Recent Canadian customs updates do not create one universal rule for every shipment. They create several separate review points: whether the tariff description is current, whether preferential treatment is supported, whether a U.S.-origin surtax applies, and whether the declared value for duty can be supported during verification. Importers in Brampton, Toronto and Mississauga should treat those questions separately, then check that the answers are consistent on the same commercial accounting declaration (CAD).
What changed between August and October 2026
Four developments are relevant to commercial import files. The first is a tariff-description amendment effective August 6, 2026. Tariff item 8507.60.20 changed from “electrically-powered motorcycles” to “motorcycles or cycles with an electric motor.” The change concerns the tariff item’s description; it is not, on the information reviewed, a general revision to every electric vehicle classification. Importers handling potentially affected goods should review their product descriptions, classification databases, advance rulings and CAD declarations. CBSA Customs Notice 26-21 describes the amendment.
The second change took effect September 1, 2026. Eligible goods originating in the United Kingdom became eligible for the Comprehensive and Progressive United Kingdom Tariff (CPUKT), identified by tariff treatment code 35. The amended tariff also covers the Channel Islands and Isle of Man. The revised 2026 tariff became available in all formats on September 16, 2026. Eligibility is not established merely because the goods were shipped from the United Kingdom: the importer should confirm the applicable CPTPP origin rules before declaring the preferential treatment. See CBSA Customs Notice 26-22 and the CBSA Customs Tariff 2026.
The third change is the September 8, 2026 surtax on specified U.S.-origin goods. The surtax rates are 15%, 25% or 50%, depending on the covered goods. It is additional to ordinary customs duties and is calculated on value for duty under sections 47 to 55 of the Customs Act. The measure can apply where goods are exported to Canada from a country other than the United States, if they are treated as U.S.-origin goods under the applicable CUSMA-country origin-marking regulations. The operative measure and implementation details are set out in CBSA Customs Notice 26-23 and the United States Surtax Order (2026).
Finally, Memorandum D11-6-8 was revised on September 9, 2026, to reflect CARM Release 3. The guidance replaces references to the former B3-3 Canada Customs Coding Form and B2 Canada Customs—Adjustment Request with the CAD. It concerns CBSA verification of non-free-trade-agreement origin, tariff classification and value for duty. Memorandum D11-6-8 explains the verification framework.
Why the four questions should not be combined
1. Is the tariff description and classification still supportable?
Classification comes first because the tariff item determines which tariff treatment and, for covered U.S.-origin goods, which surtax rules may be relevant. For goods potentially covered by item 8507.60.20, the revised wording should be reflected in internal product records and broker instructions where appropriate. An importer with an existing advance classification ruling should discuss whether the description change affects the ruling or the way the goods are described on the CAD.
This review is narrower than a general reclassification exercise. The source identifies a specific description amendment, so an importer should not assume that every electric motorcycle, cycle or battery-related product belongs under the revised item without examining the product and the applicable tariff provisions.
2. Does the claimed origin support the tariff treatment?
Origin has two different functions in these updates. For qualifying UK goods, origin is part of the test for CPUKT treatment. For the U.S. surtax, the relevant question is whether the goods are treated as U.S.-origin goods for marking purposes under the CUSMA-country origin-marking regulations.
Those tests should not be replaced by the shipment route or the supplier’s location. A UK shipment requires support for the applicable CPTPP origin rules before treatment code 35 is declared. A product manufactured in multiple countries or routed through the United States requires an origin review for the surtax analysis. Commercial importers should retain the origin records supporting the declaration and discuss any uncertain manufacturing sequence with their broker.
3. What is the value for duty used in the calculation?
For covered U.S.-origin goods, the surtax is calculated on value for duty, not simply on an invoice amount selected without regard to the Customs Act valuation rules. This makes valuation a separate control point from both classification and origin. An importer should review the value-for-duty calculation and the commercial invoice together, rather than assuming that the invoice total automatically represents the taxable base.
The research reviewed for this update did not identify a new standalone D13 valuation memorandum or valuation-rule amendment during the period from July 31 to October 29, 2026. The most recent listed D13-series revision remains D13-2-4, dated July 17, 2025, according to the CBSA D13 memorandum index. The valuation development in this period is the use of existing value-for-duty rules for the new U.S.-goods surtax, alongside the CAD verification update.
4. Can the file withstand verification?
D11-6-8 indicates that verification can involve questionnaires, letters, verification visits, document reviews, and examination of samples or other information. CBSA may re-determine origin, classification or value for duty following a verification. Importers whose goods may be reviewed should therefore keep the classification support, origin documentation, valuation records, books and CAD data consistent.
Practical file review for GTA importers
A useful review is shipment-specific rather than location-specific. A Brampton warehouse receiving goods from a U.S. supplier, a Toronto importer buying from a UK manufacturer, and a Mississauga distributor receiving goods through a Canadian airport or port may face different questions depending on the goods, origin and declaration. The address of the GTA facility does not decide tariff treatment or origin.
- For potentially affected electric motorcycles or cycles: compare the product description used by purchasing, the classification database, any advance ruling and the CAD declaration against the wording effective August 6.
- For UK-origin goods: confirm that the goods meet the applicable CPTPP origin rules before using CPUKT treatment code 35. Keep the origin support with the import file.
- For specified U.S.-origin goods: review classification, origin, the applicable surtax rate, value for duty and the CAD reporting position. Routing through another country does not by itself remove the origin question.
- For all three situations: check that supplier documents, internal master data, broker instructions and accounting records describe the same goods and support the same origin and value-for-duty conclusions.
CBSA updated Customs Notice 26-23 on October 23, 2026. The update clarified, among other points, that the surtax applies to covered commercial and casual imports, can apply to certain goods below ordinary de minimis thresholds, uses value for duty, and requires proof of origin for commercial goods. It also states that Chapters 98 and 99 are generally exempt unless specifically covered by the Order, and that overlapping surtaxes under the U.S. Surtax Order and Steel Derivative Goods Surtax Order are not cumulative in the circumstances described by CBSA. The October 23 update did not create a new general effective date; the underlying surtax remains effective from September 8, 2026. Importers should review the current notice before applying those points to a specific shipment.
What to discuss with your customs broker
For an active import program, the broker discussion should focus on the evidence behind each declaration, not only on the final tariff treatment. Ask whether the product description remains appropriate under the amended tariff wording; whether a UK-origin claim is supported under the applicable CPTPP rule; whether a U.S.-origin surtax analysis is required; and how the value for duty was established.
It is also worth confirming which records would be produced if CBSA requested a classification, origin or valuation review. The CAD has replaced the former B3-3 and B2 references in the revised verification guidance, so older procedures and templates should be mapped to the current accounting workflow. These are general compliance considerations, not a determination of the correct treatment for a particular product or transaction.
Bottom line
The principal risk in these updates is treating tariff classification, origin and valuation as one decision. The August tariff-description amendment, September UK preferential treatment, September U.S.-goods surtax and September CAD verification revision address different parts of the import file. A controlled review connects them without collapsing them: classify the goods, establish the relevant origin, calculate value for duty under the applicable rules, and preserve records that support the CAD.