Importers of permit-controlled goods should treat the import permit as an operational data record, not only as an approval obtained before shipping. A revised CBSA memorandum now sets out the information checked against import documentation, while a separate customs notice clarifies how shipment-specific permits affect tariff-rate-quota goods leaving a bonded warehouse. For importers using bonded facilities in Mississauga, Brampton or elsewhere in the GTA, the practical issue is whether the permit, release transaction and final withdrawal records describe the same shipment.
What changed in the CBSA guidance
CBSA revised Memorandum D19-10-2 on October 22, 2026. The memorandum covers administration of the Export and Import Permits Act for imports, including goods controlled by Global Affairs Canada import permits. The current guidance addresses shipment-specific permit administration and CBSA verification of the permit number, validity dates, importer identity, quantity, value, description and origin.
The practical effect is a stronger reason to make permit data part of the shipment-control process. Importers generally should not assume that a valid permit is sufficient if the permit details do not match the release or accounting information. D19-10-2 states that non-compliance can result in rejected release transactions, enforcement action and AMPS consequences. Those outcomes and the permit-verification elements should be reviewed directly against the memorandum and the importer’s own product and transaction records.
The update is particularly relevant to goods on the Import Control List, including quota-controlled products. The permit number, dates, importer identity, quantity, value, description and origin should be checked before the shipment is released or withdrawn, rather than treated as corrections to be resolved after delivery.
Bonded-warehouse withdrawals require a separate date check
Customs Notice 26-20, issued August 21, 2026, clarified the existing treatment of tariff-rate-quota goods entered into a customs bonded warehouse. The notice says the policy was clarified, not changed. To receive the within-access duty rate when the goods leave the warehouse, the importer generally needs a valid shipment-specific Global Affairs Canada import permit covering the date of exit.
This creates a timing control that can be missed when an importer focuses only on the warehouse entry date. A permit may be obtained after the goods enter the warehouse, but it needs to cover the final release date. A permit that was valid when the goods entered the warehouse may not be sufficient if it has expired by the time the goods are withdrawn.
Where the permit is unavailable, has expired or is not reflected through a Type 10 adjustment before a within-access withdrawal, the goods can attract over-access duties, surtax, interest and possible penalties, according to the notice. Importers and warehouse operators should therefore align the planned withdrawal date, permit validity period and accounting treatment before authorizing delivery.
What GTA importers should put into the workflow
1. Identify the controlling permit before the shipment moves
For each controlled product, the importer and broker should establish whether the transaction depends on a shipment-specific permit, a quota allocation or another import authorization. The applicable permit process can differ by product and program. D19-10-2 is the starting point for the CBSA administration and verification framework, but the importer should also confirm the applicable Global Affairs Canada requirements for the goods.
2. Compare the permit with the commercial and customs records
A useful pre-release review should compare the permit number and validity dates with the importer identity, product description, origin, quantity and value appearing in the commercial documents and accounting information. These are the data elements identified in D19-10-2 for CBSA verification. Any mismatch should be escalated to the importer’s customs broker and the party responsible for the permit before the transaction is submitted or released.
| Control point | Question for the importer and broker |
|---|---|
| Permit identity | Does the permit number correspond to this shipment and importer? |
| Validity | Will the permit cover the intended release or warehouse withdrawal date? |
| Goods data | Do the description, origin and quantity match the shipment? |
| Value and accounting | Does the permit information align with the value and customs accounting record? |
| Warehouse withdrawal | Is the permit status confirmed before goods are withdrawn at the within-access rate? |
3. Treat the warehouse date as a new compliance checkpoint
For tariff-rate-quota goods held in a bonded warehouse, the planned withdrawal date should be recorded as a compliance milestone. A Peel Region warehouse serving customers in Mississauga or Brampton may hold goods for a period that extends beyond the original transport or entry schedule. The team managing inventory should therefore alert the broker when the withdrawal date changes, when a permit is delayed or when goods are allocated to a different customer or delivery plan.
This is a coordination issue between purchasing, logistics, the warehouse, finance and customs—not simply a broker filing issue. The broker can review the customs treatment, but the importer generally controls the commercial facts needed to verify the permit, including the intended withdrawal date and the shipment details.
Questions to discuss with your customs broker
- Which imported products in the current catalogue depend on a Global Affairs Canada permit or quota allocation?
- Are permit numbers and validity dates captured in the same shipment record used for customs accounting?
- For goods in a bonded warehouse, what process confirms that the permit covers the actual date of withdrawal?
- What happens when the quantity, value, origin or description changes after the permit is issued?
- Would a Type 10 adjustment be relevant before a within-access withdrawal, and what supporting records would be required?
- Which internal team is responsible for monitoring permit expiry and notifying the broker before release?
The main control is simple but time-sensitive: the permit, the shipment and the customs record should remain aligned through release or warehouse withdrawal. Importers should review the revised D19-10-2 guidance and Customs Notice 26-20 with their broker, particularly where quota-controlled goods move through a GTA bonded warehouse or where the planned withdrawal date may change.
General information only. The applicable permit, tariff treatment and accounting steps depend on the goods, origin, transaction and import program.