Recent CBSA D-Memorandums and Customs Notices affect different parts of an import transaction. Some change the amount accounted for at the tariff line. Others change the evidence needed to support origin or end use, the information submitted through CARM or the Single Window Initiative, or the controls used by a carrier or warehouse. Treating every revision as a general “customs update” makes it harder to identify the records that actually need attention.
For importers in Toronto, Mississauga and Brampton, the practical question is not only whether a notice applies. It is which operational record should be reviewed: the Commercial Accounting Declaration, the tariff database, the origin file, the permit file, the warehouse instructions or the carrier’s transit data.
Start by identifying the type of change
A D-Memorandum or Customs Notice can affect at least five separate control points. The recent publications provide useful examples of each:
| Control point | Recent example | Primary file to review |
|---|---|---|
| Accounting and duty calculation | Excise and GST coding, surtaxes and tariff treatment | CAD data, tariff line and accounting instructions |
| Classification and end use | Trailer classification and automotive-part provisions | Technical specifications and end-use evidence |
| Origin and preferential treatment | UK CPTPP treatment and U.S.-origin surtaxes | Origin records and supplier declarations |
| Regulated-product data | Energy-using products under SWI/IID | Product data and agency information |
| Movement and custody | Rail in-transit reporting and sufferance-warehouse procedures | Carrier, facility and release instructions |
This classification matters because a tariff review will not resolve a missing permit, and a broker’s accounting correction will not replace evidence supporting a product’s origin or end use.
Changes that can alter the accounting line
Surtaxes and preferential tariff treatment
Customs Notice 26-17 implemented a provisional 25% surtax on specified wood cabinets, vanities and subassemblies, based on value for duty, effective July 31, 2026. The measure can remain in place for up to 200 days, subject to the Canadian International Trade Tribunal inquiry and later developments. Importers of covered goods generally need to confirm both classification and the surtax treatment in CARM accounting.
CBSA Customs Notice 26-17 is the source for the rate, effective date and covered goods. For importers supplying renovation, kitchen or bathroom channels through GTA distribution facilities, the broker discussion should focus on SKU-level descriptions, tariff classification and the value-for-duty data used on affected declarations.
Customs Notice 26-22 advised that eligible UK-origin goods may receive the Comprehensive and Progressive United Kingdom Tariff, code 35, after the CPTPP entered into force for the United Kingdom. The effective date reported in the notice is September 1, 2026. Preferential treatment remains dependent on applicable origin and documentation rules, so an importer may need to review supplier origin support rather than simply change a tariff code.
For U.S. supply chains, Customs Notice 26-23 describes surtaxes of 15%, 25% or 50% on specified U.S.-origin goods, effective September 8, 2026. The notice states that origin is determined under CUSMA-country marking-origin rules, not merely by the country from which the goods were shipped. Importers should therefore discuss manufacturing origin, product scope and supplier records with their broker before relying on a shipment’s export location.
Excise and GST coding
CBSA revised D18-5-1 on June 30, 2026, to reflect the temporary federal fuel-excise-tax suspension and broader CARM coding changes. The memorandum includes revised excise and GST exemption codes, new or consolidated codes for certain luxury vehicles and cannabis products, code removals and added CARM validations. The stated affected sectors include fuel, luxury vehicles, cannabis, alcohol, tobacco and other excisable goods.
The relevant review is the accounting configuration behind the CAD: product coding, exemption logic, tax treatment and validation results. The D18-5-1 memorandum should be used when discussing whether an existing broker instruction or internal product master needs revision.
Changes that affect classification or supporting evidence
D10-14-24, revised July 9, 2026, states that non-commercial snowmobile, utility and boat trailers are excluded from tariff item 8716.39.30 and properly classified under 8716.39.90. Importers of recreational, powersports or marine equipment should review technical descriptions and prior classification decisions rather than relying only on a product family name. The official source is D10-14-24.
D10-15-15 was revised August 14, 2026, by merging guidance for tariff items 9958.00.00 and 9959.00.00. The memorandum states that importers claiming the duty-free provisions must be able to substantiate the actual end use of the parts, accessories or articles. That makes the manufacturing connection part of the customs file: purchase descriptions alone may not be enough to demonstrate the qualifying use. Automotive manufacturers and parts suppliers in the Ontario supply chain should identify who maintains that evidence and how it can be retrieved.
These are classification-and-evidence changes, not simply rate changes. A broker may be able to classify a product from a technical sheet, but the importer generally remains the party best positioned to explain how the goods are used in production or distribution.
Changes that affect regulated data, facilities and transport
Product data and verification
CBSA revised D19-6-3 on July 24, 2026, to reflect Amendment 18 to the Energy Efficiency Regulations and update product and information requirements submitted through the Single Window Initiative’s Integrated Import Declaration. Commercial importers of regulated energy-using products should review whether the product information supplied to the broker is complete and aligned with the SWI/IID process. The source is D19-6-3.
D11-6-8 was revised September 9, 2026, to reflect CARM Release 3 and the replacement of Forms B3-3 and B2 with the Commercial Accounting Declaration. It covers verification of non-free-trade-agreement origin, tariff classification and value for duty. Importers subject to verification should be prepared for records and submissions to be organized around CAD data and CARM processes. The official memorandum is D11-6-8.
Warehouse and movement controls
D4-1-4 was revised July 6, 2026, to add the Customs Sufferance Warehouse Enrolment Form BSF897 and clarify application procedures, CARM Client Portal submission, licensing responsibilities and the service standard. The memorandum states that CBSA aims to decide complete applications within 60 business days. This is primarily a facility-control issue, but it matters to importers when cargo is held pending release or examination at air, highway or rail facilities serving Pearson and the GTA. The source is D4-1-4.
Customs Notice 26-16 clarified rail in-transit reporting, including Canada–United States–Canada movements. The notice describes reporting at the first port of arrival using ACI/eManifest data or, under the paper alternative, a completed BSF708 Rail in Transit Manifest; it also refers to the “08 In-transit” exception code and sealed railcars. Rail carriers have the direct reporting role, but importers and forwarders should confirm that routing instructions and shipment data support the carrier’s process. The notice is available at Customs Notice 26-16.
What to bring to the broker review
A focused review is more useful than sending a general request to “check the latest CBSA changes.” Importers should identify affected products, routes and facilities, then ask the broker to confirm:
- whether the tariff item, origin treatment or surtax treatment has changed;
- which supplier, manufacturing or end-use records support the proposed treatment;
- whether product data must be updated for CARM or SWI/IID;
- whether existing accounting instructions contain obsolete excise, GST or exemption codes; and
- whether a carrier or sufferance-warehouse process requires updated shipment information.
The objective is to connect each publication to the record it governs. That approach helps a Toronto importer distinguish a classification issue from an origin issue, and helps a Mississauga or Brampton distribution operation distinguish an accounting change from a custody or transit-control issue. The cited CBSA memorandum or notice should remain the controlling reference for the specific goods and transaction under review.