CBSA revised D11-6-8: Verification of Origin, Tariff Classification, and Value for Duty on September 9, 2026. The revision updates references to CARM Release 3 and the Commercial Accounting Declaration (CAD), which replaces Forms B3-3 and B2. For commercial importers, the practical change is a records problem: the information supporting the CAD should be traceable to the documents, decisions and corrections behind the shipment.
What the D11-6-8 revision changes
The revised memorandum addresses CBSA verifications of non-free-trade-agreement origin, tariff classification and value for duty. It also updates the document references used after CARM Release 3, including the replacement of the B3-3 and B2 forms by the CAD. The revision date is September 9, 2026; the memorandum does not state a separate future coming-into-force date. CBSA D11-6-8
This does not create a new tariff rate or a new origin agreement. It changes the CARM-era reference point for verification work. The memorandum is most relevant when CBSA reviews an importer’s origin, classification, value for duty, books and records, corrections or reassessments. CBSA D11-6-8
What a usable verification file should connect
Importers should discuss with their broker how each commercial entry can be connected to four evidence streams. The exact record set will vary by transaction, but the file should be organized around the issues CBSA may verify rather than around a single invoice.
Origin
For non-free-trade-agreement origin, the file should preserve the information used to determine where the goods originate and how that conclusion supports the CAD record. This becomes particularly important where goods move through a distribution hub or where the supplier country differs from the country of manufacture.
For example, the United Kingdom received eligibility for the Comprehensive and Progressive United Kingdom Tariff treatment, identified by tariff treatment code 35, effective September 1, 2026. Importers using that treatment should review the origin documentation and any existing advance rulings with their broker. Customs Notice 26-22
Tariff classification
The classification record should show the product description, technical information and reasoning used for the tariff item. A product description copied from a commercial invoice may not be enough to explain why a classification was selected during a verification.
Importers of lithium-ion batteries and related goods should also account for the amended description of tariff item 8507.60.20. The wording changed effective August 6, 2026, replacing “electrically-powered motorcycles” with “motorcycles or cycles with an electric motor.” Importers with classification rulings should discuss whether the revised wording affects their files. Customs Notice 26-21
Value for duty
The valuation file should support the amount reported on the CAD and preserve the commercial documents used to reach it. Importers should ask their broker whether their current purchase, freight, adjustment and correction records can be reconciled to the accounting declaration without relying on an employee’s memory after the shipment has been released.
Where a transaction involves a surtax, the file should separately identify the rule that applied and any relief or remission position taken. Certain U.S.-origin goods became subject to Canadian surtaxes of 15%, 25% or 50%, depending on the product and tariff classification, effective September 8, 2026. Customs Notice 26-23 was revised on October 23, 2026 and addresses, among other matters, goods in transit, returned goods, Chapter 98 goods and remission or relief claims. Customs Notice 26-23
Corrections and reassessments
A verification file should not end at the original accounting. Importers should be able to identify later corrections, reassessments and the supporting reason for each change. This is especially useful when a classification, origin conclusion or value-for-duty position has changed across multiple shipments.
Operational implications for GTA importers
For businesses in Brampton, Mississauga and Toronto, the relevant question is whether the import record is controlled across purchasing, logistics, customs and finance. A shipment arriving through Pearson or moving into a Peel Region warehouse may pass through several systems before the accounting record is reviewed. The D11-6-8 revision makes it sensible to test whether those systems preserve one consistent transaction history.
- Ask the broker which CAD data corresponds to the commercial invoice, packing information and supporting origin records.
- Identify products whose classification depends on technical specifications, product changes or a tariff-description amendment.
- Separate ordinary duty and tax support from records supporting a surtax, remission or relief claim.
- Confirm who owns post-release corrections and how the revised record is linked to the original shipment.
- Retain the broker instructions and commercial evidence used to support unusual entries, rather than only the final accounting output.
These are file-control steps, not a substitute for a transaction-specific classification, origin or valuation opinion. Importers should ask their broker to identify which records are needed for their products and accounting model.
Related notices that can expose weak records
The D11-6-8 revision should be reviewed alongside notices that change the evidence needed for particular shipments. Three examples are operationally distinct from the memorandum itself.
First, containers imported for sale require their own cargo reporting and accounting; reporting only the container number within the cargo shipment is not sufficient under Customs Notice 26-25, dated October 30, 2026. Businesses that own or sell containers should ensure the cargo record and the accounting record are connected. Customs Notice 26-25
Second, goods subject to a tariff-rate quota and placed in a customs bonded warehouse require the relevant permit to cover the date the goods leave the warehouse for within-access treatment. Where goods entered under a General Import Permit, the Type 10 CAD must first be amended before a Type 20 or 21 ex-warehouse movement can claim within-access treatment. CBSA described this August 21, 2026 notice as a clarification of existing policy. Customs Notice 26-20
Third, importers claiming remission for eligible U.S. surtax goods generally need to make and document the claim, including use of the applicable special authorization code in the CAD. The updated guidance covers eligible uses including Canadian manufacturing and processing, food and beverage packaging, health care, public health, public safety and national security. Customs Notice 25-19
A practical review before the next verification
Start with a small sample of released entries rather than attempting an immediate system-wide reconstruction. Select products with different suppliers, classifications and valuation patterns. For each one, test whether a reviewer can move from the CAD to the invoice, origin evidence, technical description, value calculation, broker instruction and any correction or relief claim.
If the chain breaks, discuss the gap with the broker before the next post-release request. The immediate objective is not to create a larger archive; it is to make the accounting declaration explainable from the underlying commercial record.