CBSA Releases October 2026 Trade Compliance Verification Priorities and Results (Updated)
Published July 14, 2026 | Updated Nov. 2, 2026
Key Points
- CBSA updated its trade compliance verification priorities and results on October 30, 2026.
- Current priorities cover tariff classification, supply-managed goods, GST and excise duties, trade agreement origin, surtax orders, and energy commodities.
- CBSA reported updated verification results, with error rates reaching 75% for certain U.S. and Chinese imports and 61% for frozen desserts.
- The agency is reviewing whether importers correctly applied surtaxes of 25%, 50%, and 100% to certain steel, aluminum, and electric vehicle imports.
- CBSA continues to use CARM and targeted compliance tools to address potential, suspected, and known non-compliance.
The
Canada Border Services Agency (CBSA) updated its 2026 trade compliance verification priorities and results on October 2026. The agency continues to focus on tariff classification, customs valuation, origin declarations, and the correct application of duties and surtaxes on imported goods.
Current verification targets include frozen desserts, spent fowl, steel and aluminum products, electric vehicles, and electricity imports. CBSA has also reported updated results for several ongoing verification rounds, identifying classification errors and unpaid duties and surtaxes that resulted in significant assessed revenue.
CBSA Trade Compliance Priorities
CBSA determines its verification priorities through an ongoing, risk-based process. The agency can add new targets throughout the year and carry over existing priorities based on monitoring activities, verification outcomes, and identified revenue risks.
The October 2026 update retains the following priorities:
Tariff rate quotas and classification of supply-managed goods
- Classification of frozen desserts containing 5% dairy products
- Classification of spent fowl products
GST and excise duties and taxes
- GST exemption codes
- Vaping products subject to excise duties and taxes
- Precious metals
CUSMA origin verifications
- Automotive industry
Import origin verifications under trade agreements
- Canada-European Union Comprehensive Economic and Trade Agreement (CETA)
- Canada-United Kingdom Trade Continuity Agreement (CUKTCA)
- Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP): Short supply list of products
Duties Relief Program (DRP)
- Verifications of licensees importing supply-managed goods
China surtax orders
- China Surtax Order (2024): Electric vehicles
- China Surtax Order (2024): Steel and aluminum
United States surtax orders
- United States Surtax Order (2025-01)
- United States Surtax Order (Steel and Aluminum 2025)
- United States Surtax Order (Motor Vehicles 2025)
- Order Imposing a Surtax on the Importation of Certain Steel Goods
- Steel Goods and Aluminum Goods Surtax Order
- Steel Derivative Goods Surtax Order
Energy commodities and final accounting
- Verification of electricity imports under Chapter 27 of the Customs Tariff
CBSA may change these priorities at any time as the trade environment evolves. The number of companies targeted and verification results can also change as the agency reviews additional cases and identifies new areas of revenue risk.
CBSA Verification Results
As of the October 2026 update, the CBSA reported compliance errors across several tariff classification and surtax verification priorities, with the following results:
- United States Surtax Order (2025-1): 281 targeted companies, 237 cases closed, and 177 cases in error (75%). Total assessed revenue reached $17,085,939.
- China Surtax Order (2024) – Steel and aluminum: 207 targeted companies, 192 cases closed, and 113 cases in error (59%). Total assessed revenue reached $12,833,159.
- United States Surtax Order (Steel and Aluminum 2025): 138 targeted companies, 43 cases closed, and 31 cases in error (72%). Total assessed revenue reached $7,787,706.
- China Surtax Order (2024) – Electric vehicles: 18 targeted companies, 16 cases closed, and 12 cases in error (75%). Total assessed revenue reached $2,220,676.
- Order Imposing a Surtax on the Importation of Certain Steel Goods: 32 targeted companies, 15 cases closed, and 4 cases in error (27%). Total assessed revenue reached $1,057,859.
- Steel Goods and Aluminum Goods Surtax Order: 23 targeted companies, 20 cases closed, and 8 cases in error (40%). Total assessed revenue reached $265,771.
