Review Your Customs Compliance for 2026

With the new year comes a great opportunity to take a step back and review your customs compliance. We encourage clients to review the HS tariff for annual updates, the Measures in Force database for SIMA changes, as well as the Canada Border Services Agency's (CBSA) annual list of trade verification priorities.

Understanding Verification Priorities

Verification priorities are specific areas of imported goods or trade issues that CBSA focuses on more closely. They determine whether importers comply with regulations regarding tariff classification, country of origin, valuation, and the payment of appropriate duties and taxes. Import activity in these areas will receive increased scrutiny and a higher likelihood of targeted CBSA reviews.

CBSA sets verification priorities through a continuous, risk-based process. They use data-driven analysis to identify where mistakes or non-compliance occur most often.

Key Priorities for 2026

CBSA has identified the following priorities for 2026. Key areas include supply-managed goods, taxes, surtaxes, and trade agreement compliance.

• Classification of Supply-Managed Goods and Tariff Rate Quotas:

- Frozen desserts with at least 5% dairy content

- Cheese treats for dogs (animal feed preparations under heading 23.09)

- Spent fowl products

• GST and Excise Duties:

- Correct GST exemption codes

- Vaping products subject to excise taxes and duties

- Precious metals

• Origin Determination and Trade Agreement Compliance:

- CUSMA (Canada-United States-Mexico Agreement), particularly within the automotive sector

- CETA (Canada-EU), general import origin verification

- CUKTCA (Canada-United Kingdom Trade Continuity Agreement), general import origin verification

• Ongoing Surtax Orders and Global Trade Measures:

- 2024 China surtax orders – including steel, aluminum, and electric vehicles

- 2025 U.S. surtax orders – including steel, aluminum, and motor vehicles

• Duties Relief Program (DRP):

- CBSA continues to verify participants in the Duties Relief Program, focusing on licensees importing supply-managed goods. Ensuring compliance with DRP requirements can help maintain program benefits and minimize risk.

• Energy Commodities:

- There will be a focus on the proper reporting and accounting for energy commodity imports, including electricity under chapter 27.

Dynamic Nature of Compliance

The list of verification priorities is dynamic and may be updated throughout the year as trade risks evolve. Importers should use these priorities as a compliance check-in. Review tariff classifications, secure origin documentation, and double-check that surtaxes, excise, and GST are being applied correctly on your entries. Proactive compliance can help reduce the risk of reassessment and costly penalties.

Importance of Compliance Reviews

Conducting regular compliance reviews is essential for any importer. It allows businesses to identify potential issues before they escalate into larger problems. By staying informed about changes in regulations and verification priorities, you can ensure that your operations remain compliant.

Steps to Ensure Compliance

1. Review Tariff Classifications:

3. Ensure that all imported goods are classified correctly according to the HS tariff.




4. Secure Origin Documentation:

6. Collect and maintain proper documentation to verify the origin of your products.




7. Check Surtaxes and Duties:

9. Confirm that all applicable surtaxes, excise, and GST are accurately applied to your entries.




10. Stay Updated:

12. Regularly check the CBSA website for updates on verification priorities and compliance requirements.




13. Seek Professional Assistance:

15. If you have questions or concerns, consider reaching out for expert guidance.

Please contact R&R for assistance with compliance reviews or if you have any questions or concerns.