Importers using customs bonded warehouses for tariff-rate-quota (TRQ) goods have a specific accounting date to control: the date the goods exit the warehouse. CBSA clarified that a shipment-specific Global Affairs Canada import permit must be valid on that date for the importer to claim the “within access” duty rate. The clarification applies to the existing policy; CBSA states that it is not a policy change. CBSA Customs Notice 26-20 was issued on August 21, 2026.
What CBSA clarified
The issue concerns TRQ goods entering a customs bonded warehouse and later being accounted for when they leave. Where an importer seeks the within-access duty rate at the ex-warehouse stage, the relevant shipment-specific Global Affairs Canada import permit must be valid on the date the goods exit the warehouse. This is a timing and document-control requirement, not simply a question of whether a permit existed when the goods first entered storage. The customs notice sets out the clarification.
The rule is relevant to importers, customs brokers and other trade-chain participants handling TRQ goods through bonded facilities. The notice identifies steel and agricultural products as examples of goods that may be affected. Importers in Mississauga, Brampton or Toronto that use a bonded warehouse should therefore treat the warehouse-exit event as a separate customs control point when the goods are subject to a TRQ.
The accounting sequence matters
CBSA’s clarification also addresses goods that initially entered under a General Import Permit. In that situation, the original Type 10 Commercial Accounting Declaration must first be amended before an ex-warehouse declaration can claim within-access treatment. The notice describes this amendment sequence.
That sequence creates a practical dependency between three records:
- the original accounting for the goods entering the bonded warehouse;
- the shipment-specific Global Affairs Canada import permit; and
- the ex-warehouse declaration claiming the applicable within-access treatment.
Importers who release goods before confirming those records may create a mismatch between the warehouse movement, the permit’s validity date and the accounting information used to claim the duty treatment. The broker handling the ex-warehouse declaration may also need confirmation that any required amendment to the original Type 10 Commercial Accounting Declaration has been completed.
Controls to put around the warehouse exit
1. Identify the TRQ status before release planning
Importers should identify whether the goods are subject to a tariff-rate quota before instructing a warehouse to release them. That review is generally tied to the tariff classification, origin, quantity and applicable permit arrangements for the shipment. The purpose is not to assume that every shipment in a bonded facility receives the same treatment, but to determine whether within-access treatment is being claimed for the particular goods leaving storage.
2. Match the permit to the shipment and the exit date
Where within-access treatment is intended, importers should discuss with their broker how the shipment-specific Global Affairs Canada permit will be verified against the date the goods exit the warehouse. A permit that was available at an earlier stage may not resolve the control issue if it is not valid on the warehouse-exit date. CBSA’s notice identifies the exit date as the relevant date for this purpose.
3. Establish whether the original accounting needs amendment
If the goods initially entered under a General Import Permit, the importer should confirm whether the original Type 10 Commercial Accounting Declaration must be amended before the ex-warehouse declaration is submitted. The amendment should be treated as a prerequisite in the release workflow rather than as a later file-cleanup task, because CBSA’s clarification places it before the ex-warehouse claim.
4. Keep the warehouse and broker instructions synchronized
Warehouse release instructions, permit information and accounting instructions should point to the same shipment. This is particularly important where a GTA importer has inventory distributed across more than one facility or where a third party coordinates the movement from a bonded warehouse to a Brampton, Mississauga or Toronto destination. The importer should discuss who confirms the physical exit date and who supplies that date to the broker.
What to discuss with the customs broker
| Control point | Question to resolve before warehouse exit | Record to retain |
|---|---|---|
| TRQ applicability | Are the goods being accounted for under a TRQ, and is within-access treatment being claimed? | Classification, origin and shipment accounting records |
| Permit timing | Is the shipment-specific Global Affairs Canada import permit valid on the date the goods exit? | Permit and evidence of the warehouse-exit date |
| Initial entry | Did the goods initially enter under a General Import Permit? | Original Type 10 Commercial Accounting Declaration |
| Amendment sequence | If applicable, has the original Type 10 declaration been amended before the ex-warehouse declaration? | Amended accounting record and broker confirmation |
| Ex-warehouse claim | Do the permit, goods and accounting records support the requested within-access treatment? | Ex-warehouse declaration and supporting documents |
Importers should also ask how the broker records a permit that expires, changes or becomes unavailable between the warehouse release instruction and the actual exit. The appropriate response will depend on the shipment and applicable trade controls, but the escalation point should be defined before the goods move.
How this fits with wider customs controls
The bonded-warehouse clarification is separate from CBSA’s September 9, 2026 revision of D-Memorandum D11-6-8. That memorandum was revised to reflect CARM Release 3 and the replacement of the former B3-3 and B2 forms with the Commercial Accounting Declaration. It also addresses CBSA verification of non-free-trade-agreement origin, tariff classification and value for duty.
For an importer using a bonded warehouse, that means the TRQ permit control should sit alongside—not replace—the ordinary support for classification, origin, value for duty and accounting. Importers subject to a CBSA verification, audit, re-determination or request for records may need to support those elements under the revised guidance. The importer should discuss with its broker which records are retained for the original warehouse entry, the permit-based treatment and the ex-warehouse accounting.
CBSA also revised D-Memorandum D19-10-2 on October 16, 2026, covering the Export and Import Permits Act. The revision includes a requirement concerning imports of aluminum under General Import Permit 83 and replaces references to the former Single Window Initiative with Customs Single Window terminology. Importers of controlled goods should confirm whether that guidance affects their own permit process rather than assuming the bonded-warehouse clarification is the only permit control in the file.
Recommended next step
For each TRQ product held in a customs bonded warehouse, importers should map the intended warehouse-exit date to the shipment-specific permit, the original Type 10 Commercial Accounting Declaration and the planned ex-warehouse declaration. The key discussion with the broker is whether the records support within-access treatment on the actual exit date and, where goods initially entered under a General Import Permit, whether the original accounting has been amended first.
That review is most useful before release instructions are issued. It gives the importer, warehouse and broker a common control date and reduces the risk that a permit or accounting step is checked only after the goods have left the bonded facility.