Canadian Supply Chain Rules and Regulations: Latest Changes for Importers

October 27, 2026 | ATN Trade & Finance

The regulatory environment governing trade with Canada has changed more in 2026 than in the previous several years combined. The changes come from both directions: Canada has rewritten how it monitors aluminum origins, rolled out a new customs accounting system, imposed surtaxes on US goods, and tightened enforcement of its supply chain transparency law. The US has simultaneously expanded and modified the Section 338 tariff scope for Canadian goods. For any business with imports or exports moving across the Canada-US border, the compliance checklist has lengthened considerably. Here is a structured guide to the changes that are in effect now or took effect this year.

Canada's Surtax on US Goods: What Importers into Canada Must Know

Canada's response to the US Section 338 and Section 232 tariff actions was the United States Surtax Order (2026), confirmed by CBSA in Customs Notice 26-23 and effective September 8, 2026. The surtax covers approximately C$27.6 billion in US imports and applies at three rates — 15%, 25%, or 50% — depending on the tariff item, mapped to Schedules 1, 2, and 3 of the order.

Affected categories include steel and steel products, dairy and agricultural goods, appliances, agricultural equipment, pulp and paper, electronics, seafood, clothing, beauty and personal care products, and cooking appliances. The surtax applies only to goods eligible to be marked as US goods under CUSMA marking rules, so origin documentation is not optional — it is a threshold requirement.

Several practical details matter for compliance. The surtax applies even to de minimis shipments. Goods already in transit when the order took effect on September 8 are exempt, but importers must be able to prove transit status through a bill of lading, cargo control documents, or report-of-entry documentation. Goods shipped via a third country can still be subject to the surtax if they are US-origin under CUSMA marking rules.

On the accounting side, the surtax is declared on the Commercial Accounting Declaration in the CARM Client Portal, EDI, or API, using three new duty codes: 26186A (15%), 26186B (25%), and 26186C (50%). The surtax amount goes in field 85. GST is calculated on a value that includes the surtax, even where customs duties are otherwise remitted. Importers seeking relief through existing remission orders (for example, steel remission) should expect those to extend to the new surtax, though each must be confirmed. Surtax amounts cannot be appealed directly; CBSA re-determinations under section 60 of the Customs Act can be requested within 90 days of payment.

Aluminum Import Reporting: New Country-of-Origin Data Required Since October 1

Effective October 1, 2026, importers of aluminum products covered by the General Import Permit No. 83 (GIP 83) must declare three new data fields for every qualifying shipment, under CBSA Customs Notice 26-15 and the Order Amending GIP 83. The three fields are:

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

These fields are submitted through the Single Window Initiative Integrated Import Declaration. The data supports Canada's aluminum import monitoring program, which tracks origin for trade remedy and supply chain transparency purposes. Two exemptions exist: Customs Self-Assessment importers releasing goods under paragraph 32(2)(b) of the Customs Act, and shipments with a total value for duty of C$5,000 or less.

The practical burden falls on importers' supplier relationships. Obtaining smelt and cast country data requires asking overseas suppliers for production-level information they may not have previously been asked to provide, or tracked. Importers who have not yet updated supplier questionnaires, purchase-order fields, or customs broker instructions to capture this data are now out of compliance for covered shipments.

CBSA D-Memorandum Revisions and Other 2026 Customs Notices

The CBSA issued a significant cluster of D-Memorandum revisions and Customs Notices in 2026 that affect day-to-day import procedures.

D11-6-8, revised September 9, 2026, updates guidance on verifying non-FTA origin, tariff classification, and value for duty, reflecting the migration to the Commercial Accounting Declaration under CARM Release 3. The B3-3 and B2 forms that this replaces are no longer in use. Any importers or brokers still referencing these forms in internal templates, automated entry instructions, or standard operating procedures need to update them.

D18-5-1, amended June 30, 2026, reflects the temporary suspension of the federal fuel excise tax and updates CARM codes for excise exemptions and GST exemptions covering fuel, alcohol, tobacco, cannabis, vaping products, luxury vehicles, and similar goods. Importers of these categories should confirm their current CARM codes are correct and that automated entry instructions are not carrying forward outdated codes.

