Several 2026 CARM revisions change how certain amounts are reported in the Commercial Accounting Declaration (CAD). They do not, on the information currently available, create a new Ontario-specific Release Prior to Payment (RPP) rule or remove the existing requirement for an importer to be enrolled in RPP and provide its own financial security through CARM. For importers in Brampton, Toronto and Mississauga, the practical task is to keep two controls separate: correct CAD coding for the goods, and continued RPP eligibility for the importer account.
What changed in CARM accounting
The changes below affect particular goods or accounting treatments. They are not a general rewrite of RPP. Importers and their brokers should identify which shipments are in scope before preparing the CAD and confirm that the accounting data flows correctly through the CARM Client Portal, EDI or API where applicable.
U.S.-origin goods: new surtax codes
Customs Notice 26-23 introduced new accounting codes for specified goods originating in the United States. The notice identifies code 26186A for a 15% surtax, 26186B for a 25% surtax and 26186C for a 50% surtax. Affected commercial importers using CARM’s self-declaration option are instructed to calculate the surtax and enter it in CAD field 85, “Surtax.” The change took effect on September 8, 2026, subject to the notice’s product schedules and exceptions. See CBSA Customs Notice 26-23.
The operational distinction is important: the new code can change the amount of duties and taxes accounted for on an eligible transaction, but it does not itself make an importer eligible for RPP. An importer using RPP would generally still need to satisfy the standing enrollment and financial-security requirements described in CBSA’s RPP guidance.
Wood cabinets and vanities: safeguard field, not ordinary surtax field
Customs Notice 26-17 introduced a 25% provisional safeguard surtax on specified wood cabinets, vanities and listed subassemblies. The notice identifies safeguard code 26169A and directs that the amount be entered in CAD field 87, “Safeguard,” rather than the ordinary surtax field. The measure took effect on July 31, 2026, and is scheduled to apply for up to 200 days, subject to the conditions and exceptions in the notice. The source is CBSA Customs Notice 26-17.
The notice also identifies exclusions and other exceptions, including goods originating in Canada, the United States, Mexico, Chile, Israel and certain developing countries. Importers should not apply the measure solely because a product description contains “cabinet” or “vanity”; origin, tariff classification, product scope and the notice’s exceptions all need to be reviewed. Where covered goods are accounted for under RPP, the safeguard may affect the amount deferred, but it does not replace the importer’s RPP security requirement.
Excise and GST-exemption coding
CBSA revised the reference material for excise and GST-exemption codes in Memorandum D18-5-1 on June 30, 2026. The revision addresses coding in the CARM system, including treatment connected with the temporary suspension of the federal fuel excise tax. The memorandum is available at CBSA Memorandum D18-5-1.
The related fuel-tax period addressed in the research material ran from April 20, 2026 through September 7, 2026, including the extension for leaded aviation gasoline described in Customs Notice 26-11. This is an accounting and exemption-coding issue for affected commercial importers, not a change to the requirement for importer-specific financial security under RPP.
What has not changed for release prior to payment
CBSA’s current RPP guidance continues to describe RPP as a program for commercial importers seeking release of goods before paying duties and taxes. Commercial importers seeking that treatment are generally required to enroll in the CARM Client Portal, enroll in RPP and provide the required financial security. The guidance states that the importer provides its own financial security through CARM; a broker’s account or a new CAD code does not substitute for that importer-specific requirement. See CBSA’s Release Prior to Payment guidance.
Based on the cited 2026 notices and guidance, there is no identified new rule specific to Ontario or the Greater Toronto Area that changes RPP eligibility, the need for importer registration, the need for the importer’s own financial security, or the consequence of lacking the required security. These are federal requirements applied to commercial importers across Canada, including businesses receiving goods into Brampton, Toronto or Mississauga.
A practical control for GTA importers
Separate product review from account review
For each affected product line, an importer and its broker should first determine whether the goods fall within a notice’s scope. That review should consider the product description, tariff classification, country of origin and any listed exception. The result should then drive the CAD field and code used: the U.S.-origin surtax treatment points to field 85 and the applicable code in Notice 26-23, while the specified wood-cabinet safeguard treatment points to field 87 and code 26169A in Notice 26-17.
Independently, the account review should confirm whether the importer is enrolled in RPP and whether its own financial security remains in place through CARM. A correct product code does not cure an RPP eligibility problem. Conversely, an importer’s RPP status does not determine whether a shipment is subject to a surtax or safeguard measure.
Check the transmission path
Notice 26-23 expressly addresses CAD submissions through the CARM Client Portal, EDI and API. Importers using more than one path should discuss whether the new code, percentage and CAD field are mapped consistently in each workflow. A self-declaring importer should also review how the amount is calculated before it is entered in field 85. The same review is prudent for broker-prepared entries, particularly where product data is shared across a Peel Region warehouse, a Toronto receiving operation and a Mississauga distribution location.
Reconcile the account after release
Importers should compare the commercial invoice, origin support, classification decision, CAD coding and the amount accounted for. For goods subject to a new measure, retain the rationale for selecting the relevant code or exception. If the importer uses RPP, reconcile the additional amount against the account activity without treating the presence of a deferred amount as evidence that the security requirement has been met.
Questions to take to your customs broker
- Does the product fall within the schedule and exceptions for the U.S.-origin surtax or wood-cabinet safeguard?
- Which CAD field and code apply to the transaction, and will that treatment be transmitted consistently through the selected filing method?
- Does the importer’s own CARM financial security support its current RPP use?
- Are excise or GST-exemption codes being applied under the revised D18-5-1 reference material?
- What records support origin, classification, exemption or exception decisions if the account is reviewed later?
The key compliance decision is not whether a new CARM code “turns on” RPP. It is whether the shipment is accounted for under the correct measure while the importer independently maintains the conditions for release before payment.