Canadian importers are facing several changes that do not operate independently. The 2026 tariff schedule files, new U.S.-origin surtax rules, revised GPT and LDCT guidance, and an updated CBSA verification memorandum all affect the same core customs data: tariff classification, origin and value for duty. For importers in Brampton, Toronto and Mississauga, the practical issue is whether those fields remain consistent across supplier documents, internal product databases and the Commercial Accounting Declaration (CAD) submitted through CARM.
What changed between June and September 2026
CBSA revised Memorandum D11-4-4 on June 25, 2026. The memorandum addresses origin rules, proof of origin and direct-shipment requirements for goods claiming the General Preferential Tariff (GPT) or Least Developed Country Tariff (LDCT). It also sets out documentation expectations, including support for origin claims and transshipment routes when requested. CBSA Memorandum D11-4-4
CBSA also released two 2026 Customs Tariff data sets for operational use: T2026-1, effective August 6, and T2026-2, effective September 1. The published tariff page does not provide a consolidated line-by-line change log, so importers relying on tariff databases generally need to compare the applicable chapters or complete files with the prior release. CBSA Customs Tariff 2026
On September 8, 2026, Customs Notice 26-23 introduced surtaxes of 15%, 25% or 50% on specified U.S.-origin goods. The notice states that the surtax is calculated on value for duty under sections 47 to 55 of the Customs Act, uses CUSMA-country marking rules to determine origin, and may apply when the goods reach Canada through a third country. Commercial importers are also required, on the terms set out in the notice, to provide proof of origin and use the specified surtax codes in CARM. CBSA Customs Notice 26-23
On September 9, 2026, CBSA revised Memorandum D11-6-8 to reflect CARM Release 3 and the replacement of Forms B3-3 and B2 with the CAD. The memorandum covers verification of non-free-trade-agreement origin, tariff classification and value for duty. It describes possible questionnaires, letters, visits, document reviews and goods analysis, and states that CBSA may reassess after a verification. CBSA Memorandum D11-6-8
The common problem: three customs fields, one transaction
These developments make it risky to maintain origin, classification and valuation as separate files. A change to a tariff item can affect whether a surtax applies. A change to the declared value can affect the surtax amount when the measure is calculated on value for duty. A supplier’s origin statement can support one tariff treatment while failing to support another, depending on the applicable rule.
For a commercial shipment, an importer’s review should connect at least these elements:
- Tariff classification: the current 2026 tariff item, including any applicable surtax or remission treatment.
- Origin: the origin conclusion and the supporting rule, marking analysis, certificate or statement.
- Value for duty: the valuation basis used for the CAD and for any measure calculated on that value.
- CARM accounting: the tariff treatment and accounting codes provided to the broker or entered through the importer’s process.
- Records: commercial invoices, supplier declarations, shipping records and calculation support that can be retrieved if CBSA asks for them.
This is especially relevant when a product is manufactured in one country, invoiced by a company in another and shipped through a third country. Customs Notice 26-23 specifically states that routing through a third country does not by itself prevent the U.S.-origin surtax from applying. The origin analysis and the shipping record therefore need to tell the same story.
Specific measures that need separate checks
U.S.-origin goods and value for duty
Importers of goods covered by Customs Notice 26-23 should review four inputs before the next accounting: whether the tariff item is listed, whether the goods meet the applicable origin rule, whether the value for duty is supported, and whether the correct CARM surtax code is being used. The notice identifies the surtax rates as 15%, 25% or 50%, depending on the covered goods. Customs Notice 26-23
The fact that a shipment is purchased from a U.S. vendor is not, on its own, the complete origin analysis described in the notice. Importers should discuss how the CUSMA-country marking rules apply to the specific product and what proof should be retained.
Wood cabinets, vanities and related subassemblies
A separate provisional safeguard surtax took effect on July 31, 2026 for specified wood cabinets, vanities and related subassemblies under tariff items 9403.40.00.10, 9403.60.10.31, 9403.60.10.39 and 9403.91.00.90. The measure applies at 25% of value for duty and covers solid or engineered wood products, finished or unfinished, including assembled, unassembled, flat-pack and ready-to-assemble products. Canada Gazette, SOR/2026-169
The order includes exceptions for qualifying goods from listed countries and tariff programs, including the United States, Mexico, Chile, Israel and GPT beneficiary countries, as well as certain casual and Chapter 98 goods. An importer of cabinetry into a GTA distribution operation should therefore avoid treating the 25% measure as a classification-only question. The tariff item, country of origin and exception evidence need to be reviewed together. The Canada Gazette identifies Ontario as having a significant domestic cabinet and vanity manufacturing base, making the measure relevant to Ontario importers and their supply chains. Canada Gazette, SOR/2026-169
GPT and LDCT preference claims
Importers claiming GPT or LDCT treatment should confirm that the supplier’s origin documentation, ex-factory calculations and shipping records support the claim under the revised D11-4-4 guidance. The revised memorandum addresses direct-shipment requirements and the need to substantiate transshipment routes when requested. CBSA Memorandum D11-4-4
What GTA importers should review with their broker
Importers operating warehouses or distribution networks in Brampton, Toronto or Mississauga may want to review their product master data and accounting instructions rather than checking only individual shipments. The review should cover products subject to U.S. surtaxes, cabinetry and vanity products, and goods receiving GPT or LDCT treatment.
- Compare the applicable tariff items and tariff treatments against the T2026-2 data set effective September 1, 2026.
- Identify products for which the country shown on the invoice differs from the country of origin used for customs purposes.
- Confirm how value for duty is calculated and what records support that calculation.
- Check that CAD instructions include the tariff treatment and any applicable surtax code.
- Ask whether supplier origin statements and shipping records meet the relevant preference or surtax requirements.
- Test whether the importer can retrieve the records supporting a classification, origin or value-for-duty decision if CBSA begins a verification.
Importers should also distinguish remission from exemption treatment. The amended United States Surtax Remission Order (2025), registered June 22, 2026, added products to several remission and exemption schedules, extended certain periods to June 30, 2027, and exempted qualifying Canadian-origin steel derivative goods that are temporarily exported and reimported. Some relief requires a remission claim and supporting records, while the Canadian-origin steel derivative exemption operates differently. Canada Gazette, SOR/2026-154
Why record consistency matters
The revised D11-6-8 memorandum means that CBSA verification may examine origin, classification and value for duty in the same broader review framework. A tariff database showing one tariff item, a supplier file supporting another origin conclusion and a CAD using a different valuation instruction can create avoidable questions even when each record was prepared for a different purpose.
The practical discussion with a customs broker is therefore not limited to whether a shipment can be released. It should include which tariff data version is being used, how the origin conclusion was reached, how value for duty was calculated, which CARM codes were selected and where the supporting records are maintained in Canada. This general information does not replace transaction-specific advice; unusual products, related-party transactions, preference claims and surtax exceptions warrant a review of the underlying facts.
Sources and effective dates
| Issue | Date | Primary source |
|---|---|---|
| GPT and LDCT origin and shipping guidance | June 25, 2026 | D11-4-4 |
| U.S. surtax remission amendments | June 22, 2026 registration | SOR/2026-154 |
| Wood cabinet and vanity safeguard surtax | July 31, 2026 | SOR/2026-169 |
| 2026 tariff data releases | August 6 and September 1, 2026 | Customs Tariff 2026 |
| Specified U.S.-origin surtaxes | September 8, 2026 | Customs Notice 26-23 |
| Verification framework and CAD changes | September 9, 2026 | D11-6-8 |