D19-10-2 Revised: What Aluminum Importers Using GIP 83 Should Change in Their Canadian Customs Workflow

CBSA revised D19-10-2, Administration of the Export and Import Permits Act (Importations), on October 16, 2026. The revision adds information about aluminum imported under General Import Permit 83 and replaces references to the former Single Window Initiative with the term Customs Single Window. For importers, the immediate issue is not a new general aluminum duty. It is whether the shipment data and broker instructions identify covered aluminum correctly and carry the required permit reference through the accounting process.

What the D19-10-2 revision changes

D19-10-2 applies to the administration of import permits for goods controlled under the Import Control List, including agricultural products, steel, aluminum, textiles and clothing. The October 16 revision adds information for aluminum imported under General Import Permit 83. The official memorandum does not state a separate future coming-into-force date for this revision; the requirements described apply to the relevant import transactions. CBSA D19-10-2

For item-83 aluminum, the importer or broker should account for the required identifier in the customs data associated with the import. For a C-type Canada Customs Coding Form, the reference is cited in field 81 as:

GIP83-OIC19-1224

For users transmitting through Customs Single Window, the information goes in the specified permit field with qualifier 8. The exact handling therefore depends on the accounting channel used for the shipment, but the control point is the same: the transaction needs to carry the information associated with General Import Permit 83. CBSA D19-10-2

Why this is a workflow issue rather than a tariff-classification update

The revision concerns administration under the Export and Import Permits Act. It does not, based on the information in the revised memorandum, announce a new general customs duty or tariff classification for aluminum. That distinction matters because a classification review and a permit-data review are different control activities.

• Classification review: confirms the tariff item and product description used for the goods.
• Permit review: determines whether the goods are controlled and whether the appropriate permit or general-permit reference is represented in the customs transaction.
• Accounting review: confirms that the information reaches the relevant field in the C-type CAD or Customs Single Window transmission.

An importer can have a correct commercial invoice and a defensible tariff classification while still creating a processing problem if the permit information is absent, incomplete or sent through the wrong data path. Importers should therefore discuss D19-10-2 with their broker as a data-mapping and transaction-control question, not only as a product-classification question.

Which shipments deserve an immediate review

Aluminum purchased from recurring suppliers

Recurring supply does not remove the need to identify the products covered by the revised process. Manufacturers and distributors should review item-83 aluminum lines in supplier catalogues, purchase orders and commercial-invoice templates. This is particularly relevant to Ontario businesses receiving aluminum for automotive, construction, packaging, machinery or fabricated-metal operations.

A practical review can begin with the product master: identify the aluminum items that may be imported under GIP 83, then confirm that the customs instructions supplied to the broker distinguish those items from other metals or non-controlled goods. The purpose is to prevent a blanket instruction from being applied to products that require different treatment.

Shipments using different accounting channels

Importers using C-type CADs should confirm how the GIP 83 reference is supplied for field 81. Importers using Customs Single Window should confirm that the permit information is transmitted in the specified permit field with qualifier 8. Businesses that use more than one broker, filing process or import stream should not assume that a control working in one channel automatically works in another. CBSA D19-10-2

For a company receiving aluminum into a Mississauga or Brampton warehouse and distributing it to production or customers elsewhere in Ontario, the physical destination does not replace the transaction review. The key question is whether the import entry for the covered goods carries the required information before the shipment is accounted for.

Mixed shipments and product descriptions

Mixed loads can create a handoff risk when the commercial invoice groups several metal products under a broad description. Importers should discuss whether the invoice, packing list and broker instructions identify the relevant aluminum goods sufficiently for the permit workflow. A broad description may be commercially understandable but still require clarification before the broker can determine how the line should be handled.

Questions to take to the customs broker

The revised memorandum is best converted into a short set of shipment-level questions:

1. Which of our products are being treated as aluminum imported under GIP 83?
2. For those products, will the C-type CAD identify GIP83-OIC19-1224 in field 81?
3. If the shipment uses Customs Single Window, where will the permit information and qualifier 8 be transmitted?
4. What information must appear on the commercial invoice or broker instruction for mixed or recurring shipments?
5. How will our team know when a new product, supplier or tariff line needs a permit-workflow review?
6. Can our import records show which product lines were assessed for the GIP 83 treatment?

These questions help separate responsibilities. The importer generally controls product information, origin and supplier documentation. The broker generally uses that information to prepare and transmit the customs accounting data. Both sides benefit when the product-level instruction is agreed before cargo arrives at a GTA facility, Pearson-area gateway or other Canadian port.

Do not confuse this revision with other 2026 D-memo changes

Other 2026 revisions have different operational effects. D10-15-15 consolidated earlier guidance on qualifying vehicle parts, accessories and materials under tariff items 9958.00.00 and 9959.00.00; the change is principally a consolidation and clarification rather than a newly imposed duty. D19-12-1 updated the definition of “temporary residents” for vehicle importation. D19-4-1 updated the Greater Toronto Area Region’s postal code for cultural-property administration. CBSA D10-15-15 CBSA D19-12-1 CBSA D19-4-1

That comparison is useful because not every D-memorandum revision requires the same response. For D19-10-2, the sensible first action is to test the permit-data handoff for affected aluminum transactions. Importers should ask their broker to confirm how GIP 83 information is captured, transmitted and retained for the relevant entries.