CBSA Trade Compliance Verification Priorities: July 2026 Update
Every year in July, the Canada Border Services Agency (the “CBSA”) updates their trade compliance verification priorities. Importers in Canada should prepare for the likelihood of a CBSA trade compliance verification as the result of such verifications can result in payment of additional duties, interest, and penalties.
The targeted verification priorities for 2026 was published on the CBSA’s website as follows in January:
Tariff rate quota and classification of supply managed goods (i.e., cheese treats for dogs, gloves, bags, LED lamps, frozen desserts, spent fowl);
GST and excise duties and taxes;
Canada-United States-Mexico Agreement (CUSMA) origin verifications;
Import origin verification under the Canada-European Union Comprehensive Economic and Trade Agreement (CETA) and the Canada-United Kingdom Trade Continuity Agreement (CUKTCA);
Surtax-related verifications (i.e., China Surtax Order 2024, United States Surtax Order - Steel and Aluminum 2025, United States Surtax Order - Motor Vehicles 2025, etc);
Energy commodities and final accounting (electricity imports under chapter 27 of the Customs Tariff).
In the CBSA’s July 2026 update, Cheese treats for dogs (preparations of a kind used in animal feeding under heading 23.09) have been removed but import origin verifications under different free trade agreements now include the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP).
The full list can be found here.
CBSA Verifications Objectives:
The CBSA conducts verifications of the goods origin, tariff classification, and value for duty each year in order to ensure that importers in Canada comply with the CBSA’s requirements and programs. Specifically, verifications are used to:
Assess a client’s compliance with CBSA administered legislation;
Determine compliance within industry sectors;
Conduct a review of a client’s liabilities and entitlements; and
Assess the integrity of trade data received from importers.
In addition to the verification priorities listed by the CBSA, the CBSA will also utilize several compliance tools to address areas of known or suspected non-compliance. Specifically, the CBSA will use
CARM, to validate duties and taxes and conduct compliance interventions to address areas of known or suspected non-compliance;
Trade Advisory Notice (TAN), a letter to the importer asking them to review a declaration where there is a potential for non-compliance;
Compliance Validation Letter (CVL), a letter to the importer asking for more information when the CBSA suspects an instance of non-compliance;
Directed Compliance Letter (DCL), a letter to the importer accompanied by a monetary assessment to address instances of known non-compliance.
These additional compliance tools provide the CBSA with additional means to enhance its trade compliance regime.
Takeaway:
The CBSA’s verification priorities are chosen based on high levels of non-compliance identified by the CBSA. As such, importers of items found in the CBSA’s priorities list should contact counsel for assistance with a CBSA compliance review. That said, importers of other goods should note that a trade compliance verification may still occur at any time. If you have noticed any inaccuracies in your import declarations, we recommend taking corrective measures immediately. For assistance, please contact us at bahriye.ceyhancavdar@ceyhankim.com (Bahriye Ceyhan Cavdar) or bomin.kim@ceyhankim.com (Bomin Helen Kim).
Canada Introduces New Legislation to Strengthen the Ban on Importing Goods Made with Forced Labour
On June 2, 2026, the United States Trade Representative (“USTR”) made findings under Section 301 of the Trade Act of 1974 that 60 countries failed to “impose and effectively enforce a prohibition on the importation of goods produced with forced labour”. The United States found that this failure is “unreasonable or discriminatory and burdens or restricts U.S. commerce”, and have proposed actions to be taken against these countries.
With respect to Canada specifically, although Canada’s Customs Tariff already prohibits the importation of goods that are “mined, manufactured or produced wholly or in part by forced labour”, the USTR determined that Canada failed to “effectively enforce its forced labour import prohibition.” Further, the USTR found that Canada “has not taken action to restrict the importation of goods for which there is a known risk of forced labour.” In light of these findings, the USTR proposed additional duties of 10% on goods from Canada. The proposed additional duties will not apply to products that are compliant with the United States-Mexico-Canada trade agreement.
In response, Canada is introducing a new legislation (Bill C-35) that will implement safeguards to stop the importing of goods made with coerced labour into Canada. As stated in the announcement made by the government of Canada, the new legislation will:
Authorize the Minister of Foreign Affairs to establish a list of high-risk goods—identified by region, entity, or individual—where there are reasonable grounds to suspect they are produced by forced labour;
Establish requirements for importers of certain high-risk goods to provide enhanced supply chain tracing information to the CBSA, in accordance with the regulations;
Introduce a deeming provision, meaning goods identified as high-risk would be deemed prohibited from importation when mandatory information requirements are not met;
Allow the CBSA to designate a customs officer to determine whether imported goods are produced wholly or in part by forced labour and detain goods for a period of up to 90 days; and
Create a cost-recovery model when importers are found to have imported goods made using forced labour.