- Spent fowl: 26 targeted companies, 19 cases closed, and 5 cases in error (26%). Total assessed revenue reached $196,004,072.
- Frozen desserts: 36 targeted companies, 31 cases closed, and 19 cases in error (61%). Total assessed revenue reached $57,054,302.
These figures include duties at risk, GST, interest, and penalties in the calculation of total assessed revenue. Older verification rounds counted only duties at risk and penalties.
Important Considerations for Importers
CBSA’s verification results highlight several areas where importers should review their customs declarations and supporting records.
Steel and aluminum imports
CBSA identified a risk that importers failed to apply the 25% surtax on certain steel goods containing steel melted and poured in China and aluminum goods containing aluminum smelted and cast in China. The verification covers goods listed under the Steel Goods and Aluminum Goods Surtax Order but classified under Chapter 99 of Canada’s Customs Tariff.
CBSA is also reviewing certain steel, aluminum, and other U.S.-origin goods subject to the United States Surtax Order (Steel and Aluminum 2025), which carries a 25% surtax.
Certain steel imports subject to tariff rate quotas
CBSA identified a risk that importers failed to apply the 50% surtax on certain steel goods subject to tariff rate quotas (TRQs) when import volumes exceeded the applicable quotas.
U.S.-origin goods
The United States Surtax Order (2025-1) imposes a 25% surtax on certain goods originating in the United States. CBSA is reviewing whether importers correctly applied the surtax to the value for duty.
Chinese electric vehicles
CBSA is checking whether importers applied the 100% surtax on Chinese-made electric vehicles originating in China. The measure covers electric and hybrid passenger automobiles, trucks, buses, and delivery vans subject to the China Surtax Order (2024).
Spent fowl
CBSA is reviewing imported goods under HS headings 02.07, 16.01, and 16.02 for potential misclassification as spent fowl instead of the appropriate tariff items subject to TRQs. Incorrect classification could result in significantly lower duty rates.
Frozen desserts
CBSA is reviewing products classified under tariff item 2105.00.10. Importers may incorrectly classify products as ice cream and other edible ice instead of using tariff item 2105.00.92, which can carry duty rates of up to 277%.
CBSA Valuation Priority: Energy Commodities
CBSA’s current valuation priority covers imported electrical energy classified under HS heading 27.16.
The agency identified a risk that importers may not properly account for electricity imports under the Customs Act or follow the prescribed accounting requirements.
The verification began in October 2025 and remains ongoing. Its latest results show:
- Targeted companies: 17
- Cases closed: 10
- Cases in error: 5 (50%)
- Total assessed revenue: $10,734,001
Importers handling electricity shipments should review their accounting practices and ensure they meet CBSA requirements.
CARM and Other CBSA Compliance Tools
CBSA uses the CBSA Assessment and Revenue Management (CARM) system to validate duties and taxes and conduct compliance interventions involving known or suspected non-compliance.
The agency also uses three compliance intervention tools:
- Trade Advisory Notice (TAN): CBSA sends a letter asking an importer to review a declaration when it identifies potential non-compliance. The notice includes guidance to help the importer address the issue. No monetary assessment follows from a TAN.
- Compliance Validation Letter (CVL): CBSA requests additional information when it suspects non-compliance. Importers must respond within 30 days. A monetary assessment may follow the agency’s review.
- Directed Compliance Letter (DCL): CBSA sends a letter with a monetary assessment when it identifies known non-compliance.
The recourse provisions of the Customs Act apply to any resulting assessments.
These tools complement traditional trade compliance verifications. While traditional verifications examine an importer’s transactions over a period, normally one year, compliance interventions target specific transactions. They also give importers an opportunity to correct errors earlier and address recurring compliance issues.
Tip: Use GHY’s CARM guide to stay compliant with CBSA requirements. It covers essential tasks like posting financial security, registering and delegating in the CARM Client Portal, managing payments, and handling Commercial Accounting Declarations (CADs) efficiently.
For any questions about the priority list, please email: cbsa.trci-erecio.asfc@cbsa-asfc.gc.ca.
How GHY Can Help?
GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.
By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.
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