Canadian importers face two different customs review points following CBSA updates published on October 16 and October 23, 2026. The first concerns smelt-and-cast information for aluminum imported under General Import Permit No. 83. The second clarifies when Chapter 98 or 99 tariff treatment does—or does not—remove goods from the United States Surtax Order (2026). Neither update creates a GTA-specific border rule, but both can affect commercial shipments accounted for by importers in Mississauga, Brampton and Toronto.
What changed in the October updates
The revised CBSA Memorandum D19-10-2, published October 16, documents reporting requirements that took effect October 1, 2026 for covered aluminum goods imported under GIP 83. Where the goods contain primary aluminum, the importer generally needs to provide the country of largest smelt and, where applicable, the country of second-largest smelt. For all covered aluminum goods, the country of most recent cast is required.
The same memorandum identifies exemptions for CSA importers and certain low-value shipments. Importers and brokers handling aluminum through the Customs Single Window Integrated Import Declaration should therefore confirm whether a shipment falls within the reporting requirement before relying on a standard declaration workflow.
Separately, CBSA updated Customs Notice 26-23 on October 23 to clarify the treatment of Chapter 98 and 99 goods under the United States Surtax Order (2026). The clarification does not create a new surtax effective October 23. The underlying surtax remains effective September 8, 2026.
Why the two checks should stay separate
The aluminum update is principally an origin-data and declaration completeness issue. It applies to covered aluminum imported under GIP 83 and asks for production-stage information: smelt locations and the most recent casting country.
The Chapter 98/99 update is a classification and surtax-treatment issue. Goods classified under those chapters are generally exempt from the United States surtax unless the applicable Chapter 98 or 99 tariff item is specifically listed in Schedule 4 and the goods are also otherwise classifiable under a tariff item subject to the surtax.
These are not interchangeable controls. An importer reviewing aluminum supplier data should not treat that review as proof that a Chapter 98 or 99 exception applies. Conversely, a Chapter 98 or 99 classification review does not establish the smelt or cast countries needed for a covered GIP 83 declaration.
A practical intake sequence for affected shipments
1. Screen the product and permit basis
For an aluminum shipment, first determine whether the goods are covered by GIP 83 and whether the shipment is being accounted for through the relevant import declaration. Importers generally should also check whether a CSA or applicable low-value exemption removes the shipment from the new reporting requirement. The available CBSA material does not make every aluminum shipment subject to the same data fields.
2. Obtain production-stage information early
Where the GIP 83 requirement applies, the commercial file should support the country of largest smelt, the second-largest smelt where applicable, and the most recent cast country. Those details may need to come from the producer or supplier rather than from the commercial invoice. If the information is incomplete, the declaration should be held for review rather than treating an unverified country as a substitute for the required production data.
3. Test any Chapter 98 or 99 claim against the exception
For U.S.-origin goods potentially eligible for Chapter 98 or 99 treatment, importers generally should review the applicable tariff item against Schedule 4 and confirm whether the goods are otherwise classifiable under a tariff item subject to the surtax. The classification itself does not automatically settle the surtax result.
4. Preserve the classification and origin record
CBSA’s clarification indicates that importers should retain documentation supporting both the tariff classification and the U.S.-origin determination. Where the goods are subject to the surtax treatment, the applicable treatment should be declared in CARM. The file should show the reasoning used, not only the final tariff item.
What GTA teams should change now
Importers operating warehouses or distribution processes in Mississauga, Brampton or Toronto can use one intake checklist with two separate decision paths: a GIP 83 data path for covered aluminum and a Chapter 98/99 surtax path for potentially eligible U.S.-origin goods. This approach is relevant whether the shipment is released through an Ontario commercial channel or another Canadian release point, because the measures are national rather than tied to a particular airport, sufferance warehouse or border crossing.
For shipments already in process, the most useful review is date-sensitive: apply the aluminum reporting rule from October 1, and distinguish the October 23 Chapter 98/99 clarification from the September 8 effective date of the underlying surtax. That separation helps prevent a guidance update from being recorded internally as a new duty date.
This article is general information, not legal advice for a specific shipment. Importers should assess the product, origin, tariff classification and applicable program treatment for each entry.