On September 9, 2026, the Canada Border Services Agency revised Memorandum D11-6-8 to reflect CARM Release 3 procedures, including the use of the Commercial Accounting Declaration (CAD) in place of the former B3-3 accounting form and B2 adjustment request. For commercial importers in Toronto, Mississauga and Brampton, the practical issue is terminology and record alignment during verification—not a new CARM implementation date.
What changed in the guidance
The revised memorandum addresses CBSA verification of origin, tariff classification and value for duty. Its references now reflect CARM Release 3 processes and CAD terminology. The update replaces references to the former B3-3 accounting form and B2 adjustment request with the Commercial Accounting Declaration.
Importers and customs brokers can review the revised Memorandum D11-6-8 when preparing for a CBSA verification, responding to a questionnaire, or reviewing a post-release adjustment workflow.
What the update does not change
The September 9 publication is a revision to verification guidance, not a new underlying CARM rule. CARM Release 3 became the official system of record on October 21, 2024. That means the September memorandum update should not be treated as a new effective date for the CARM framework.
There is also no new Ontario- or GTA-specific customs requirement identified in the materials reviewed for this reporting period. The revised guidance is federal and is relevant to commercial importers and their brokers wherever the associated CBSA verification processes apply.
What importers should review now
1. Match internal terminology to current accounting records
Importers who maintain customs procedures, audit checklists or broker instructions using B3-3 or B2 terminology should review those references against current CAD and CARM processes. The aim is to ensure that staff handling customs records describe the accounting and adjustment process consistently.
2. Keep verification files connected to the accounting record
Because the memorandum concerns verification of origin, tariff classification and value for duty, importers should be able to connect the information used in those determinations with the related commercial and customs records. This is particularly relevant when a business is responding to a CBSA verification questionnaire, review or post-release adjustment.
3. Coordinate broker and importer procedures
Where an importer uses a customs broker or another agent, both sides should use the same CAD and CARM terminology in instructions, file notes and review procedures. A mismatch between the importer’s internal language and the broker’s current accounting references can make a file harder to interpret, even when the underlying shipment information is available.
Separate a guidance revision from a new obligation
The distinction matters for planning. A guidance revision can change how CBSA verification material describes an existing process without creating a new tariff, filing deadline or program eligibility rule. Businesses should therefore update their internal references and review workflows, but should not infer a new compliance date solely from the September 9 memorandum revision.
For GTA importers operating from warehouses or offices in Mississauga, Brampton or Toronto, a focused review is usually more useful than a broad redesign: identify obsolete B3-3 and B2 references, confirm that current files use CAD terminology, and ensure that verification-related records can be located through the business’s customs process.
Bottom line
Memorandum D11-6-8 now reflects CARM Release 3 and CAD procedures. Importers who may be subject to CBSA verification should align their documentation language and broker instructions with the revised guidance. The change is procedural and interpretive; it is not a newly effective CARM rule or a GTA-specific border requirement.