CBSA D-Memorandum Revisions and Customs Notices: What Canadian Importers Should Review

Recent CBSA publications affect how importers handle surtaxes, vehicles, tariff-rate quotas, rail in-transit cargo, regulated products and CARM coding. This review separates new measures from policy clarifications and D-Memorandum revisions, with practical questions to discuss with a customs broker.

CBSA UpdatesSeptember 12, 20266 min readBy LogisticNorth Editorial Team
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Recent CBSA customs notices and D-Memorandum revisions create several separate review points for Canadian importers. The changes do not all operate the same way: some introduce or explain surtax treatment, some revise guidance for regulated goods, and others clarify documentation or coding procedures. Importers clearing freight through Toronto, Mississauga and other Ontario trade channels should identify which publications match their products and transportation arrangements rather than treating every notice as a general change to customs processing.

Start by separating effective dates from revision dates

A customs notice may identify an effective date for a measure. A D-Memorandum page may instead show a revision or publication date without stating a separate legal effective date. That distinction matters when deciding whether an entry, shipment or internal procedure requires immediate review.

  • September 8, 2026: Customs Notice 26-23 provides operating instructions for new surtaxes on specified U.S.-origin goods. The notice identifies surtax rates of 15%, 25% or 50% of value for duty, depending on the covered goods. CBSA Customs Notice 26-23
  • July 31, 2026: Customs Notice 26-17 identifies a 25% provisional safeguard surtax on specified wood cabinets, vanities and subassemblies. The notice was updated on August 5, 2026. CBSA Customs Notice 26-17
  • July 24, August 14, September 2 and other dates: the D-Memorandum pages identify revisions to guidance, but the materials summarized here do not state separate legal effective dates for those revisions.

For an internal compliance review, record the publication or revision date, the affected tariff items or product category, the relevant accounting process and any documents that support the treatment. That record helps distinguish an actual new charge from a clarification of an existing process.

Customs notices requiring product or shipment-level review

U.S.-origin goods subject to new surtaxes

Customs Notice 26-23 provides instructions for the United States Surtax Order (2026). Covered U.S.-origin commercial or casual goods may be subject to surtax at 15%, 25% or 50% of value for duty. The notice states that the measure can apply where goods are shipped through another country, to courier shipments and to goods below normal de minimis thresholds. Importers may therefore need to review origin and routing records together, rather than relying only on the country of shipment.

Where the goods are covered, the applicable surtax is declared in the Commercial Accounting Declaration through CARM, EDI or API. Importers should discuss with their broker how the affected goods will be identified in the accounting workflow and what evidence will be retained for goods already in transit when the surtax came into force. The operating instructions are in Customs Notice 26-23.

Wood cabinets, vanities and subassemblies

Customs Notice 26-17 concerns specified wood cabinets, vanities and subassemblies and identifies a 25% provisional safeguard surtax effective July 31, 2026. The notice directs attention to tariff classification, origin, valuation and possible CUSMA-related relief. Businesses supplying Ontario construction, renovation, kitchen or bathroom markets should review product descriptions and supplier documentation against the covered goods before assuming that all wood cabinetry is treated alike. See Customs Notice 26-17.

Tariff-rate-quota goods in bonded warehouses

Customs Notice 26-20 clarifies that tariff-rate-quota goods entering a customs bonded warehouse require a shipment-specific Global Affairs Canada import permit to receive the within-access duty rate. CBSA describes this as a clarification of existing policy, not a policy change. The notice is dated August 21, 2026.

Importers, carriers and warehouse operators handling quota goods should confirm who obtains and supplies the shipment-specific permit, and at what point the permit is matched to the warehouse movement and eventual accounting. This is relevant to bonded warehousing and distribution operations around Mississauga and the wider Southern Ontario freight network. See Customs Notice 26-20.

Rail cargo moving Canada–United States–Canada

Customs Notice 26-16 addresses domestic Canadian cargo moving through the United States by rail. The notice states that rail carriers use the appropriate ACI/eManifest reporting process or, alternatively, a completed BSF708 Rail in Transit Manifest, together with the required in-transit exception code and sealed railcars. It is dated July 10, 2026 and was updated July 24, 2026; no separate future effective date is stated.

Importers using rail corridors that connect Ontario, the United States and Western Canada should ask their carrier or freight forwarder how the reporting method, exception code and sealing requirements are documented. A problem in the carrier’s reporting can affect cargo moving through the supply chain even where the importer is not the party submitting the rail report. See Customs Notice 26-16.

