CBSA Updates Mass Adjustment Submission Rules
Trade Update • Feb. 11, 2026
Key Points
- Changes took effect February 2, 2026.
- Mass adjustments apply only to Commercial Accounting Declarations (CADs) in CARM.
- Form BSF987 is now mandatory for all mass adjustment submissions
- Up to three reason codes are permitted, but changes must apply to all lines.
- Non-compliant submissions will be rejected, and time limits will not be protected.
The Canada Border Services Agency (CBSA) issued Customs Notice 26-03 outlining changes to the mass adjustment process effective February 2, 2026. Importers and brokers must continue following all requirements in Memorandum D17-2-1, Adjusting Commercial Accounting Declarations, in addition to the new requirements in this notice until D17-2-1 is formally updated. The notice introduces a mandatory submission form, clarifies limits on reason codes, and establishes strict sequencing rules when multiple legislative issues apply. Failure to comply will result in rejection of the mass adjustment case in CARM, and statutory time limits will not be protected.
Mass Adjustments and Corrections
- Mass adjustments may be submitted for corrections.
- Corrections cannot be included in the same request as adjustments.
- A correction is a voluntary change made between the initial acceptance of the CAD and 11:59:59 pm EST/EDT on the payment due date.
Mass adjustments apply only to CADs in CARM.
For Pre-CARM B3 entries that have not been converted to CADs, importers must follow Memorandum D17-2-4, Preparation and Presentation of Pre-CARM Adjustments.
For procedural guidance, refer to the CARM Client Portal (CCP) User Guide: Submit a Mass Adjustment Request.
New Submission Requirement
Form BSF987 Required
All mass adjustment submissions must include:
- Completed BSF987 – Mass Adjustment Request Form
- Upload of the form to the mass adjustment case in the CARM Client Portal (CCP)
Submissions without the required form will be rejected.
Reason Code Requirements
Line Consistency Rule
- A mass adjustment may include up to three reason codes
- The same changes must apply to all lines in the request
- Different tariff classification changes cannot be combined in one mass adjustment
If changes do not apply uniformly across all lines, CBSA will reject the case and statutory time limits will not be protected.
Example:
If changing tariff classification from 0805.10.00.10 to 0804.40.00.00, that same change must apply to every line included in the request.
Reason Code Order Requirements
CBSA now permits multiple legislative issues in one submission. To prevent underpayment or overpayment of interest, importers must follow a specific order.
If the Adjustment Results in a Refund
- Enter the trade program code and reason code supporting the refund in Commodity Reason Code 1
- Enter additional supporting reason codes in subsequent fields
Example:
- If changing from a surtax-subject tariff classification to a non-surtax classification and the duty rates remain the same, the surtax-related reason code must appear in Commodity Reason Code 1.
- If changing to a higher duty rate while applying preferential tariff treatment and the overall result is a refund, the preferential tariff treatment reason code must be listed first.
If the Adjustment Results in a Receivable or Is Revenue Neutral
- Enter the trade program code and reason code that supports the amount owed or non-revenue change in Commodity Reason Code 1.
Example:
If increasing Value for Duty and changing to a lower duty rate, and the net result is an amount owed to CBSA, the Value for Duty reason code must appear in Commodity Reason Code 1.
For detailed coding guidance, refer to Appendix A of Memorandum D17-2-1.
Rejections and Processing Outcomes
When a Mass Adjustment Case Is Rejected
- Case status will display as “Rejected” in CARM
- CADs selected for review will be individually rejected
- No Statement of Adjustment will be issued for those CADs
- CBSA will communicate the reason for rejection through an ad-hoc notification in the CCP
For instructions on viewing notifications, refer to the CARM User Guide: View Notifications.
CADs Not Referred for Review
- CADs already processed in CARM will not be affected
- Statements of Adjustment will confirm processed adjustments
Tip: For instructions on submitting CAD corrections and adjustments in CARM, check out GHY’s CAD Corrections and Adjustments Guide. It covers timelines, steps, and FAQs for managing declarations efficiently.
For more information, contact:
- Within Canada and the U.S. (toll free): 1-800-461-9999
- Outside Canada: 1-204-983-3550 or 1-506-636-5064
- TTY: 1-866-335-3237
- Online inquiries available through the CBSA website
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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