Dear valued client,

The Canada Border Services Agency (CBSA) has released its updated 2026 Trade Compliance Verification Priorities, reinforcing a more proactive approach to trade compliance under the CBSA Assessment and Revenue Management (CARM) system.

The update signals a continued shift toward targeted, risk-based verifications designed to identify non-compliance earlier and encourage voluntary corrections before issues become more significant.

What this means for importers

With CARM now fully integrated into the CBSA's compliance strategy, importers should expect increased scrutiny in several areas, including:

• Tariff classification
• Country of origin and preferential trade agreement claims
• Surtax applicability
• Customs valuation
• GST and excise tax reporting
• Duty relief programs and other special customs provisions

Rather than conducting only broad post-entry audits, the CBSA is increasingly using targeted compliance interventions to identify specific transactions that may present a higher risk of non-compliance.

Current CBSA compliance priorities

The 2026 priorities include verification activities related to:

• United States surtax measures
• Steel and aluminum surtaxes
• China surtax measures
• CUSMA, CETA, CUKTCA, and CPTPP origin claims
• Tariff rate quotas and supply-managed goods
• Tariff classification
• GST exemptions and excise duties
• Duties Relief Program (DRP)
• Energy commodity accounting
• CARM validation and trade compliance

As the CBSA continues to use an evergreen, risk-based approach, new priorities may be introduced throughout the year.

What the verification results tell us

The CBSA has also published the results of several ongoing verification programs. The findings indicate that many importers continue to experience challenges complying with Canada's evolving trade measures.

Some notable results include:

• United States Surtax Order (2025-1): 75% of completed verifications identified errors, resulting in more than $11.8 million in assessed duties, taxes, interest, and penalties.
• United States Surtax Order (Steel and Aluminum 2025): 69% of reviewed importers were found to be non-compliant, with more than $7.3 million assessed.
• China Surtax Order (2024) – Steel and Aluminum: 60% error rate, generating over $5.1 million in assessments.
• Steel Goods and Aluminum Goods Surtax Order: Half of the completed verifications identified errors, despite this program only beginning in April 2026.

We have included the CBSA verification results below for reference.

Recommended actions

Given the CBSA's increased focus on trade compliance, importers should consider reviewing:

• Tariff classifications and applicable surtax provisions
• Country of origin declarations and free trade agreement eligibility
• Customs valuation methodologies
• CARM accounting and reporting practices
• Internal procedures for maintaining customs documentation and supporting records

Taking a proactive approach today can help reduce the risk of future reassessments, interest, and administrative penalties.

If you have questions about these updates or would like assistance reviewing your imports, please contact your JORI representative.