D-Memorandum revisions to match against product files

PublicationRevision dateImporter review point
D19-12-1, Importation of VehiclesSeptember 2, 2026Vehicle regulatory status, original design intent, modified and foreign-market vehicles, trailers and restricted-use vehicles
D19-6-3, Importation of Energy-using ProductsJuly 24, 2026Products subject to the Energy Efficiency Act, Energy Efficiency Regulations, 2016 and Natural Resources Canada requirements
D19-10-2, Export and Import Permits Act, importationsJuly 13, 2026Controlled goods, import permits and tariff-rate-quota regimes
D19-2-1, Nuclear Safety and Control ActAugust 14, 2026Nuclear substances, prescribed equipment and other goods subject to Canadian Nuclear Safety Commission controls
D10-15-15, Tariff Item 9959.00.00August 14, 2026Whether existing classification and tariff-relief claims remain supported by the revised interpretation
D18-5-1, Excise and GST exemption coding in CARMJune 30, 2026Exemption-code treatment for goods subject to excise duty or GST exemptions

The vehicle revision covers regulated and non-regulated vehicles, work and agricultural vehicles, restricted-use vehicles, modified vehicles and foreign-market vehicles. A dealer or equipment distributor in the GTA should compare the revised guidance with product specifications and any existing import process before the next shipment. See D19-12-1.

The energy-using-products revision supersedes the October 9, 2025 version and explains CBSA administration of import requirements under the Energy Efficiency Act and Energy Efficiency Regulations, 2016. Appliance, HVAC, electrical-equipment and building-supply importers should review whether their product files contain the information needed for the applicable Natural Resources Canada requirements. See D19-6-3.

The D19-10-2 revision concerns CBSA administration of import requirements under the Export and Import Permits Act. It is relevant to controlled agricultural, steel, aluminum and other quota-managed goods. The D19-2-1 revision concerns import administration under the Nuclear Safety and Control Act and is relevant to specialized industrial, medical, research and energy-sector shipments. Both revisions are listed in the CBSA D19 memorandum index.

D10-15-15 concerns the interpretation of tariff item 9959.00.00. Its effect depends on the goods’ classification and the conditions for the specific relief. Importers relying on that tariff item should compare the revised memorandum with their existing classifications and rulings rather than assuming the relief applies unchanged. See the CBSA D10 memorandum index.

D18-5-1 concerns coding of excise-duty and GST exemption codes in CARM. Importers accounting for alcohol, tobacco and other excise-related goods, and brokers filing Commercial Accounting Declarations on their behalf, should review the exemption-code logic used in their accounting instructions. See the CBSA D18 memorandum index.

Questions to take to the customs broker

  1. Which product SKUs, tariff classifications or origins fall within the new surtax notices?
  2. For goods already in transit, what evidence supports the applicable treatment under the U.S.-origin surtax instructions?
  3. For cabinetry and subassemblies, has the classification, origin, valuation and possible CUSMA treatment been reviewed?
  4. For quota goods entering a bonded warehouse, who is responsible for the shipment-specific Global Affairs Canada permit?
  5. For rail cargo moving through the United States, which party confirms the ACI/eManifest or BSF708 process and the required exception code?
  6. Do vehicle, energy-using-product, controlled-goods, nuclear, tariff-relief or CARM exemption files need updating?

These publications should be treated as targeted review triggers, not as one combined customs change. Importers should preserve the source notice or memorandum version used in their decision, document the affected goods and discuss any classification, origin, permit, valuation or CARM-coding uncertainty with their customs broker before accounting for the next shipment.

Frequently asked questions

Do all D-Memorandum revisions have a separate effective date?+

Not necessarily. The revisions summarized here are identified by CBSA publication or revision dates, and the source materials do not state a separate legal effective date for those D-Memorandum changes. Importers should distinguish that date from the effective date stated in a customs notice.

Which recent customs notice introduced new surtaxes on U.S.-origin goods?+

Customs Notice 26-23 provides operating instructions for specified U.S.-origin goods subject to surtax at 15%, 25% or 50% of value for duty, effective September 8, 2026.

What permit issue applies to tariff-rate-quota goods entering a bonded warehouse?+

Customs Notice 26-20 states that goods subject to tariff-rate quotas require a shipment-specific Global Affairs Canada import permit to receive the within-access duty rate. CBSA describes the notice as a clarification of existing policy.

Which importers should review D18-5-1?+

Importers and customs brokers handling goods subject to excise duty or GST exemptions should review D18-5-1 because it concerns exemption-code treatment in CARM, including for alcohol, tobacco and other excise-related goods.

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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