CBSA Customs Notice Revisions in 2026: An Operational Change-Control Checklist

Several 2026 CBSA notices and D-Memorandum revisions affect surtax coding, tariff treatment, warehouse processes, product data and CARM documentation. This operational checklist helps importers assign each change to the right team before the relevant accounting or release activity.

CBSA UpdatesSeptember 26, 20266 min readBy LogisticNorth Editorial Team

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Several CBSA customs notices and D-Memorandum revisions issued in 2026 affect different parts of an import operation: tariff coding, CARM accounting, origin evidence, warehouse licensing, regulated-product data and end-use records. The practical risk is not one broad customs-system change. It is that a change reaches the broker, purchasing team, warehouse or product master at different times.

Importers in Toronto, Mississauga and Brampton can use the checklist below to assign each revision to an operational owner. The dates and requirements should be confirmed against the linked CBSA notice before a shipment is released or an accounting declaration is submitted.

Start with the effective date, not the publication date

A notice may be issued on one date while its accounting or tariff consequence applies on another. For example, Customs Notice 26-23 states that certain U.S.-origin goods became subject to surtaxes effective September 8, 2026. The notice describes rates of 15%, 25% or 50% of value for duty and identifies Commercial Accounting Declaration codes 26186A, 26186B and 26186C. Commercial and casual goods originating in the United States may be covered, including goods shipped through a third country. Customs Notice 26-23

That means a change-control record should separately capture the publication date, effective date, affected tariff or origin population, CARM field and required evidence. Goods already in transit to Canada on September 8, 2026 may qualify for an exception where the importer retains the supporting transportation and cargo documents described in the notice. Customs Notice 26-23

ChangeEffective or revision dateFirst operational owner
U.S.-origin surtaxesSeptember 8, 2026Trade compliance and CARM accounting
Wood cabinet safeguardJuly 31, 2026Classification, purchasing and broker instructions
U.K. tariff treatmentSeptember 1, 2026Origin and tariff-management teams
Electric motorcycle and cycle descriptionAugust 6, 2026Product master and classification
D11-6-8 CARM terminologySeptember 9, 2026Trade compliance and records

Changes that affect the Commercial Accounting Declaration

Separate ordinary surtax coding from safeguard coding

Customs Notice 26-17 describes a provisional 25% safeguard surtax on certain wood cabinets, vanities and related subassemblies. The coverage can include finished, unfinished, assembled, unassembled and flat-pack goods, including products containing engineered wood. Commercial importers of covered kitchen, bathroom and closet products may be affected. Customs Notice 26-17

The notice states that the measure took effect July 31, 2026 and is generally in place for up to 200 days. The amount is declared in the CAD “Safeguard” field using safeguard code 26169A, rather than the ordinary surtax field. The notice also identifies exclusions, including certain countries, goods in transit, casual goods and specified accessories. A furniture, renovation or construction-supply importer should therefore map the product scope and exclusions before changing a blanket rule in its ERP or broker instructions. Customs Notice 26-17

Review fuel exemption coding separately

Customs Notice 26-11 updates the temporary federal fuel-excise-tax suspension. For covered unleaded gasoline, unleaded aviation gasoline, diesel fuel, aviation fuel and leaded aviation gasoline, the zero-rate suspension is extended through January 31, 2027. The notice states that 50% of the regular rates apply from February 1 to March 31, 2027, with full rates returning April 1, 2027. Importers claiming the suspension use CARM excise exemption code F00 on the CAD. Customs Notice 26-11

This is a useful example of why accounting-code testing should include the date of import and the date of declaration. Fuel importers and their brokers should discuss how the F00 code is handled across the applicable periods rather than treating the notice as a permanent rate change.

