CBSA’s current trade compliance verification priorities point to a common control problem: an importer may have the correct commercial documents but still lack the evidence needed to support surtax treatment, tariff classification, origin, value for duty or quota status. The emphasis is national rather than GTA-specific, but it is directly relevant to importers operating warehouses, purchasing functions and distribution networks in Brampton, Toronto and Mississauga.
What CBSA’s verification priorities now emphasize
The CBSA trade compliance verification page was updated on July 7, 2026. Its active priorities include the Steel Goods and Aluminum Goods Surtax Order, particularly goods containing steel melted and poured in China or aluminum smelted and cast in China where an applicable surtax may not have been declared. The page also identifies the separate order imposing a surtax on certain steel goods, including goods subject to tariff-rate-quota measures where imports exceed the applicable quota and the related surtax may not have been declared. CBSA trade compliance verification priorities
These steel-related priorities were initiated in April 2026 and remain part of CBSA’s risk-selection process. The same priority page identifies other existing areas, including U.S. surtaxes, Chinese electric vehicles, Chinese steel and aluminum, motor vehicles, steel derivatives, supply-managed goods, energy commodities, GST exemptions, vaping products, precious metals and certain preferential-origin programs. CBSA trade compliance verification priorities
The practical point is not that every importer in these sectors will be selected. It is that a product file should explain the complete duty treatment, including why a surtax does or does not apply. Classification and origin records that were adequate before a surtax measure may not be adequate when the result also depends on melt-and-pour, smelt-and-cast, quota or other product-specific facts.
The three verification questions that deserve separate evidence
1. Does the tariff item produce the correct surtax result?
For each affected product, the importer should be able to connect the commercial description to the tariff classification and then to the applicable surtax treatment. This is particularly important for steel and aluminum products with China-related production information and for steel products subject to quota-related measures. The CBSA priority page reports targeted verification activity for both steel-related areas, but it does not create a separate GTA priority list. CBSA trade compliance verification priorities
A useful internal review separates three questions rather than treating “steel” or “aluminum” as the conclusion:
- What is the complete product and tariff classification?
- What production, origin or quota facts determine the measure?
- How was the resulting surtax treatment reflected in the accounting record?
Where the answer depends on supplier information, the file should identify the supplier, product scope and period covered by that information. A general country-of-shipment statement may not answer a question about where steel was melted and poured or where aluminum was smelted and cast.
2. Can the importer substantiate U.S.-origin treatment?
The United States Surtax Order (2026) took effect on September 8, 2026. The related Customs Notice dated September 7, 2026 states that specified U.S.-origin goods are subject to surtaxes of 15%, 25% or 50%, depending on the tariff item. The measure can apply where goods are shipped to Canada through another country, and certain Chapter 98 and Chapter 99 goods are exempt unless specifically listed. Customs Notice 26-23
CBSA’s notice says affected goods may be examined at importation and subjected to post-release verification of tariff classification, valuation, origin and other applicable requirements. It also states that errors can result in additional surtax, customs duties, taxes, penalties and interest. Customs Notice 26-23
For a U.S.-sourced product, the evidence package should therefore be broader than a freight route or vendor address. Importers should discuss with their broker how to retain support for:
- U.S. origin;
- tariff classification;
- value for duty;
- the applicable surtax rate; and
- any remission, drawback or Duties Relief claim.
The official notice also states that the measure applies to shipments below ordinary de minimis thresholds, subject to the specific rules in the Order. That makes it important to review small commercial shipments separately instead of assuming their value removes them from the analysis. Customs Notice 26-23
3. Can the record be produced through the CARM accounting framework?
On September 9, 2026, CBSA revised Memorandum D11-6-8, which covers verifications of non-free-trade-agreement origin, tariff classification and value for duty. The revision reflects CARM Release 3 and the replacement of the former B3-3 Canada Customs Coding Form and B2 adjustment request with the Commercial Accounting Declaration, or CAD. Memorandum D11-6-8
The revised memorandum states that CBSA may use questionnaires, verification visits, CADs, product information, analysis and other information available to the Agency. It also states that CBSA can reassess classification, origin or value for duty within the applicable statutory period. Memorandum D11-6-8
This makes record naming and retrieval an operational issue. An importer whose procedures still refer only to legacy B3 or B2 workflows should discuss how those references map to current CAD records. The objective is not to recreate a former form; it is to ensure that the accounting declaration, commercial documents, product data and adjustment history can be connected for the same transaction.
A practical preparation file for GTA importers
Importers with purchasing, receiving and customs records spread across Toronto, Mississauga or Brampton may want to organize a verification file by product family and accounting period. The file should allow a reviewer to move from the imported item to the entry, then from the entry to the supporting evidence.
| Control area | Evidence to discuss with the broker |
|---|---|
| Classification | Product specifications, composition, technical descriptions and the classification rationale |
| Origin | Supplier origin records and, where relevant, production information for the applicable measure |
| Steel and aluminum measures | Evidence addressing melt-and-pour or smelt-and-cast facts, where those facts determine treatment |
| Quota-related steel | Records supporting quota status and the surtax treatment used when applicable |
| Valuation | Commercial invoices, assists, adjustments and other information supporting value for duty |
| Accounting | CAD records, corrections and the link between the accounting declaration and shipment documents |
This is a control structure, not a substitute for reviewing the tariff item and the applicable order. The source materials identify the verification subjects and available verification methods; they do not establish that every listed document is required in every transaction. Importers should confirm the appropriate evidence for their goods with their customs broker.
What to ask the broker before a verification notice
A focused review is generally more useful than a broad request to “check compliance.” Importers can ask their broker to identify products where the duty result depends on a fact that is not currently captured in the master product record. They can also ask whether the current process distinguishes shipment country from origin and whether the tariff classification, value for duty and surtax code are reviewed together.
For U.S.-origin goods covered by the 2026 order, the review should also address whether the importer can substantiate the claimed origin, classification, value and surtax rate, as well as any relief claim. Customs Notice 26-23 For steel and aluminum, the discussion should address whether supplier declarations contain the production facts relevant to the measure rather than only a shipping origin. CBSA trade compliance verification priorities
Finally, importers should confirm how a questionnaire or verification visit would be handled under the revised D11-6-8 framework and how records are retrieved from CARM. Memorandum D11-6-8 Preparing that evidence before a request arrives gives the importer a clearer way to identify a genuine data gap, a classification issue or an accounting correction.
Bottom line
CBSA has not announced a separate Brampton, Toronto or Mississauga verification priority. The relevant change for GTA importers is a national, risk-based emphasis on whether the declared surtax result can be supported by classification, origin, value for duty, quota status and current accounting records. Importers should review those elements as one connected control before a post-release verification, questionnaire or visit requires the evidence.