Tax Insights: Are your goods on the list? CBSA releases an expanded list of trade compliance verification priorities

Issue 2026-02

In brief

What happened? 

The Canada Border Services Agency (CBSA) has released an updated list of its trade compliance verifications¹ for January 2026. The list has significantly expanded to include:

• origin verifications of certain trade agreements (i.e. the Canada-United States-Mexico Agreement (CUSMA) relating to automotive, the Canada-European Union Comprehensive Economic and Trade Agreement (CETA) and the Canada-United Kingdom Trade Continuity Agreement (CUKTCA))
• surtax-related verifications of the China surtax orders (2024) and multiple United States surtax orders

The expanded CBSA compliance priorities list is likely a result of recent significant changes to the global trade landscape due to US tariff policies and Canada’s response to US tariffs by imposing a Canadian surtax on certain imports.

Why is it relevant?

More businesses that import goods could be subject to a CBSA trade compliance verification (or audit), especially since trade agreements and surtax orders can apply to a wide range of imported goods. Importers with goods on the list should prepare for the likelihood of a CBSA trade compliance verification in the near future, the results of which may include payment of additional duties or surtaxes, Goods and Services Tax (GST), interest and penalties. Given the retrospective nature of these audits, assessed amounts tend to be difficult to recover from customers through increased pricing.

Actions to consider

Importers should proactively review CBSA’s published compliance verification priorities to determine whether any of their imported goods fall within these targeted areas. Understanding whether a product is designated as a compliance priority helps organizations assess their exposure and the potential implications of being selected for a CBSA trade compliance verification. In addition, importers should review their historical import data (which is available through the CARM Client Portal) annually to evaluate how current verification priorities may affect their operations. If errors or inconsistences are identified, take corrective action before being notified of a CBSA audit to mitigate punitive interest and potential penalties.

In detail

What is a trade compliance verification?

The CBSA manages the verification program in two ways – by random verifications and through verification priorities. The list of verification priorities is continuously updated so that it reflects the CBSA’s assessment of non‑compliance with customs legislation to ensure that importers comply with the requirements for tariff classification, customs valuation and origin and, more recently, to comply with surtax orders (i.e. on certain Chinese- and US-origin goods). The verification priorities are generally imports from a specific category of goods or a specific industry. 

Some priorities carry over from one year to the next and some remain on the list for several years, e.g. the valuation of apparel (the CBSA has been targeting clothing and apparel for many years and there have been numerous related audits and assessments). However, with the evolving trade landscape, origin verifications under trade agreements and surtax-related verifications have been added to the priorities list.  

The overall goal of these verifications is to:

• enforce compliance with customs requirements, and 
• ensure that the correct amount of duties (or surtax) is being assessed  

All importers are at risk of random or compliance-based verifications.

The targeted priorities list

There are currently nine targeted verification priorities, of which four relate to surtax orders (for China and the United States). The nine priorities are all related to tariff classification and are summarized in the Appendix. Although there are currently no specific targeted priorities for origin of goods and customs valuation, the CBSA remains focused on origin verifications under CUSMA (automotive), CETA and CUKTCA, as discussed below.

Other compliance priorities 

The CBSA significantly expanded its list of compliance priorities in January 2026. Nine of those priorities are on the targeted priorities list (see above and in the Appendix). The remaining compliance priorities are listed below and could be subject to CBSA trade verifications, or added to the targeted priorities list, at any time. The CBSA may add or revise their priorities throughout the year based on risk and revenue exposure. The other compliance priorities follow: 

• tariff rate quotas and classification of supply managed goods (such as classification of certain cheese treats for dogs)
• GST and excise duties and taxes (GST exemption codes, vaping products subject to excise duties and taxes, precious metals)
• import origin verifications under trade agreements (CUSMA relating to the automotive industry, CETA and CUKTCA)
• Duties Relief Program (reviews of licensees importing supply managed goods)
• surtax-related verifications (United States Surtax Order (Motor Vehicles 2025), Order imposing a Surtax on the importation of Certain Steel Goods, Steel Goods and Aluminum Goods Surtax Order and Steel Derivative Goods Surtax Order)²
• energy commodities (final accounting of energy-related imports and verifying electricity imports under chapter 27 of the Customs Tariff)

Tariff classification issues 

The main tariff classifications issues relate to importers classifying their goods under a code that is duty free or at a lower duty rate. This includes goods that:

• have been misclassified in the past (e.g. gloves under headings 39.26 and 42.03)
• are subject to high duty rates, or
• are from regions with known compliance issues

Importers should review their classifications to ensure compliance and limit the potential for duty exposures.

Customs valuation issues 

The main customs valuation issues for all importers include: 

• using an incorrect valuation method (e.g. the importer incorrectly reports the original cost) 
• ensuring that the importer is also a purchaser in Canada (a defined term in Canadian law) so that the transaction value method can be used 
• adding to the reported value for duty, when applicable, an amount for "assists," royalties and subsequent proceeds (e.g. management/administrative fees, etc.) 

It is important to note that not all audits are based on verification priorities. Although the priorities on the list focus on risk in the three principal customs areas (tariff classification, valuation and origin), verifications of import compliance can also cover other customs programs (e.g. trade incentives and compliance with areas of regulation administered by other government departments). Importers of goods that are not included on this list should, nevertheless, be aware that the CBSA also conducts random or compliance-based verifications. 

Importers should review their customs compliance practices to ensure that they are compliant and can withstand a CBSA audit. 

Customs origin issues 

The CBSA may audit any goods that are imported into Canada, including those that benefit from duty‑free status because of a trade agreement. The CBSA is actively conducting CUSMA‑origin verifications focused on the automotive sector and continues to conduct CETA- and CUKTCA‑origin verifications. When importers rely on a trade agreement, they must ensure that these goods meet all the requirements under the relevant agreement, such as the information outlined in the rules of origin. Regardless of who completes the certificate of origin, the importer bears the ultimate responsibility for any information reported to the customs authority and must ensure that the evidentiary support is available at the time of declaration. 

The takeaway

If your business imports goods into Canada, you should: 

• know what your business actually imports
• pay extra attention to your import practices and customs paperwork 
• determine your level of compliance with the legislative requirements and any overpayments 
• take corrective action before you are notified of a CBSA audit to mitigate punitive interest and potential penalties 
• be aware that a negative audit finding can hurt your business financially and could lead to a reassessment or supply chain disruptions due to closer scrutiny by the CBSA 

Our customs specialists can work with you to evaluate your customs and trade compliance practices, guide you step-by-step to correct past errors and improve these practices going forward.

<sup>1. “Trade compliance verifications,” Canada Border Services Agency (January 2026).
2. See our Tax Insights:
- “US tariffs on imports of automobiles and automobile parts from Canada” (May 2, 2025 update)
- “Canada implements tariff rate quotas and surtaxes on imports of steel mill products” (December 3, 2025 update)</sup> 

Appendix

^{3. See our Tax Insights “Canada to impose surtaxes on steel and aluminum products from China and Chinese-made electric vehicles” (October 29, 2024 update).}