Navigating Heightened Canada Customs Oversight

The Canada Border Services Agency (CBSA) has recently updated its trade compliance verification priorities for 2026, signaling an increased focus on tariff classification, free trade agreement compliance, goods and services tax (GST) reporting, and Canada's growing network of surtax measures. The latest priorities reflect CBSA's risk-based enforcement approach and the agency's continued use of the CBSA Assessment and Revenue Management (CARM) platform to strengthen compliance oversight.

For Canadian importers, the update serves as a reminder that customs compliance extends well beyond duty rates. Verification activity now spans tariff classification, origin declarations, surtax applicability, GST obligations, and participation in customs relief programs. Understanding where CBSA is increasing its scrutiny can help importers identify potential exposure, strengthen documentation and address compliance gaps before they result in reassessments, penalties or other costs.

Here’s what importers should know about the new changes:

CBSA continues to modernize compliance enforcement

Under CARM, CBSA has adopted a more targeted approach to identifying areas of revenue risk and non-compliance. Verification priorities are continuously reviewed and adjusted based on emerging risks, industry trends, and audit findings. This means new product categories and compliance programs can be added throughout the year as priorities evolve. Importers should view the published priority list as an indication of where CBSA is most likely to focus future verification and reassessment activities.

Three key areas receiving increased attention

While CBSA's verification priorities cover a range of products and programs, three areas stand out for their potential to create significant financial and compliance exposure for importers: surtax applicability, trade agreement origin claims and tariff classification.

1. Surtax compliance

One of the most notable developments for 2026 is the expansion of surtax-related verification priorities. CBSA has identified multiple surtax programs for enforcement review, including measures affecting:

Chinese electric vehicles
Chinese steel and aluminum products
U.S.-origin goods subject to retaliatory surtaxes
U.S. steel and aluminum products
U.S. motor vehicles
Certain steel, aluminum, and derivative steel goods subject to Canada's surtax orders

The heightened focus reflects the growing complexity of Canada's trade remedy environment and the significant revenue implications associated with surtax assessments. Importers must be able to support their declarations with detailed product, origin, and manufacturing documentation.

2. Trade agreement origin claims

CBSA will continue to scrutinize origin claims under several trade agreements, including:

Canada-United States-Mexico Agreement (CUSMA)
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)

Particular attention is being directed toward CUSMA origin claims in the automotive sector, where complex regional value content, steel and aluminum sourcing requirements, and supplier certifications create additional compliance risk. Importers claiming preferential tariff treatment should ensure origin certifications, supplier records, and supporting documentation are readily available in the event of a verification request.

3. Tariff classification reviews

Tariff classification remains a foundational CBSA enforcement priority. Current verification targets include:

Supply-managed goods and tariff rate quotas (TRQs)
Frozen desserts containing dairy products
Spent fowl products
LED lamps
Bags
Gloves

Incorrect tariff classification can result in reassessed duties, surtaxes, GST, penalties, and interest—making this one of the most important areas for proactive review.

Why importers should pay attention

Recent CBSA updates suggest enforcement activity is increasingly focused on areas where surtaxes, trade agreement benefits, and tariff classifications intersect. In many cases, the financial impact of a compliance error may extend beyond customs duties to include GST, interest, and penalties. The emphasis on steel, aluminum, automotive products, and trade agreement origin claims also aligns with broader North American trade policy developments and the increased use of tariff and surtax measures as trade policy tools.

Steps importers can take now

With verification priorities evolving throughout the year, importers can take proactive steps now to identify potential exposure and strengthen their compliance position. Rather than waiting for a verification request, reviewing high-risk products, documentation and processes in advance can help reduce the likelihood of costly surprises.

Traders can reduce risk by:

Reviewing tariff classifications for products identified in CBSA's priority list.
Validating origin documentation supporting CUSMA, CETA, CPTPP, and CUKTCA claims.
Confirming surtax applicability and supporting documentation for steel, aluminum, automotive, and other affected imports.
Assessing GST exemption code usage and excise tax obligations.
Conducting internal compliance reviews before receiving a CBSA verification notice.
Monitoring the ongoing review and evolution of major trade agreements such as CUSMA.

Stay ahead of compliance risk

As CBSA continues to refine its verification priorities, importers should view customs compliance as an ongoing process rather than a one-time review. Proactively identifying areas of exposure and maintaining accurate, well-supported records can help importers respond more confidently to changing requirements while reducing the risk of unexpected duties, surtaxes, penalties and other costs.