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Canadian Supply Chain Rules and Regulations: Latest Changes for Importers

Canadian Supply Chain Rules and Regulations: Latest Changes for Importers

ATN BREAKING NEWS |

Canadian Supply Chain Rules and Regulations: Latest Changes for Importers

October 8, 2026 | ATN Trade & Finance

A wave of regulatory changes has hit Canadian import compliance in the past few months — from a brand-new aluminum reporting requirement that took effect just last week to an update in how forced labour obligations are enforced at the border. Here is what importers into Canada need to know right now.

New Aluminum Import Reporting — Mandatory Since October 1

The most immediate change: as of October 1, 2026, importers of aluminum products listed under General Import Permit 83 on Canada's Import Control List must now report three new data elements through the CBSA's Single Window Initiative (SWI) Integrated Import Declaration (IID):

  • Country of Largest Smelt (CLS) — where the majority of the aluminum was smelted
  • Country of Second-Largest Smelt (C2S) — where applicable
  • Country of Most Recent Cast (CRC) — the country where the aluminum was last cast before import

The requirement flows from Customs Notice 26-15 and is designed to improve traceability of aluminum origin — a direct response to concerns about transshipment and circumvention of Section 232 measures. Exemptions apply for CSA importers under paragraph 32(2)(b) of the Customs Act and for shipments with a total value for duty at or below CAD $5,000. Any importer bringing aluminum into Canada this week who has not updated their IID filing process is already out of compliance.

CBSA "Last Sale" Valuation Proposal

A structural change to customs valuation is working its way through the regulatory process. The CBSA has proposed shifting from a "first sale" to a "last sale" valuation methodology — meaning the dutiable value of imported goods would be determined by the final transaction price paid to the Canadian buyer, not an earlier price in the supply chain. The comment period closed January 23, 2026, and the effective date remains to be confirmed. For importers who have structured their supply chains around first-sale valuation — particularly those using related-party pricing or multi-tier distribution — the shift would increase declared values and, in most cases, duty payable.

Key CBSA Notices and Regulatory Updates

Several other changes from 2026 require importers' attention.

Customs Notice 26-17 introduced a 25% provisional safeguard surtax on wood cabinets and vanities effective July 31, 2026, for up to 200 days. Importers of those product categories who have not reclassified or repriced contracts accordingly are carrying unplanned duty exposure.

Customs Notice 26-20 (August 21) clarified that goods subject to tariff-rate quotas (TRQs) held in Canadian bonded warehouses still require a valid Global Affairs Canada (GAC) import permit to qualify for the within-access tariff rate. This had been a source of confusion following CARM implementation.

D-Memorandum D11-6-8 (September 9) updated verification guidance and confirmed the transition from legacy B3-3 and B2 forms to the Commercial Accounting Declaration (CAD) under CARM Release 3. Importers still using paper B3 workflows should treat this as a firm deadline signal.

Customs Notice 26-22 (September 1) allows eligible goods from the United Kingdom, Channel Islands, and Isle of Man to receive CPUKT treatment under the CPTPP framework, with updated T2026-2 tariff schedule files available since September 16.

Forced Labour Reporting: Where Things Stand

Annual reports for fiscal year 2025 under the Fighting Against Forced Labour and Child Labour in Supply Chains Act were due May 31, 2026. Entities that produce goods in Canada or import goods into Canada — unless they have only "very minor dealings" — must file board-approved reports and complete the mandatory online questionnaire covering policies, risk identification methods, remediation processes, and year-over-year progress commitments.

Enforcement is no longer theoretical. The CBSA detained approximately 50 shipments in 2025 and denied entry to nine on forced labour grounds. Bill C-251, which would create a presumptive import ban on goods produced with forced labour, has not yet entered into force — but the current framework already gives CBSA authority to act at the border, and that authority is being exercised.

What this means for importers: October 1's aluminum origin reporting requirement is live — if your IID filings do not include CLS, C2S, and CRC fields for GIP 83 goods, your shipments are at risk of delay or rejection today. The CBSA "last sale" valuation proposal has no confirmed effective date yet, but warrants a supply chain cost audit now. And with nine shipments denied entry on forced labour grounds in 2025, the Supply Chains Act is past the awareness phase — compliance documentation needs to be on file, not in progress.

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