The new legislation therefore will outline mandatory requirements for importers of certain high-risk goods, the imports of which will be deemed prohibited if importers fail to meet the requirements.
Our team will continue to monitor further developments with respect to this new legislation and we will report updates on our website.
Takeaway
Businesses in Canada should review their policies in relation to forced labour and child labour in their supply chains and reach out to our team with any specific questions related to their business.
Contact info:
Exporting from Canada: Compliance Considerations for International Trade
Canadian businesses looking to export abroad must comply with additional trade compliance responsibilities. To ensure that exporting activities comply with various Canadian laws and regulations, Canadian exporters should be aware of the following.
1. EXPORT DECLARATION REQUIREMENTS
To export from Canada, exporters are required to report exports of certain goods according to Canadian laws. If reporting of goods is required, exporters in Canada must submit export declarations to the Canada Border Services Agency (“CBSA”) on the Canadian Export Reporting System (“CERS”) or on the G7 Electronic Data Interchange Export Reporting (“G7 EDI”).
To determine whether or not exporters should report the goods, exporters must consider the following factors:
Whether or not the goods fall under the definition of “Restricted Goods”;
Whether or not the goods fall under the definition of “Special Goods”;
Whether or not the goods fall under an exception found in the “exceptions to reporting by the exporter” section; and
Whether or not the goods are can be considered “Regular Goods”.
While exporters may delegate the reporting of goods to a third party, such as a customs service provider, the ultimate responsibility falls on the exporter to ensure that true, accurate and complete information is provided in accordance with Canadian laws and regulations.
Failure to properly meet export reporting requirements may result in enforcement actions by the CBSA. Enforcement actions may be in the form of detention of exports, seizures and ascertained forfeitures of exports, or monetary penalties.
Takeaway
Given the above, we advise exporters in Canada to seek legal assistance to understand export declaration requirements in Canada.
2. EXPORT CONTROLS
In Canada, export control laws require a permit or a license for certain goods to be exported. This is to ensure that exports of certain controlled goods are conducted lawfully and in a manner consistent with Canada’s national interests and international obligations.
Export and Import Permits Act
Under the Export and Import Permits Act, the Minister of Foreign Affairs issues to any resident of Canada a permit to export items included on the Export Control List or to a country included on the Area Control List.
Exporters should ensure that any exported goods are compliant with the requirement of Canadian laws regulating exports. Failure to comply with export control requirements as outlined in Canadian laws and regulations may lead to fines of up to $250,000 and/or imprisonment for up to 10 years.
To understand export permit requirements for the goods, Canadian exporters must consider factors such as the nature, characteristics, origin, or destination of the goods being exported. Exporters may obtain certainty as to the control status of their goods by applying for an advisory opinion (“AO”) or by applying for an export permit.
Products subject to export controls include:
Military and strategic goods and technology;
Softwood lumber;
Firearms;
Sugar and sugar containing products;
Peanut butter;
Logs; and
U.S.-origin goods and technology.
Controlled Goods Program
Under the Defence Production Act, controlled goods are goods that have military or national security significance. In Canada, individuals and organizations must register in the Controlled Goods Program to examine, possess or transfer such controlled goods.
Upon registering in the Controlled Goods Program, registrants must comply with additional requirements of the Defence Production Act. This includes conducting and submitting reports on security assessments of personnel, preparing for inspections, developing security plans, and reporting security breaches.
Takeaway
It is important for individuals and organizations to have a clear understanding about the application of export controls. We recommend consulting with our team to learn more about the legal obligations.
3. SANCTIONS AND RESTRICTED MARKETS
Canada has trade and economic sanctions imposed on specific countries, organizations, and individuals. Sanctions restrict or prohibit certain activities with targeted countries, organizations, and individuals. As such, exporters are responsible for being aware of any applicable sanctions if they are exporting to or otherwise doing business in or with any of the named countries.
Canada imposes sanctions under the following regimes:
The United Nations Act;
The Special Economic Measures Act; and
The Justice for Victims of Corrupt Foreign Officials Act.
There are also regulations under the above regimes which must be reviewed to understand whether or not an activity or transaction is permitted under Canadian sanctions.
Currently, Canada imposed sanctions in relation to the following countries:
Belarus;
Central African Republic;
China;
Democratic People’s Republic of Korea (North Korea);
Democratic Republic of the Congo;
Guatemala;
Haiti;
Iran;
Iraq;
Lebanon;
Libya;
Moldova;
Myanmar;
Nicaragua;
Russia;
Somalia;
South Sudan;
Sri Lanka;
Sudan;
Syria;
Ukraine;
Venezuela;
Yemen; and
Zimbabwe.