Changes that affect tariff treatment and product master data

Confirm CPUKT eligibility for U.K.-origin goods

Customs Notice 26-22 states that eligible goods from the United Kingdom, the Channel Islands and the Isle of Man became eligible for the Comprehensive and Progressive United Kingdom Tariff, using tariff treatment code 35, effective September 1, 2026. The change does not make every U.K. product duty-free. Applicable origin and tariff-treatment requirements still need to be satisfied, and the relevant CPUKT rate should be confirmed in the T2026-2 tariff. Customs Notice 26-22

For an importer, the immediate task is to update tariff-treatment logic and retain the origin information supporting the claim. The tariff files were made available in all formats on September 16, 2026, according to the notice. Customs Notice 26-22

Update descriptions for electric-mobility products

Customs Notice 26-21 records an amendment to the description of tariff item 8507.60.20. The wording was changed from “electrically-powered motorcycles” to “motorcycles or cycles with an electric motor,” effective August 6, 2026. Importers whose goods are classified under that tariff item should review their classification database, product descriptions and broker instructions so the revised wording is reflected in commercial documentation. Customs Notice 26-21

Changes that affect records, warehouses and regulated products

Use the current CARM and CAD terminology in verification files

Memorandum D11-6-8 was revised September 9, 2026 to replace references to the former B3-3 Canada Customs Coding Form and B2 adjustment request with the Commercial Accounting Declaration following CARM Release 3. The revision concerns CBSA verification procedures involving origin, tariff classification and value for duty. Importers subject to a verification should align internal records and broker correspondence with the CAD/CARM framework rather than relying on obsolete form names. Memorandum D11-6-8

Check warehouse and product-specific procedures

Memorandum D4-1-4 was updated July 6, 2026 to include Customs Sufferance Warehouse Enrolment Form BSF897. Applicants and licensed operators of sufferance warehouses should review the revised enrolment process when applying for, amending or managing a licence. This is directly relevant to warehouse and freight-forwarding operations serving GTA distribution networks. Memorandum D4-1-4

Memorandum D19-6-3 was revised July 24, 2026 for changes arising from Amendment 18 to the Energy Efficiency Regulations. Commercial importers of regulated energy-using products should review whether products are newly regulated or have updated information requirements, and whether the required data is supplied through the Integrated Import Declaration or Single Window process. Memorandum D19-6-3

Memorandum D10-15-15 was revised August 14, 2026 and consolidated the earlier D10-15-15 and D10-15-21 guidance concerning tariff items 9958.00.00 and 9959.00.00. Importers of automotive parts, accessories and materials should review the eligibility, exclusions and actual end-use substantiation requirements described in the consolidated guidance. Memorandum D10-15-15

What to discuss with the customs broker

  • Which SKUs, origins and shipment dates fall within each notice’s scope?
  • Which CAD field, tariff-treatment code, surtax code or excise code applies?
  • What transportation, cargo, origin or end-use records support an exception or preferential treatment?
  • Which ERP, product-master, classification and broker-instruction changes have been tested?
  • Does a warehouse, Single Window or Integrated Import Declaration process require a separate update?

For importers distributing through Mississauga, Brampton or Toronto, the review should be assigned by process rather than by notice title: product data to classification, origin evidence to trade compliance, CAD coding to accounting, and warehouse forms to the licensed-warehouse team. That division makes it easier to identify an unreviewed change before the next shipment is accounted for.

This article is general information, not advice for a specific transaction. Importers should discuss the application of each notice, memorandum and tariff measure with their customs broker before changing declarations or internal controls.

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Frequently asked questions

Which 2026 CBSA change should importers review first?+

Importers should first review changes tied to an upcoming or already active accounting date, including the September 8, 2026 U.S.-origin surtax and the July 31, 2026 wood-cabinet safeguard. The applicable CARM field, code, scope and supporting records should be confirmed with the customs broker.

Is the wood-cabinet safeguard declared like an ordinary surtax?+

No. Customs Notice 26-17 states that the safeguard amount is declared in the CAD “Safeguard” field using code 26169A, rather than the ordinary surtax field, subject to the notice’s scope and exclusions.

Does CPUKT treatment make every U.K. import duty-free?+

No. Eligible U.K., Channel Islands and Isle of Man goods may use CPUKT tariff treatment code 35 from September 1, 2026, but the applicable origin and tariff-treatment requirements still need to be met and the relevant rate confirmed.

What changed in D11-6-8?+

The September 9, 2026 revision replaced references to the former B3-3 and B2 terminology with the Commercial Accounting Declaration and CARM framework for the verification procedures covered by the memorandum.

This article was reviewed by our licensed customs team before publication. It is general information, not customs or legal advice — regulations change, and your circumstances may differ. Talk to a broker before acting on it.

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