Recent CBSA publications include changes to commercial verification procedures, rail reporting and the Courier Low Value Shipment program. They should not be treated as one general change to every importer’s customs process. The practical question is who owns the action: the importer, the customs broker, the rail carrier or the authorized courier.
Start by identifying the party named in the change
The revised Memorandum D11-6-8, dated September 9, 2026, directly concerns commercial importers and customs brokers involved in CBSA verifications of origin, tariff classification or value for duty. By contrast, Customs Notice 26-16 addresses rail-carrier reporting for certain Canada–United States–Canada in-transit movements, and Customs Notice 26-24 concerns authorized Courier Low Value Shipment participants.
This distinction matters for change management. An importer may need to update evidence, correction and verification procedures under D11-6-8. The same importer may only need to confirm routing and document handoffs when a shipment moves under the rail process, or confirm service implications when using a courier participating in CLVS. Those are different controls and should be assigned to different internal owners.
Changes that directly affect commercial importers
Verification records now use CAD and CARM terminology
D11-6-8 was revised to reflect CARM Release 3. The memorandum replaces references to the former B3-3 Canada Customs Coding Form and B2 adjustment request with the Commercial Accounting Declaration, or CAD. The revision applies in the context of CBSA verification work involving origin, tariff classification and value for duty. [Official source: Memorandum D11-6-8]
Importers whose transactions may be selected for verification should discuss with their broker how response files, entry records and correction procedures use CAD and CARM terminology. The objective is not simply to rename a document. The importer’s commercial records, broker entry data and supporting evidence should be capable of being connected to the accounting declaration under review.
This is particularly relevant where a company has separate teams for purchasing, tariff classification, accounts payable and customs. A verification response can become difficult to assemble when the shipment file uses legacy B3 or B2 terminology while current accounting and broker records use CAD terminology. The D11-6-8 revision is therefore a records-and-response issue for the importer, not merely a software-label change.
Automotive parts require a product-specific review
Memorandum D10-15-15 was revised on August 14, 2026, consolidating the previous D10-15-15 and D10-15-21 guidance. It clarifies the treatment of parts, accessories and materials used to manufacture or repair certain automobiles, trucks, buses and related vehicles under tariff items 9958.00.00 and 9959.00.00. [Official source: Memorandum D10-15-15]
Commercial importers claiming duty-free treatment under those tariff items should review whether their product descriptions, end-use information and supporting records address the revised and consolidated guidance. Automotive manufacturers and parts suppliers in the broader Ontario manufacturing corridor, including operations connected to Brampton and Toronto distribution networks, may need to coordinate customs classification with engineering and purchasing records.
Changes where the carrier or courier owns the primary action
Canada–United States–Canada rail movements
Customs Notice 26-16 was issued July 10, 2026, and updated July 24, 2026. It clarifies rail-carrier reporting for cargo moving from one Canadian point to another through the United States. The notice identifies the applicable rail in-transit reporting process, including required ACI/eManifest information or the specified BSF708 Rail in Transit Manifest paper process. The notice does not identify a separate later effective date. [Official source: Customs Notice 26-16]
The primary procedural owner is the rail carrier. An importer moving cargo through an Ontario intermodal facility should nevertheless confirm that its carrier, freight forwarder and broker have consistent routing and shipment data. A reporting problem can affect release timing even when the importer did not prepare the rail manifest.
For freight moving toward distribution facilities in Mississauga or Brampton, the relevant control is the handoff: the routing must be communicated accurately, and the parties should know which entity supplies or confirms the in-transit information. Importers should discuss with their broker whether any recurring Canada–United States–Canada lane requires a documented pre-departure data check.
Courier low-value shipments through Pearson
Customs Notice 26-24, effective September 14, 2026, allows authorized Courier Low Value Shipment participants to use third-party air carriers that are not Partners in Protection-certified, provided the other CLVS program conditions remain satisfied. The change applies to authorized couriers operating under the CLVS program, not ordinary importers directly. [Official source: Customs Notice 26-24]
For importers using express services through Pearson-area air-cargo facilities, the immediate issue is service-provider configuration rather than a new importer filing requirement. Courier customers may experience changes in routing or capacity, but the courier remains responsible for meeting the program conditions described in the notice. An importer should ask its courier or broker whether a shipment is moving under CLVS and whether any change affects document timing, routing or expected release handling.
A practical ownership checklist
| Update | Primary party affected | Importer discussion point |
|---|---|---|
| D11-6-8 revision | Commercial importer and broker | Align verification files, corrections and terminology with CAD/CARM records. |
| D10-15-15 revision | Automotive importer and broker | Review eligibility evidence for tariff items 9958.00.00 and 9959.00.00. |
| Customs Notice 26-16 | Rail carrier and parties arranging transit | Confirm routing, ACI/eManifest or BSF708 handoffs for Canada–United States–Canada movements. |
| Customs Notice 26-24 | Authorized CLVS courier | Confirm whether courier routing or capacity changes affect shipment planning. |
The table is a workflow allocation tool, not a substitute for reviewing the applicable memorandum or notice. The same shipment can involve more than one control. For example, an importer may need CAD-aligned records while its carrier separately manages rail reporting.
What importers should review with their broker
- Which recent CBSA publication applies to the importer’s own goods, shipment mode or verification exposure.
- Whether internal files still rely on B3 or B2 terminology where the current verification process refers to CAD.
- Whether automotive parts or materials claimed under tariff items 9958.00.00 or 9959.00.00 have evidence supporting the relevant use and classification.
- Whether recurring rail movements through the United States have a clear carrier and broker data handoff.
- Whether courier shipments through Pearson are using the CLVS program and whether the courier has communicated any operational change.
For GTA businesses, the useful response is not to change every customs procedure at once. It is to identify the responsible party for each update, document the handoff and change only the records or shipment instructions that the applicable CBSA publication actually affects.
Frequently asked questions
Does Customs Notice 26-16 create a new filing for every importer?
The notice describes rail-carrier reporting requirements for Canada–United States–Canada in-transit cargo. Importers can be affected through carrier documentation, routing and release timing, but the primary reporting responsibility described is the rail-carrier process. See Customs Notice 26-16.
Does the CLVS change apply to ordinary courier customers?
Customs Notice 26-24 applies to authorized couriers operating under the CLVS program. Ordinary importers are not directly made CLVS participants by the notice, although courier customers may experience routing or capacity effects. See Customs Notice 26-24.
What is the most direct importer action under D11-6-8?
Importers involved in CBSA verifications should discuss with their broker how records, verification responses and correction processes align with CAD and CARM terminology rather than legacy B3 and B2 references. See Memorandum D11-6-8.
Who should review the automotive memorandum?
Commercial importers of automotive parts, accessories and manufacturing materials claiming duty-free treatment under tariff items 9958.00.00 and 9959.00.00 should review the consolidated guidance with their broker and relevant technical or purchasing teams. See Memorandum D10-15-15.