Customs Notice 26-17, issued for wood cabinets and vanities, imposed a provisional safeguard surtax of 25% of value for duty beginning July 31, 2026, for specified tariff items. It may last up to 200 days, meaning it could run through February 2027. Importers of cabinetry, vanities, or related wood furniture items must match their goods against the listed tariff items — product names alone are not sufficient — and review open purchase orders and bonded inventory.

Customs Notice 26-22 expanded CPTPP benefits to include UK, Channel Islands, and Isle of Man eligibility from September 1, 2026, with updated tariff files available September 16. Importers sourcing from these origins should confirm eligibility and ensure origin documentation is current.

Customs Notice 26-20 clarified that tariff-rate-quota goods require a valid shipment-specific Global Affairs Canada import permit to receive the within-access rate when entering a customs bonded warehouse — a rule unchanged in substance, but the notice was issued specifically because entries were being filed incorrectly.

The October 30 Section 338 Scope Changes: US Tariffs on Canada, Revised

While not a Canadian regulatory change, the US Section 338 tariff modifications effective October 30, 2026 directly affect the cost and sourcing decisions of importers on both sides of the border. The modification removes 22 HTS lines from the Section 338 duty and adds 100 HTS lines.

Removed from scope: specified plywood (seven HTS codes under heading 4412), plastic boxes and bags, corrugated cartons and boxes (4819.10.00 and 4819.40.00), paper-pulp packaging, refrigeration machinery (8418.69.01 and 8419.89.95), and filling and packing machinery. US importers of these specific Canadian goods who have been paying the 50% additional duty since August 22 should consult their customs broker about refund procedures for entries filed after that date.

Added to scope include approximately 43 carpet and textile floor covering lines (headings 5701–5705), wood products and wood packaging (multiple 4400-series codes), paints and coatings, personal care ingredients, sweetened cocoa powder under quota provisions, diagnostic reagents, chemical waste, plastic flooring, and certain valves and specialized equipment. US importers of these goods from Canada need to reprice affected supply before the end of this week.

Fighting Against Forced Labour and Child Labour: 2026 Reporting Requirements

Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211) remains in full effect, with the May 31, 2026 annual report deadline having passed for the most recent cycle. Public Safety Canada updated its guidance ahead of that cycle with several notable changes.

The clearest shift was the removal of PSC's earlier informal assurance that it would not pursue enforcement against sellers and distributors that chose not to report. That protection is gone. PSC has also refined the test for who qualifies as a non-reporting "very minor dealings" entity: the guidance now defines that category as importation or production activity that is incidental, low-volume, and not central to core business — and directs entities to assess their own status based on scale, frequency, and relevance to their operations.

Reports must include a description of the entity's structure, activities, and supply chains; steps taken to prevent and reduce forced and child labour risks; policies and due diligence processes; an assessment of effectiveness with year-on-year improvement goals; and an attestation signed by a governing body member. Personal information must be excluded from the submission. Entities operating across multiple jurisdictions can use the optional joint Canada-UK-Australia multi-jurisdictional template but remain individually responsible for satisfying each country's requirements.

What this means: The Canada-facing compliance landscape in late 2026 is not a single rule change — it is a simultaneous layering of new obligations across customs accounting, aluminum origin tracking, safeguard surtaxes, supply chain transparency, and tariff scope modifications. Businesses that treat customs as a back-office function rather than a front-of-supply-chain one face the highest exposure: the aluminum reporting requirement alone requires supplier-level data that cannot be collected at the point of entry. The Section 338 scope changes on October 30 require importers of Canadian goods to review their HTS classifications this week. And the removal of PSC's enforcement forbearance on the Forced Labour Act means the reporting obligation for eligible entities is no longer advisory in practice. Any business importing goods with Canadian content, sourcing from Canada, or sending US goods into Canada should be in active conversation with a licensed customs broker and trade counsel before November 1.

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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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