CBSA Trade Compliance Verification Priorities: Build the Evidence Before the Letter

CBSA’s current trade-compliance priorities are a useful risk map, not a complete list of every shipment the agency may review. The page updated on July 7, 2026 identifies priority goods and programs involving surtaxes, preferential origin, supply-managed products, GST exemptions, vaping products, precious metals and electricity. The revised Memorandum D11-6-8, published September 9, 2026, sets out how CBSA verifies non-free-trade-agreement origin, tariff classification and value for duty in the CARM environment. CBSA trade compliance verification priorities Memorandum D11-6-8

What CBSA’s priority list actually signals

The July update does not state that every listed priority began on July 7. It records the date on which the verification page was updated, while noting that some work had started earlier. The steel and aluminum priorities were identified as having been initiated in April 2026, and the electricity priority began in October 2025. The practical point is that the page should be read as an active, changing risk list rather than as a single new tariff measure. CBSA trade compliance verification priorities

The listed areas include:

• Steel and aluminum surtax compliance involving Chinese melt-and-pour or smelt-and-cast content.
• Certain steel goods imported above tariff-rate-quota volumes and subject to 50% surtax treatment.
• U.S. steel and aluminum, motor vehicles and other surtax orders.
• Chinese electric vehicles, steel and aluminum.
• Supply-managed goods, including frozen desserts and spent fowl.
• CUSMA automotive origin.
• CETA, CUKTCA and CPTPP origin.
• GST exemption codes, vaping products and precious metals.
• Electricity imports under Customs Tariff heading 27.16.

CBSA describes more than a traditional completed audit process. Its verification activity can include trade advisory notices, compliance validation letters and directed compliance letters. Importers whose products or accounting treatments fall within one of these areas should therefore organize supporting records before a request arrives, rather than treating the first letter as the beginning of the review. CBSA trade compliance verification priorities

Use the priorities to assign an evidence owner

A priority list becomes operationally useful when each exposure is tied to a person, record set and review question. The relevant question is not simply whether a company imports steel, food or vehicles. It is whether the importer can support the specific origin, classification, value or relief claimed on the Commercial Accounting Declaration.

Origin and surtax records

Importers dealing in steel, aluminum, vehicles or goods claimed under CUSMA, CETA, CUKTCA or CPTPP should identify the records that establish origin for the affected product and transaction. For steel and aluminum subject to the listed Chinese content priority, the internal review should address the available melt-and-pour or smelt-and-cast information. For automotive goods, the relevant file should support the CUSMA origin treatment claimed. These are areas named in CBSA’s current verification priorities; the exact records available will depend on the product and supply chain. CBSA trade compliance verification priorities

Classification and value for duty

Memorandum D11-6-8 states that CBSA verifies tariff classification and value for duty, in addition to non-free-trade-agreement origin. A verification file may involve CADs, product information, trade literature, samples and other information already available to CBSA. Importers receiving a questionnaire or letter should have a controlled method for matching the requested product and accounting information to the underlying commercial records. Memorandum D11-6-8

The memorandum also reflects CARM Release 3 and replaces references to the former B3-3 and B2 forms with the Commercial Accounting Declaration. That makes the CAD the relevant accounting record to identify when reviewing prior transactions and preparing a response. Memorandum D11-6-8

The separate 2026 U.S. surtax check

Importers of covered U.S.-origin goods have an additional accounting question. The United States Surtax Order (2026) and related amendments took effect September 8, 2026. CBSA implementation guidance identifies surtax codes 26186A for 15%, 26186B for 25% and 26186C for 50% for applicable goods. The correct code depends on the covered tariff item and circumstances described in the applicable measures; it should not be selected solely because a shipment was purchased from a U.S. supplier. CBSA Customs Notice 26-23 United States Surtax Order (2026)

The guidance applies to importers using CARM, including accounting through EDI or API. CBSA states that covered goods may be examined and may be subject to post-release verification of tariff classification, valuation, origin and other requirements. Incorrect or omitted surtax declarations can result in reassessments, penalties and interest. CBSA Customs Notice 26-23

For an importer with receiving or distribution operations in Mississauga, Brampton or Toronto, this is best handled as a transaction-level control: identify affected U.S.-origin tariff items, confirm the code used on the CAD, and retain the product and origin information used to reach that result. The issue is not limited to the customs entry team; purchasing, product management and the supplier may hold information needed to support the declaration.

What to discuss with your customs broker

A broker discussion should be organized around the importer’s actual exposure, not the entire priority page. Consider asking for a review of the following items:

1. Which products in the current catalogue correspond to a CBSA priority, including steel, aluminum, vehicles, supply-managed goods, vaping products, precious metals or electricity.
2. Which shipments claim CUSMA, CETA, CUKTCA or CPTPP treatment, and what origin support is available for those claims.
3. Whether the classification and value-for-duty analysis used on the CAD remains supported by current product information and trade literature.
4. Whether U.S.-origin goods imported on or after September 8, 2026 require a surtax review and, if so, which implementation code applies.
5. Who will retrieve CADs and supporting records if CBSA issues a compliance validation letter, directed compliance letter or verification questionnaire.

The revised memorandum says CBSA may re-determine origin, classification or value for duty generally within the statutory reassessment period. An importer should therefore avoid limiting its review to the most recent shipment or to transactions that have already attracted a question. The appropriate period and records will depend on the matter under review. Memorandum D11-6-8

A practical review sequence

Start with a product-to-priority inventory. Next, map each product to its CAD treatment and identify the person who can explain classification, origin and value for duty. Then test a sample of transactions against the supporting documents actually retained, rather than documents that could theoretically be obtained later. For U.S.-origin goods, separately test the September 8 surtax treatment and code where the goods are within scope. CBSA Customs Notice 26-23 Memorandum D11-6-8

CBSA’s priorities may expand or change during the year. Treat the July page as a recurring monitoring source, while treating the CAD and the records supporting it as the transaction-level evidence to be tested. This approach helps an importer distinguish a broad priority announcement from the narrower question CBSA may ask about a particular product, accounting treatment or period. CBSA trade compliance verification priorities