Canadian Supply Chain Rules and Regulations: Latest Changes for Importers

October 22, 2026 | ATN Trade & Finance

The past ten months have brought a wave of changes to how goods enter Canada — new customs accounting systems, mandatory aluminum traceability rules, a provisional safeguard surtax on cabinets and vanities, new UK tariff treatment under the CPTPP, and draft legislation that would fundamentally reshape forced labour enforcement at the border. Here is what importers need to know right now.

CARM Is Now the Law — Ten Months In

The CBSA Assessment and Revenue Management system (CARM) became Canada's permanent customs accounting and duty payment platform on January 1, 2026, when the transition period ended and amendments to the Customs Act took effect. Any importer that was hoping for another extension did not get one.

The practical requirements remain unchanged but are now fully enforced: all commercial importers — resident and non-resident — must be registered in the CARM Client Portal (CCP) with a Business Number (BN). Importers who want to release goods before paying duties must be enrolled in Release Prior to Payment (RPP) and have posted financial security. Importers who are not registered face potential release delays, with the CBSA accepting an administrative BN15 on a paper C-type CAD only in limited contingency situations.

The most recent operational update came September 9, 2026, when the CBSA revised Memorandum D11-6-8 to reflect CARM Release 3. The revision formally replaces the legacy B3-3 and B2 forms with the Commercial Accounting Declaration (CAD) as the instrument of record for accounting and adjustments. Importers and their brokers should confirm that internal systems and entry instructions no longer reference the old forms.

Aluminum: New Origin Reporting Mandatory Since October 1

One of the most operationally demanding changes of the year took effect October 1, 2026: mandatory country-of-origin reporting for aluminum imports covered by Global Inclusion Program 83 (GIP 83). The requirement flows from Customs Notice 26-15 and the Order Amending GIP 83.

Importers of covered aluminum products must now declare three new data elements through the Single Window Initiative (SWI) Integrated Import Declaration (IID) at the time of entry:

Country of Largest Smelt (CLS): required when the goods contain primary aluminum.
Country of Second-Largest Smelt (C2S): required when a second country contributed to the smelting of primary aluminum.
Country of Most Recent Cast (CRC): required for all GIP 83 goods, whether or not they contain primary aluminum.

Two categories are exempt: importers whose goods are released under paragraph 32(2)(b) of the Customs Act (CSA importers), and shipments with a total value for duty of CAD $5,000 or less.

The practical implication is significant for any importer sourcing aluminum products from Asia, the US, or multi-stage processing supply chains: the supplier must be able to provide smelt and cast country data before goods arrive at the Canadian border. Customs brokers, trade software, and internal procurement systems all need to be updated to transmit the new fields. Importers who have not yet identified which of their lines fall under GIP 83 should treat this as urgent — the requirement is already in force.

Wood Cabinets and Vanities: 25% Provisional Safeguard Surtax

A 25% provisional safeguard surtax on specified wood cabinets, vanities, and related products took effect July 31, 2026, under Customs Notice 26-17. The surtax is provisional — it can remain in place for up to 200 days, which means it could run through approximately February 16, 2027, pending a final determination.

Importers of affected products should confirm the specific tariff items covered (the surtax applies based on tariff item numbers, not product descriptions), review open purchase orders and any bonded inventory, and consult their broker on whether CUSMA origin, duty relief, drawback, or bonded-warehouse treatment applies to their specific supply lines.

UK Tariff Treatment Under CPTPP: Effective September 1

Canada extended CPTPP tariff treatment (CPUKT — Comprehensive and Progressive UK Tariff) to eligible goods from the United Kingdom, Channel Islands, and Isle of Man effective September 1, 2026, under Customs Notice 26-22. Updated tariff schedule files were published September 16.

Importers sourcing from the UK should confirm that each shipment qualifies for the treatment and that origin documentation is in order. This is a material benefit for categories where the MFN rate is high — but preferential claims require verifiable origin support.

Bill C-35: Forced Labour Import Ban Moving Through Parliament

The most significant structural change on the horizon is Bill C-35, the Ban on Importing Goods Made with Forced Labour Act, introduced June 12, 2026, and currently working through the legislative process after First Reading. It is not yet law, but its provisions signal where Canadian import enforcement is heading.

Bill C-35 would replace the existing import prohibition in the Customs Tariff with a standalone framework modelled more closely on the US Uyghur Forced Labor Prevention Act. Its core mechanism is a presumptive list — the Minister of Foreign Affairs could designate goods, producers, countries, or regions where there are "reasonable grounds to suspect" forced labour. Importers of listed goods would be required to provide supply chain tracing information to the CBSA on demand; if that information is not provided, the goods are deemed prohibited from importation. Importers and owners of prohibited goods would be jointly and severally liable for government costs of detention, storage, transport, and disposal — a significant financial exposure beyond the value of the goods themselves.

The bill adopts an ILO-based definition of forced labour that aligns with CUSMA's labour chapter, replaces the existing domestic definitions, and covers child labour implicitly through the same ILO standard. Customs officers could detain suspected goods for up to 90 days. Judicial review would run through the Federal Courts Act rather than the Customs Act's existing appeal process.

On October 8, 2026, the government published "What We Heard" consultation reports ahead of Bill C-35's next legislative stages. The reports confirm that feedback is informing future measures but create no new importer documentation requirements today. Importers with exposure to higher-risk supply chains — particularly in electronics, garments, solar components, and agricultural inputs — should be reviewing their supply chain tracing capabilities now, before the legislation is in force.

Other Active Regulatory Updates

Two additional CBSA notices are worth tracking. Customs Notice 26-20 (August 21, 2026) clarified that goods subject to a tariff rate quota (TRQ) still require a valid shipment-specific Global Affairs Canada permit for the within-access rate, even when stored in a bonded warehouse. Bonded storage does not defer or waive the permit requirement.

Memorandum D18-5-1 was amended June 30, 2026, updating excise and GST exemption codes in CARM following the temporary suspension of the federal fuel excise tax. Importers of affected fuel products should verify that current exemption codes in automated entry instructions are correct, since using outdated codes can trigger unnecessary duty assessments.

What this means: Canadian import compliance is in a period of compounding change. CARM is fully live, and the window for soft-pedaling non-compliance has closed. The aluminum origin rules are new and require cooperation from overseas suppliers — not just a box checked at the border. The wood cabinet surtax will run at least into early 2027. And Bill C-35, once enacted, will put the burden of proof on importers to demonstrate clean supply chains for designated categories rather than leaving it to the CBSA to prove forced labour was used. Importers who treat these updates as separate events will find themselves managing each one reactively. The pattern they describe together is a tighter, more traceable, more importer-liable Canadian customs framework — and 2027 will bring further tightening.

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Canadian Supply Chain Rules and Regulations: Latest Changes for Importers

Canadian Supply Chain Rules and Regulations: Latest Changes for Importers

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