Not every CBSA D-Memorandum revision creates a new duty, restriction or filing deadline. The practical question for importers is which part of the import process needs to change. Three 2026 revisions illustrate the distinction: D19-10-2 addresses aluminum imported under General Import Permit 83; D19-6-3 updates energy-efficiency guidance after a change in departmental responsibility; and D11-6-8 updates verification procedures for CARM and the Commercial Accounting Declaration (CAD).
What changed in the three memoranda
D19-10-2: aluminum under General Import Permit 83
CBSA revised Memorandum D19-10-2 on October 16, 2026. The revision adds a requirement relating to the importation of aluminum under General Import Permit 83 and replaces references to the “Single Window Initiative” with “Customs Single Window.” The memorandum directs readers to paragraphs 41–43 and 47 for the relevant instructions. CBSA Memorandum D19-10-2.
The source does not state a separate future implementation date for the aluminum requirement. Importers of controlled aluminum products should therefore have their broker and trade-compliance team review the revised instructions as part of the current import process, while confirming whether Global Affairs Canada has issued any separate direction.
For a metal distributor or manufacturer receiving goods into a Mississauga or Brampton facility, this is primarily a controlled-product data issue. The review should establish whether the goods fall under the Import Control List, whether General Import Permit 83 is the applicable authorization, and what permit information needs to be transmitted on the Commercial Accounting Declaration or release documentation.
D19-6-3: energy-efficiency responsibility moved to ECCC
CBSA revised Memorandum D19-6-3 on October 15, 2026, to reflect the transfer of responsibility for the Energy Efficiency Regulations from Natural Resources Canada to Environment and Climate Change Canada. The underlying responsibility transfer took effect July 30, 2026. The memorandum also updates terminology from “Single Window Initiative” to “Customs Single Window.” CBSA Memorandum D19-6-3.
The revision does not eliminate the electronic product-data process. CBSA’s guidance says clients should continue using the existing NRCan-linked settings for processing until system changes are finalized, even though ECCC now has responsibility. Importers of regulated products—including appliances, HVAC equipment, motors, lighting products and televisions—should therefore avoid changing system mappings solely because the responsible department changed.
This issue belongs with the product-compliance and customs-data owners, not only the finance team. A Toronto importer receiving appliances or HVAC equipment through Pearson and moving the goods to a GTA distribution site should compare its product master data, electronic submission settings and broker instructions against the revised memorandum.
D11-6-8: verification language now uses CARM and CAD terminology
CBSA revised Memorandum D11-6-8 on September 9, 2026. The revision reflects CARM Release 3 and replaces references to Form B3-3, the Canada Customs Coding Form, and Form B2, Canada Customs—Adjustment Request, with the Commercial Accounting Declaration. The memorandum concerns CBSA verifications involving non-free-trade-agreement origin, tariff classification and value for duty. CBSA Memorandum D11-6-8.
The operational point is not simply that document names changed. Importers involved in a verification should align their internal records, broker correspondence and response package with the current CAD terminology. The memorandum also confirms that CBSA may reassess classification, origin or value for duty following a verification. That makes the revision relevant to the importer’s evidence file, even where the shipment’s accounting process has already been completed.
Route each revision to a different owner
These memoranda should not be treated as one generic “CARM update.” They affect different control points:
| Revision | Primary control point | Internal owner to involve |
|---|---|---|
| D19-10-2 | Aluminum authorization and permit data | Trade compliance, purchasing and customs data teams |
| D19-6-3 | Regulated-product data and electronic submission settings | Product compliance, regulatory affairs and customs operations |
| D11-6-8 | Verification records and accounting terminology | Customs, finance and audit-response teams |
The table is a workflow aid, not a substitute for reviewing the source memorandum. The relevant importer should confirm the product scope, authorization and data requirements with its customs broker and, where appropriate, the responsible government department.
What GTA importers should review now
1. Identify affected product families
Start with the product master rather than the entry list. Identify aluminum products that may be controlled, energy-using products covered by the Energy Efficiency Regulations, and tariff lines or products likely to be examined in a classification, origin or value-for-duty verification. This approach is useful for importers with several receiving points, such as a Pearson-area operation in Mississauga and warehouses serving Brampton or Toronto.
2. Compare broker instructions with system data
For aluminum, compare the permit information available to the broker with the data transmitted on release or accounting documentation. For regulated energy-using products, verify that the existing NRCan-linked settings remain in place while system changes are pending. For verification files, use CAD terminology consistently across accounting records, entry histories and supporting documents.
3. Preserve the evidence behind the declaration
Importers should be able to connect a declared classification, origin, value for duty or permit reference to the commercial records supporting it. Depending on the goods, that may include product specifications, supplier information, origin documents, valuation material, permit details and correspondence with the broker. D11-6-8 is particularly relevant where CBSA has opened a verification or requests records relating to classification, origin or value for duty.
4. Ask targeted questions before the next shipment
Rather than asking whether a memorandum “applies” in the abstract, ask the broker to review the specific product, tariff item and declaration pathway. Useful questions include:
- Does the aluminum product fall within the controlled scope addressed by D19-10-2, and is General Import Permit 83 relevant?
- What permit information should appear on the CAD or release documentation?
- Does the product require energy-efficiency data, and are the current electronic settings being used while the responsibility transition is implemented?
- If CBSA requests records, which documents support the classification, origin and value-for-duty declarations?
- Are internal records using CAD terminology consistently with current CBSA verification guidance?
One administrative revision should not be overread
CBSA also revised Memorandum D19-4-1 on October 17, 2026, to provide the Greater Toronto Area Region’s new postal code. The source describes this as an administrative contact update and states that the substantive cultural-property import and export rules were not changed. The memorandum identifies the GTA permit office at Pearson cargo operations in Mississauga. CBSA Memorandum D19-4-1.
For businesses handling cultural property through the GTA, the contact information should be updated in operating procedures. It should not be treated as a new import restriction based on the revision alone.
Practical takeaway
The strongest response to these D-Memorandum revisions is targeted routing. Send aluminum changes to the permit and trade-compliance workflow, keep energy-efficiency submissions aligned with the interim system guidance, and prepare verification records using current CARM and CAD terminology. Importers should discuss the affected product lines, declaration data and supporting records with their broker before relying on an existing procedure for a new shipment.