D11-6-8 Revised: How Canadian Importers Should Prepare for a CBSA Verification

CBSA revised Memorandum D11-6-8 on September 9, 2026. The memorandum covers verification of non-free-trade-agreement origin, tariff classification and value for duty, and updates its terminology to reflect CARM Release 3 and the Commercial Accounting Declaration (CAD). The revision does not, based on the cited memorandum, create a new tariff rate or a new import program. Its practical effect is that importers should review how their verification files connect product records, broker instructions and CAD accounting data.

What changed in D11-6-8

The revised memorandum replaces references to the former B3 and B2 forms with the CAD. It applies to CBSA verification activity involving non-free-trade-agreement origin, tariff classification and value for duty. The memorandum describes verification activity that can include requests for records, questionnaires, visits, re-determinations and further re-determinations. CBSA Memorandum D11-6-8

For an importer, the important distinction is between a terminology update and a change to the underlying review topics. The revised language does not mean that legacy internal records have no value. It means that those records should be capable of supporting the data reported through the current accounting process, including the CAD.

What the revision does not establish

The cited revision does not state that every commercial importer will receive a verification request, nor does it announce a general reclassification or valuation change. It also does not remove the need to retain commercial evidence supporting the information reported for an import transaction. The precise records relevant to a file depend on the goods, transaction structure and issue under review.

Build the verification file around three questions

Importers preparing for a possible verification should organize records around the three areas identified in D11-6-8 rather than around the document names used before CARM.

1. What is the correct origin?

A file should allow the importer and broker to trace the origin conclusion back to the product and transaction. Depending on the goods and supply chain, that may involve supplier information, manufacturing details, commercial documents and origin support. Importers should distinguish non-preferential origin analysis from any separate preferential tariff claim; D11-6-8 addresses verification of non-free-trade-agreement origin, classification and value for duty. CBSA Memorandum D11-6-8

Where goods move through multiple countries before entering Canada, the internal file should identify which party supplied the origin information and which product facts were relied on. A country shown on an invoice may not, by itself, explain the origin conclusion used for customs purposes. Importers should discuss any multi-country production or supplier changes with their broker before the next accounting.

2. Why was this tariff classification used?

Classification support should connect the tariff item reported on the CAD with the product description, technical characteristics and the importer’s classification rationale. Product descriptions copied from purchase orders may be too general to explain why a particular tariff item was selected.

Importers with large product catalogues should identify products whose specifications, packaging or intended use have changed since the classification was first approved. A classification database can remain internally consistent while the underlying product has changed. That creates a verification risk even if the broker continues to receive the same part number.

3. How was value for duty determined?

The value-for-duty file should explain the transaction value or other valuation basis used for the entry and identify the commercial documents supporting it. Importers should pay particular attention to arrangements involving related parties, assists, royalties, rebates, transfer-pricing adjustments or post-import price changes where those facts may affect the customs analysis.

The objective is not to create a separate document for every possible issue. It is to make the reasoning visible: what was purchased, from whom, under what terms, and how the amount reported for customs purposes was derived.

Reconcile the broker file to the CAD

The D11-6-8 revision makes a terminology check worthwhile. Importers whose procedures still refer only to B3 or B2 should map those internal references to the current CAD process and confirm that staff can identify the corresponding accounting information. CBSA Memorandum D11-6-8

A practical review can compare a sample of completed transactions across four layers:

• the purchase order, commercial invoice and transport documents;
• the product master data and classification instructions;
• the origin and valuation support retained by the importer; and
• the broker’s accounting record and corresponding CAD information in CARM.

Differences do not automatically indicate an error. A broker record may use a shortened description, while the importer’s technical file uses a longer one. The concern is whether the difference prevents the importer from explaining the origin, classification or value-for-duty result reported to CBSA.

Keep ownership clear across the GTA supply chain

Many importers separate responsibilities across locations: a Toronto purchasing or finance team, a Mississauga customs contact and a Brampton warehouse or distribution operation. That structure can make a verification response slower if no one owns the complete file.

Importers should identify one internal owner for each product family or import program and document where the supporting records are held. The broker may hold accounting data and entry instructions, while the importer holds technical specifications, supplier correspondence and valuation information. A workable process should allow those records to be assembled without relying on one employee’s mailbox or a warehouse team’s local files.

What to discuss with your customs broker

The following questions are reasonable agenda items for a broker review:

• Which current CAD information corresponds to the legacy B3 or B2 references in our procedures?
• Can our product descriptions support the tariff classifications used on recent transactions?
• Which origin facts were used for products sourced from more than one country?
• What valuation assumptions were provided for related-party purchases, assists, royalties or price adjustments?
• Which records would the importer provide directly if CBSA sent a questionnaire or requested a verification visit?
• How would corrections, re-determinations or further re-determinations be tracked if a verification identified an issue?

These questions do not replace transaction-specific customs advice. They are intended to expose gaps before a request arrives, particularly where the importer’s commercial, technical and accounting teams use different product descriptions or retain different versions of the same document.

Action plan for importers

1. Inventory current procedures that still use B3 or B2 terminology.
2. Select representative import transactions across major suppliers and product families.
3. Trace each sample from the commercial documents and product data to the broker record and CAD information.
4. Record unresolved questions about non-free-trade-agreement origin, tariff classification or value for duty.
5. Agree with the broker on who will respond to records requests, questionnaires or other verification activity.
6. Update internal work instructions so future product or supplier changes trigger a customs review.

The September 9 revision is therefore best treated as a control and documentation checkpoint. Importers should not assume that a familiar broker entry is a complete verification file. The importer’s records need to explain the customs result, while the CAD terminology and CARM data provide the current accounting reference point.