CBSA Publishes January 2026 Trade Compliance Verification Priorities

Trade Update • Jan. 8, 2026

Key Points

  • CBSA has updated its 2026 trade verification and compliance priorities.
  • Key areas include supply-managed goods, taxes, surtaxes, and trade agreement compliance.
  • CBSA highlights CARM as a central tool to validate duties and support compliance interventions.
  • TAN, CVL, and DCL tools address potential, suspected, and known non-compliance.
  • Priorities may change during the year based on monitoring, revenue risk, and verification outcomes.
CBSA 2026 trade compliance priorities with cargo containers and Canadian flag, highlighting supply-managed goods, surtaxes, and CARM compliance tools

The Canada Boder Services Agency (CBSA) updated its 2026 trade verification and compliance priorities. Priority areas include supply-managed goods, frozen desserts, spent fowl, energy commodities, and regulated taxes. CBSA also monitors compliance under trade agreements like CUSMA, CETA, and CUKTCA, and enforces China and U.S. surtax orders. Using the CARM system and other trade compliance tools, CBSA focuses on timely interventions while adapting priorities as risk and revenue exposure change.

Compliance Priorities

The CBSA has identified the following priorities:

  • Tariff rate quotas and classification of supply-managed goods
    • Verifications on the classification of frozen desserts containing 5% dairy
    • Verifications on the classification of cheese treats for dogs (animal feed preparations under Heading 23.09)
    • Verifications on the classification of spent fowl products
  • GST and excise duties, including:
    • Exemption codes
    • Vaping products that are subject to excise duties and taxes
    • Precious metals
  • CUSMA origin verifications
    • Automotive sector
  • Import origin verifications under:
    • Canada–United Kingdom Trade Continuity Agreement (CUKTCA)
    • Canada–European Union Comprehensive Economic and Trade Agreement (CETA)
  • Duties Relief Program (DRP)
    • Verifications of licensees importing supply-managed goods
  • China Surtax Order (2024):
    • Electric vehicles
    • Steel and aluminum 
  • U.S. Surtax Order
    • (2025-01)
    • Steel and aluminum (2025)
    • Motor Vehicles 2025
  • Order imposing a Surtax on the importation of Certain Steel Goods
  • Steel and Aluminum Goods Surtax Order
  • Energy commodities and final accounting
    • Verifications on electricity imports under Chapter 27

CBSA sets verification priorities through a continuous, risk-based process. New priorities may be added during the year, and CBSA may revise these priorities at any time as risk conditions change.

CARM and Other CBSA Compliance Tools

CBSA highlights the CBSA Assessment Revenue Management (CARM) as a central tool for validating duties and taxes. It enables targeted compliance interventions to address areas of known or suspected non-compliance, complementing the agency’s broader verification priorities.

In addition to CARM, CBSA uses three compliance intervention tools:

  1. Trade Advisory Notice (TAN): Alerts importers to potential non-compliance and provides guidance. No monetary assessment is issued.
  2. Compliance Validation Letter (CVL): Requests additional information when non-compliance is suspected. Monetary assessment may follow.
  3. Directed Compliance Letter (DCL): Addresses known non-compliance and includes a monetary assessment.

All resulting assessments are subject to the recourse provisions of the Customs Act.

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.

Contact Us Today! Booking a Meeting, email consult@ghy.com, or call +1 (800) 667-0771.

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