Canada’s September 2026 customs developments affect three different importer processes, not one general border procedure. The United States Surtax Order (2026) formalized surtaxes on specified U.S.-origin goods, Customs Notice 26-24 changed an air-carrier condition for authorized Courier Low Value Shipment (CLVS) participants, and CBSA revised its verification memorandum to reflect CARM Release 3. For importers in Toronto, Mississauga and Brampton, the practical response is to separate the work into three queues: shipment costing, courier operations and verification records.
Queue one: identify shipments with U.S.-goods surtax exposure
The federal order was published in the Canada Gazette on September 23, 2026, with an effective date of September 8, 2026. It imposes surtaxes of 15%, 25% or 50% on specified U.S.-origin goods, including listed appliances, agricultural equipment, pulp and paper, electronics and dairy products. The order also moves most steel and aluminum goods previously subject to a 25% rate to a 50% rate.
The surtax is calculated on customs value and applies in addition to ordinary customs duties. Goods already in transit to Canada on or before the order’s entry-into-force date are excluded. The order also provides for possible remission for specified uses, including manufacturing, food or beverage packaging, agriculture, health care, public safety and national security, subject to its conditions. These details are set out in the published order.
This queue belongs with the teams reviewing classification, origin and valuation. A GTA importer receiving goods through Pearson, a Mississauga-area sufferance warehouse or a Southern Ontario highway crossing would generally need to determine whether the goods fall within the order before accounting for the shipment. The review should also distinguish goods in transit by the relevant date and document any potential remission pathway.
- Confirm the tariff classification against the covered goods in the order.
- Review the U.S.-origin determination for the shipment.
- Check the customs value used as the surtax base.
- Record whether the shipment was already in transit on or before September 8, 2026.
- Assess whether a specified remission use could apply, without assuming eligibility before the order’s conditions are met.
Queue two: isolate the CLVS carrier change from ordinary imports
Customs Notice 26-24, issued September 14, 2026, permits authorized CLVS participants to use third-party air carriers that are not Partners in Protection (PIP) certified. The third-party carriers must remain bonded and continue presenting CLVS shipments at the designated sufferance warehouse. The courier itself must retain active PIP certification for the air mode, according to the CBSA notice.
This is a narrow operating change for authorized courier operators and shipments moving under the CLVS Program. It is not a general exemption for commercial importers or for every air carrier. Importers using express services through Toronto Pearson should therefore direct the review to their courier and carrier arrangements rather than treating the notice as a change to their general customs-accounting process.
For a courier operation, the relevant control record is likely to be the transportation arrangement: which party is carrying the shipment, whether the carrier remains bonded, where the shipment is presented and whether the courier retains the required PIP status. Those checks are separate from deciding whether a U.S.-origin product attracts a surtax.
Queue three: prepare records for CARM-related verification
CBSA revised Memorandum D11-6-8 on September 9, 2026. The memorandum addresses verification of non-free-trade-agreement origin, tariff classification and value for duty, and reflects CARM Release 3. It replaces references to the former B3-3 and B2 forms with the Commercial Accounting Declaration (CAD), as described in the revised memorandum.
The memorandum states that verification activity can involve questionnaires, verification letters, site visits and document reviews. Importers of commercial goods and their customs agents should therefore treat this development as a records-readiness issue. The core file should connect the declared origin, classification and value for duty to the commercial and operational documents supporting those declarations.
For companies holding inventory or accounting records across Brampton, Mississauga or Toronto operations, the immediate question is not whether every shipment will be selected for verification. It is whether the records can be retrieved and reconciled if a verification request arrives. The CAD reference also means that internal procedures relying on the former form names should be reviewed and updated.
Why the three queues should remain separate
The surtax order changes the potential cost of specified goods. The CLVS notice changes an operating option for a defined courier program. The D11-6-8 revision describes how CBSA verification work is documented and conducted. Combining all three into a single “September customs update” task can obscure ownership and leave important evidence in the wrong file.
A practical review can assign one owner to U.S.-origin surtax screening, one to CLVS transportation controls and one to CAD-based verification records. The owners can then escalate exceptions to the customs broker or internal trade-compliance lead. This approach does not replace shipment-specific classification, origin, valuation or program analysis; it puts each question in the work queue where it can be answered.
What importers should review now
- Run the surtax review on covered U.S.-origin goods and preserve the basis for the classification, origin and customs value decisions.
- Ask courier operations whether any CLVS air-carrier arrangement relies on the September 14 change, and confirm the continuing bonding, sufferance-warehouse and courier PIP conditions.
- Update verification files and procedures to use CAD terminology where the revised memorandum applies.
- Keep the three records linked at the shipment level, but do not treat a courier-carrier change as evidence of surtax treatment or verification compliance.
These September developments are different in scope. The most useful control is therefore not a single broad checklist, but a clear separation between duty exposure, transport eligibility and the evidence supporting customs declarations.