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.
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