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CBSA to Repeal Memorandum D10-2-3

Trade Update • May 1, 2026

Key Points

  • CBSA identified Memorandum D10-2-3 for repeal from its website.
  • The memorandum covers tariff classification, sampling, and testing of raw sugar.
  • CBSA said the information in the policy is no longer valid.
  • The agency also cited low usage rates and lack of policy relevance.
  • For any concerns, contact Andrea.Richard@cbsa-asfc.gc.ca by May 13, 2026.
Small Canadian flags lined up outdoors, symbolizing Canada’s plan to repeal Memorandum D10-2-3, an outdated policy on raw sugar tariff classification, sampling, and testing

A​​s relayed by the Canadian Society of Customs Brokers (CSCB), the Canada Border Services Agency (CBSA) identified Memorandum D10-2-3, Tariff Classification, Sampling, and Testing of Raw Sugar, for repeal as part of the Trade Programs Directorate’s ongoing review of trade Departmental Memoranda (D-Memoranda). CBSA said the memorandum no longer contains valid policy information, has low usage rates, and no longer represents a policy issue. The review forms part of the agency’s rolling five-year process to align D-Memoranda with legislative and regulatory amendments, jurisprudence, and accessibility standards.

Stakeholders can submit comments or concerns to Andrea Richard, Manager of the Tariff Classification Unit, by May 13, 2026.

What is Memorandum D10-2-3?

Memorandum D10-2-3 outlines the Canada Border Services Agency’s guidelines and procedures for the tariff classification, sampling, and testing of imported raw sugar under tariff subheadings 1701.11 and 1701.12.

First issued in 2002, the memorandum explains how Canada determines raw sugar classification using “settlement polarization,” sets requirements for sugar sampling and laboratory testing, and details procedures for customs officers when collecting and submitting samples for analysis.

It also references applicable provisions under the Customs Act and the Determination of the Tariff Classification of Sugar, Molasses and Sugar Syrup Regulations.

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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