Canadian Supply Chain Rules and Regulations: Latest Changes for Importers
October 21, 2026 | ATN Trade & Finance
Four regulatory changes are actively reshaping what Canadian importers must track, report, and prove. Two are already in force; two are moving through Parliament. Here is what changed, what is coming, and what requires action now.
1. Aluminum Origin Reporting: Mandatory Since October 1
The most immediately operational change is CBSA Customs Notice 26-15, which became mandatory on October 1, 2026. Importers of aluminum products covered by General Import Permit No. 83 must now declare three country-of-origin fields at entry through the Single Window Initiative Integrated Import Declaration: the Country of Largest Smelt (CLS), the Country of Second-Largest Smelt (C2S) where a second country contributed to primary aluminum production, and the Country of Most Recent Cast (CRC) for all covered goods. The requirement applies regardless of whether the goods contain primary aluminum or not, subject to the C2S field.
Two exemptions exist: Customs Self-Assessment importers whose goods are released under paragraph 32(2)(b) of the Customs Act, and shipments with a value for duty of CA$5,000 or less. All other covered importers needed their customs brokers and purchase-order systems updated before October 1 — if that work has not been done, shipment data may already be non-compliant.
2. Wood Cabinets and Vanity Surtax
Customs Notice 26-17, issued July 31, 2026, imposed a provisional 25% safeguard surtax on specified wood cabinets, vanities, and subassemblies. The measure can last up to 200 days and covers specific tariff items — not general product descriptions — so importers in the kitchen, bath, and furniture categories should match their HS codes precisely against the notice rather than relying on product names. The notice also affects CUSMA treatment, bonded warehouse inventory, and drawback eligibility on affected goods.
3. Bill C-35: A New Forced Labour Import Framework
Introduced June 12, 2026, Bill C-35 would replace the existing blanket forced labour prohibition under the Customs Tariff with a targeted, list-based regime. The Minister of Foreign Affairs would have authority to designate specific goods — by producer, country, or region — as high-risk. Importers of listed goods would be required to provide enhanced supply chain tracing information to CBSA on request. Failure to comply triggers a deemed prohibition, and CBSA would gain authority to detain goods for up to 90 days pending a determination.
Critically, Bill C-35 removes administrative appeal rights: CBSA determinations under the new regime would be subject only to judicial review under the Federal Courts Act — a significant procedural shift for importers contesting a detention. The bill has not yet reached second reading, but on October 8 the government released its "What We Heard" consultation findings. Stakeholder feedback broadly supported the risk-based approach and requested clear guidance, transparency in list-building, and procedural fairness. A parallel legislative stream is exploring civil liability and mandatory due diligence obligations for companies with international supply chains.
4. CBSA "Last Sale" Valuation Rule: Watch This Space
A proposed change to customs valuation methodology — moving from first-sale to last-sale pricing as the basis for calculating value for duty — would materially increase duty costs for importers operating layered supply chains. The comment period on the proposal closed January 23, 2026, and no implementation date has been announced. The change would raise declared values and, in turn, the duty base for all ad valorem tariffs. Supply chain and procurement teams should be modelling the landed-cost impact now, since the rule could be finalized with limited lead time.
Other Active Changes
Two additional notices are in effect. CBSA's revised D-Memorandum D11-6-8 (September 9, 2026) reflects the CARM Release 3 transition: the Commercial Accounting Declaration has replaced the B3-3 and B2 forms. Customs Notice 26-22 (September 1, 2026) allows eligible goods originating in the UK, Channel Islands, or Isle of Man to receive CPUKT preferential treatment under the CPTPP — a change that benefits importers sourcing from those origins but requires verified origin documentation and updated broker classification tables.
What this means: The aluminum reporting requirement is live and may already have a compliance gap for importers who missed the October 1 effective date. The wood cabinet surtax is actively adding 25% to landed costs for affected SKUs. Bill C-35 and the forced labour consultation signal a coming wave of supply chain due diligence obligations that will raise the documentation bar significantly — particularly for goods sourced from high-risk regions. Importers should treat the next six months as a preparation window, not a waiting period.
Sources:
- New Aluminum Import Reporting Requirements Coming October 1, 2026 — Livingston International
- CBSA 2026 D-Memorandum Revisions and Customs Notices Explained — Logistic North
- Canada Raises the Bar on Forced Labour Enforcement: Bill C-35 — DLA Piper GENIE
- Government of Canada Releases What We Heard Reports on Fighting Forced Labour — Canada.ca
- CBSA Proposed "Last Sale" Rule — C.H. Robinson