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CBSA COMPLIANCE VERIFICATION PRIORITIES

FOCUS ON U.S. & CHINA SURTAX ORDERS

The Canadian Border Services Agency (the “CBSA”) has released the July 2025 update to its compliance and verification priorities.  This update is part of the CBSA’s semi-annual process of resetting its verification priorities, which occurs in January and July of each year.

In this July 2025 update, the CBSA has placed a significant focus on the U.S surtaxes, alongside other ongoing compliance areas from previous rounds.  We provide a detailed breakdown of these priorities below.

Compliance Priorities

Unsurprisingly, given the recent developments in the Canada - U.S. trade relationship, the CBSA is emphasizing enforcement of compliance with the recently imposed U.S. surtaxes.  This includes the application of the following Surtax Orders:

• United States Surtax Order (2025-01):  This is the first Surtax Order imposed on U.S. origin goods, which we wrote about here.
• United States Surtax Order (Steel and Aluminium 2025):  This surtax targets U.S. steel and aluminum products, which we wrote about here.
• United States Surtax Order (Motor Vehicles 2025):  This surtax targets motor vehicles originating in the U.S. and represents Canada’s direct response to the U.S. tariff on Canadian automobiles and automobile parts.
  

Additionally, the CBSA continues to emphasize compliance on existing surtaxes on goods originating in China, including (1) the Surtax Order on electric vehicles (discussed here), and (2) the Surtax Order on steel and aluminum products (discussed here).

Tariff Classifications and Origin Priorities

The CBSA will be maintaining its existing focus on eight (8) types of goods for tariff classification and one (1) type of goods for origin verification.  These types are consistent with previous rounds:

• Tariff Classification : Gloves, bags, spent fowl, freezers and other freezing equipment, washers and dryers, LED lamps, furniture for non-domestic purposes, and bicycle parts.
• Origin : Bedding and drapery.

Notably, disposable and protective gloves have been removed from the tariff classification priority list.  This is surprising given that in the fifth and most recent round of verifications, the CBSA found a 100% non-compliance rate for this category.

Similarly, apparel has been removed from the valuation priority list.  This is also unexpected given that in the fourth round of verifications, more than half of the cases were found to be non-compliant.

Takeaways

While importers should always try to get things like tariff classification, valuation, and origin correct the first time, the CBSA’s priorities are special targets because of the high levels of non-compliance already identified.  Additionally, the focus on surtax orders for goods from the U.S. and China is likely to impact a significant number of importers, given the import volumes between Canada and these two countries.

Obtaining specialized legal advice is important, not only to ensure compliance but also to maximize opportunities for applicable financial relief, including applications for remission orders.

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