CBSA’s July 2026 trade-compliance verification update gives importers a current list of risk areas, but it does not identify a special verification campaign for Ontario or the Greater Toronto Area. The more useful question for an importer in Toronto, Mississauga or Brampton is which products, tariff claims and tax treatments in its own customs population correspond to the published priorities.
What CBSA’s July 2026 update identifies
CBSA refreshed its public verification-priority list on July 7, 2026. The list includes classification of certain supply-managed goods, GST exemption codes, vaping products subject to excise duties and taxes, precious metals, automotive CUSMA origin, short-supply provisions under CETA, CUKTCA and CPTPP, Duties Relief Program licensees importing supply-managed goods, electricity imports under Chapter 27 of the Customs Tariff, and several surtax-related areas. CBSA’s verification-priority page
The published list also identifies China electric-vehicle, steel and aluminum surtaxes, U.S. surtax measures involving steel, aluminum and motor vehicles, and steel and aluminum surtax measures more generally. CBSA records two 2026 verification initiatives already underway: the Steel Goods and Aluminum Goods Surtax Order and the Order imposing a Surtax on the Importation of Certain Steel Goods, both initiated in April 2026. CBSA’s verification-priority page
CBSA states that its targeting is evergreen and may change during the year. The July publication should therefore be treated as a current risk signal, not as a permanent or exhaustive list. CBSA did not publish a line-by-line comparison showing which items were added or removed from the previous update. CBSA’s verification-priority page
How to turn the priority list into an importer review
A broad review of every customs entry is unlikely to be the most efficient starting point. A better approach is to identify the claims that combine a published priority with a material customs consequence. The following triage can help structure a discussion with the customs broker and internal product, purchasing and finance teams.
1. Start with origin and preferential treatment
Importers claiming CUSMA automotive origin, or origin under CETA, CUKTCA or CPTPP short-supply provisions, fall within areas named in the current priority list. The initial review should identify the specific products using those provisions, the supplier or producer information supporting the claim, and whether the documentation corresponds to the goods actually imported.
Automotive importers should separate CUSMA origin files from other preferential-origin files rather than treating all free-trade claims as one category. The applicable agreement and provision matter to the claim, while the commercial file should allow the broker to connect the imported product with the supporting origin information. These are practical review steps based on the verification areas CBSA has published; the priority page does not prescribe a single document format. CBSA’s verification-priority page
2. Isolate goods affected by surtax measures
Steel, aluminum, vehicles, automotive parts and electric vehicles deserve a separate review because the current priority list includes multiple surtax-related areas. For an importer, the key control is not simply whether a product is described commercially as steel, aluminum or automotive. The broker and importer should confirm the tariff classification, origin analysis and measure-specific treatment used for the actual goods.
A further issue applies to specified U.S.-origin goods. Customs Notice 26-23 states that, effective September 8, 2026, certain U.S.-origin goods became subject to Canadian surtaxes of 15%, 25% or 50%, depending on the goods and tariff item. The notice states that the measures can apply to commercial and casual imports, and that goods shipped through another country can remain covered if they originate in the United States. Customs Notice 26-23
For covered shipments, an importer’s review should distinguish the goods’ shipping route from their origin, and should test the tariff item against the applicable schedule. The official notice also identifies classification, valuation, origin and other CBSA-administered requirements as matters that may be examined through post-release verification. Customs Notice 26-23
3. Review tax, excise and specialized product codes
The current priorities include GST exemption codes, vaping products subject to excise duties and taxes, precious metals and electricity imports under Chapter 27. These categories should be reviewed separately from ordinary tariff-classification work because the issue may involve a tax or excise treatment in addition to the tariff item.
For supply-managed goods, CBSA specifically identifies classification of frozen desserts containing dairy products and spent fowl. The priority list also includes Duties Relief Program licensees importing supply-managed goods. An importer handling these products or using the program should consider whether the product description, tariff classification and program-related treatment are being applied consistently across entries. CBSA’s verification-priority page
Why the September D-memorandum matters to the review process
On September 9, 2026, CBSA revised Memorandum D11-6-8, which addresses verification of origin, tariff classification and value for duty. The revision reflects CARM Release 3 and replaces references to Form B3-3, Canada Customs Coding Form, and Form B2, Canada Customs — Adjustment Request, with the Commercial Accounting Declaration, or CAD. Memorandum D11-6-8
The memorandum states that CBSA may use CADs, product information, trade literature, samples and other information during a verification. It also explains that verification results can lead to re-determinations of origin, classification or value for duty. This makes the published priority list relevant to more than the original entry: a broker and importer may need to connect the accounting record with the product and commercial information that supports the customs treatment. Memorandum D11-6-8
What GTA importers should discuss with their broker
The published priorities apply nationally. CBSA has not identified a verification campaign limited to Toronto, Mississauga, Brampton or another GTA location. An importer accounting through Toronto Pearson, using a Mississauga or Brampton warehouse, or moving goods through the broader Ontario distribution network should therefore focus on the goods and claims in its records, not assume that a local facility changes the risk analysis.
- Which products in the current import population match a published priority?
- Which entries use preferential origin, a surtax treatment, a GST exemption code, an excise-related treatment or Duties Relief Program treatment?
- Do the classification, origin and value-for-duty positions remain consistent across suppliers and shipments?
- Can the broker and importer identify the relevant CAD records and connect them to product information, trade literature and other supporting material?
- For U.S.-origin goods, has the team separated origin from the shipping route and checked the applicable tariff schedule?
- Are older internal procedures still using B3 or B2 terminology when the current CARM workflow uses CAD terminology?
These questions do not mean that every importer in a listed sector will be selected for verification. They provide a practical way to rank review work against CBSA’s current public priorities. Importers receiving a questionnaire, verification letter or visit should coordinate the response with their broker and relevant internal record owners, using the applicable CBSA instructions and the facts of the shipment.
Bottom line
The July 2026 update is best used as a screening tool. Begin with products affected by surtaxes, preferential-origin claims, supply-managed classifications and specialized tax or excise treatments. Then confirm that the accounting records, product information and commercial evidence are aligned with the CAD-based CARM process described in revised Memorandum D11-6-8. For U.S.-origin goods covered by the September 8 surtax measures, add a specific review of origin, tariff classification, value for duty and any claimed exception or special tariff treatment. CBSA verification priorities D11-6-8 Customs Notice 26-23