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CBSA TARGETTING CHEESE DOG TREATS

IMPORTERS OF DOG TREATS COULD FACE MASSIVE DUTY ADJUSTMENTS

The Canada Border Services Agency (“CBSA”) has listed verifying tariff classifications of cheese treats for dogs (“Cheese Treats”) as one of its compliance priorities for 2026. While it may sound niche, CBSA has identified Cheese Treats as a potential threat to Canada’s supply-managed dairy system, which is one of Canada’s most consequential – and sometimes controversial – trade barriers.

In this Customs & Trade Report, we explain what is behind this strange new CBSA effort, and why impacted importers could face significant financial risk.

The Core Issue: HUGE Duty Differential

At the heart of this verification priority is the massive duty differential between animal feed, like dog treats, and dairy products.

In Canada’s Customs Tariff, “preparations of a kind used in animal feeding” are classified under heading 23.09 and can be imported with relatively low duties. On the other hand, cheese is classified under heading 04.06 and, as a dairy product subject to Supply Management, comes with enormous duties essentially calculated to make importation impossible – like 245%!

The CBSA’s concern is for technical compliance with the Customs Tariff, which requires that goods bear the appropriate tariff classification. Whether or not they are marketed to dogs is irrelevant to whether the product is a “cheese” for tariff classification purposes, and putting a picture of a dog on a product is not enough to change its tariff classification.

Why Cheese Treat Importers Must Act Now

At the conclusion of a customs audit (technically called a “verification”), the CBSA will generally assess certain selected import transactions and issue a Statement of Adjustment. The importer will then be required to file self-corrections with respect to any other importations impacted by the same issue (“Self-Corrections”).

Many importers are surprised to learn that in order to dispute a Statement of Adjustment or a Self-Correction (and there is often good reason to do so), the importer must first pay the duties owing (or post satisfactory security for the full amount of the duties).

When dealing with supply-managed products with exceptionally high duty rates, it is not uncommon to see CBSA assessments in dollar amounts that small importers simply cannot pay or post security for. This essentially leaves these businesses unable to challenge the CBSA’s decision because they cannot afford to.

For this reason, the recommended approach when facing a verification by the CBSA is to get Experienced Customs Counsel to provide you guidance from the start. A business ought to put its best foot forward when dealing with the CBSA, and make submissions on any points in dispute before the CBSA concludes its verification.

Takeaways

One of CBSA’s latest compliance priorities is verifying tariff classifications used by importers of Cheese Treats for dogs. This is the latest example of CBSA taking strong action to uphold Canada’s supply-managed dairy industry.

Compliance disputes with CBSA are uniquely expensive and difficult because, once CBSA has issued an Adjustment, the importer must pay, or post security for, the re-assessed duties before appealing and seeking a re-determination.

For this reason, Experienced Customs Counsel should be involved at the start of a CBSA compliance review – CBSA even proposes adjustments. 

For help with a CBSA Audit, please click here.

Download a PDF copy of this Blog here.