We advise Canadian individuals and entities to conduct due diligence before engaging in activity abroad or engaging in transactions involving individuals or entities from foreign countries. Violating Canadian sanctions can result in the following:
Under the United Nations Act, maximum penalty on summary conviction of $100,000 fine and/or a 1-year prison term with convictions on indictment that may result in a maximum 10-year prison term;
Under the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act, maximum penalty on summary conviction of $25,000 fine and/or a 10year prison term with convictions on indictment that may result in a maximum 5-year prison term.
Takeaway
Given the above, we advise seeking legal advice for assistance in the interpretation of the Canadian sanctions regime to assess their full impact
Please contact us at bahriye.ceyhancavdar@ceyhankim.com or bomin.kim@ceyhankim.com for specific questions related to your business.
CBSA Trade Compliance Verification Priorities 2026
Each year, the Canada Border Services Agency (the “CBSA”) announces their trade compliance verification priorities. Importers in Canada should prepare for the likelihood of a CBSA trade compliance verification as they can result in additional duties, interests, and penalties.
The targeted verification priorities for this year is published on the CBSA’s website:
Tariff rate quota and classification of supply managed goods (i.e., cheese treats for dogs, gloves, bags, LED lamps, frozen desserts, spent fowl);
GST and excise duties and taxes;
Canada-United States-Mexico Agreement (CUSMA) origin verifications;
Import origin verification under the Canada-European Union Comprehensive Economic and Trade Agreement (CETA) and the Canada-United Kingdom Trade Continuity Agreement (CUKTCA);
Surtax-related verifications (i.e., China Surtax Order 2024, United States Surtax Order - Steel and Aluminum 2025, United States Surtax Order - Motor Vehicles 2025, etc).
The full list can be found here.
CBSA Verifications Objectives:
The CBSA conducts verifications of the goods origin, tariff classification, and value for duty each year in order to ensure that importers in Canada comply with the CBSA’s requirements and programs. Specifically, verifications are used to:
Assess a client’s compliance with CBSA administered legislation;
Determine compliance within industry sectors;
Conduct a review of a client’s liabilities and entitlements; and
Assess the integrity of trade data received from importers.
In addition to the verification priorities listed by the CBSA, the CBSA will also utilize several compliance tools to address areas of known or suspected non-compliance. Specifically, the CBSA will use
CARM, to validate duties and taxes and conduct compliance interventions to address areas of known or suspected non-compliance;
Trade Advisory Notice (TAN), a letter to the importer asking them to review a declaration where there is a potential for non-compliance;
Compliance Validation Letter (CVL), a letter to the importer asking for more information when the CBSA suspects an instance of non-compliance;
Directed Compliance Letter (DCL), a letter to the importer accompanied by a monetary assessment to address instances of known non-compliance.
These additional compliance tools provide the CBSA with additional means to enhance its trade compliance regime.
Takeaway:
The CBSA’s verification priorities are chosen based on high levels of non-compliance identified by the CBSA. As such, importers of items found in the CBSA’s priorities list should contact counsel for assistance with a CBSA compliance review.
Contact Information:
Bahriye Ceyhan Cavdar (bahriye.ceyhancavdar@ceyhankim.com)
Bomin Kim (bomin.kim@ceyhankim.com)
CBSA Appeal/Review Process
It All Begins Here
May 6, 2026
If an importer disagrees with a decision made by the Canada Border Services Agency (“CBSA”), the importer has the right to appeal the CBSA’s decision under section 60 of the Customs Act.
Background:
Pursuant to the Customs Act, the CBSA may issue a notice of determination, re-determination, or further redetermination on tariff classification, origin, and value for duty of goods imported into Canada. The CBSA’s decisions can have an impact on the rate of duties and taxes importers can owe on goods. If an importer disagrees with the CBSA’s decision, and to receive accurate and fair decisions from the CBSA and to reduce the duties and taxes owed on imports, importers may appeal the CBSA’s decision under section 60 of the Customs Act provided that the request is made within 90 days of the initial notice.
Steps:
The steps to request a review and to appeal the CBSA’s decision is outlined in the CBSA’s Memorandum D11-6-7 (the “D-Memo”):
Ensure that the person making the request is one of person who can file a request (i.e., importer of the goods, owner of the goods at the time of release, etc);
Make the request within 90 days of the CBSA’s original notice of determination, re-determination, or further re-determination. An application for an extension of this time limit is available but only under certain conditions;
An “Appeals Officer” will be assigned to the file, and make a decision after considering the evidence, arguments provided, the relevant law and position, and any other additional research that is conducted;
If an importer’s appeal is successful, the duties and taxes applied to your imports will be adjusted and the CBSA will change their initial ruling;
If an importer’s appeal isn’t successful, the importer may further escalate the case to the Canadian International Trade Tribunal (CITT).
If you require assistance in this area, please contact us at bahriye.ceyhancavdar@ceyhankim.com or bomin.kim@ceyhankim.com for specific questions related to your business.