186A, 26186B and 26186C.
The surtax applies to qualifying U.S.-origin goods, not simply to goods shipped from the United States. Importers may need to maintain and furnish origin evidence, and goods already in transit on or before the applicable entry-into-force date are treated separately under the Order. The underlying value-for-duty rules remain relevant: the surtax is calculated on value for duty under sections 47 to 55 of the Customs Act. The notice also addresses exclusions that may apply to post-export transportation and associated costs and to certain Canadian brokerage costs included in the price paid or payable. CBSA Customs Notice 26-23 and the related Canada Gazette Order should be read together for the transaction treatment.
A separate tariff amendment changed tariff item 8507.60.20 by replacing “electrically-powered motorcycles” with “motorcycles or cycles with an electric motor.” The amendment can remove the prior 7% tariff for qualifying lithium-ion batteries imported as inputs for electric-bicycle production in Canada. It is not a blanket zero-duty treatment for every lithium-ion battery. The Gazette Order specifies August 7, 2026 as its coming-into-force date, while the related CBSA notice states that the tariff change took effect August 6, 2026. Importers should reconcile the applicable tariff version and entry date before seeking corrections. Canada Gazette, SOR/2026-173 and CBSA Customs Notice 26-21 are the relevant sources.
The United Kingdom, the Channel Islands and the Isle of Man were added to the 2026 Customs Tariff with Comprehensive and Progressive United Kingdom Tariff treatment when the CPTPP entered into force for the United Kingdom on September 1, 2026. The applicable CPUKT rate depends on the tariff item and the goods’ qualification for preferential treatment. Shipment from the United Kingdom alone does not establish eligibility. The applicable CPTPP origin, proof-of-origin and shipping requirements remain relevant. CBSA Customs Notice 26-22 explains the treatment.
Finally, CBSA revised Memorandum D11-6-8 on September 9, 2026. The revision updates verification procedures for non-free-trade-agreement origin, tariff classification and value for duty to reflect CARM Release 3, including replacement of references to the former B3-3 and B2 forms with the Commercial Accounting Declaration. The revision is principally procedural; it does not establish a new general valuation methodology or general rule of origin. Memorandum D11-6-8 sets out the revised process.
The three checks should be performed on the same transaction
These developments are easiest to control when the importer treats classification, origin and value for duty as linked but separate tests. A correct answer in one field does not establish the answer in the others.
| Control question | Evidence to review | Potential consequence |
|---|---|---|
| What are the goods? | Technical specifications, product descriptions, tariff classification analysis and any applicable ruling | Determines the tariff item, including whether a U.S. surtax or battery amendment is potentially relevant |
| Where do the goods originate? | Production details, supplier origin records and required proof of origin | Separates qualifying U.S.-origin goods from other goods and tests eligibility for CPUKT treatment |
| What is the value for duty? | Commercial invoice, price-paid-or-payable records and applicable transportation or brokerage-cost analysis | Provides the base on which an applicable U.S. surtax is calculated |
| What was reported in CARM? | CAD data, tariff treatment, surtax code and accounting records | Creates the record that should reconcile to the importer’s supporting documentation |
This approach matters because a supplier invoice may describe an item as “U.S. product” without establishing legal origin, while a product may fit a tariff description without qualifying for a preferential tariff treatment. Similarly, a surcharge calculation should not be reviewed without checking which value-for-duty elements were included.
What GTA importers should put into their review queue
U.S.-origin goods
Importers receiving covered goods into a Mississauga, Brampton or Toronto facility should identify entries made on or after September 8, 2026 and compare the declared tariff item with the applicable surtax schedule. The review should separately test whether the goods qualify as U.S.-origin, whether the correct CARM surtax code was used and whether the value-for-duty calculation treated transportation and brokerage costs consistently with the applicable rules.
For goods moving through Pearson or along the 401/407 corridor, the physical route does not replace the origin analysis. The commercial record should connect the shipment to the product’s origin evidence, classification support and accounting declaration. Importers should also isolate goods that were already in transit on or before the applicable effective date because the Order provides separate treatment for those goods. CBSA Customs Notice 26-23 is the controlling operational reference identified for these checks.
U.K. purchases
Importers should not change a tariff treatment to CPUKT solely because the purchase order, invoice or transport document shows a U.K. address. The review should establish the applicable tariff item, confirm the CPTPP origin requirements and retain the required proof-of-origin and shipping records. Broker instructions and CARM tariff-treatment data should then reflect the supported treatment. CBSA Customs Notice 26-22 provides the source for the U.K. treatment.
Lithium-ion batteries
Manufacturers and importers supplying Canadian electric-bicycle production should review whether the battery fits the amended description and whether the end use and product facts support the applicable tariff item. Existing advance tariff-classification rulings should be checked where the description change could affect the ruling. The amendment does not justify applying duty-free treatment to unrelated lithium-ion batteries. The Gazette Order and CBSA Customs Notice 26-21 should be compared when reviewing entries around the conflicting effective-date references.
Records to align before a CBSA verification
Commercial importers whose records may be selected for verification should be able to connect the CAD data to the underlying origin, classification and valuation analysis. D11-6-8 addresses verification of non-free-trade-agreement origin, tariff classification and value for duty, and explains the CARM terminology used for verification-related processes. CBSA may reassess those elements following verification within the applicable statutory reassessment period. Memorandum D11-6-8 is the official source for that procedural framework.
- Maintain the technical information supporting the tariff classification.
- Keep origin evidence separate from shipping evidence; a ship-from location is not, by itself, the complete origin record.
- Document the value-for-duty calculation and the treatment of transportation and brokerage costs.
- Reconcile the CAD, tariff treatment and surtax code to the accounting file.
- Ask the broker to review entries affected by the U.S. surtax, CPUKT treatment or battery amendment before filing a correction or relying on a prior ruling.
The central control is transaction-level consistency. Importers should discuss with their broker not only which tariff item applies, but also whether the origin evidence supports the requested treatment and whether the declared value for duty supports any related surtax calculation. That three-part review is the most reliable way to distinguish a new duty rule from a classification issue, an origin issue or a CARM recording issue.