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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 19, 2026 | ATN Trade & Finance

Canadian importers are navigating a dense stack of regulatory changes in 2026 — several already in force, one pending in Parliament, and one proposed reform that could materially raise duty costs across complex supply chains. Here is what is current.

CARM Is Now Permanent

The CBSA Assessment and Revenue Management (CARM) system's transition period ended December 31, 2025. Since January 1, 2026, CARM is Canada's permanent customs accounting platform, and the temporary transition measures that gave importers flexibility during the rollout have expired. Commercial importers — resident and non-resident alike — must be registered in the CARM Client Portal, hold a Business Number, and enrol in the Release Prior to Payment (RPP) program with financial security posted if they want to release goods before duties are paid. Importers who are not yet compliant face delayed releases at the border.

Aluminum: New Country-of-Origin Reporting as of October 1

Effective October 1, 2026, importers of aluminum goods covered under General Import Permit No. 83 (GIP 83) must declare three new data fields at time of entry through the Single Window Initiative Integrated Import Declaration: the Country of Largest Smelt (CLS), the Country of Second-Largest Smelt (C2S) where applicable, and the Country of Most Recent Cast (CRC). The requirement flows from CBSA Customs Notice 26-15. Importers should be collecting this data from overseas suppliers now; goods below CAD $5,000 in value for duty and CSA-released shipments are exempt.

Valuation Reform: The "Last Sale" Proposal

The CBSA has proposed replacing Canada's longstanding first-sale customs valuation method with a last-sale approach — meaning duties would be calculated on the final sale price to a Canadian buyer rather than an earlier transaction in a multi-tier supply chain. A public comment period closed January 23, 2026. The change has not yet been finalized but is being closely watched: importers with offshore intermediaries who currently declare a lower first-sale value would face higher duty bases and meaningfully higher landed costs. Importers should review their current valuation method and consider seeking a CBSA advance ruling before the rule is codified.

Bill C-35: Forced Labour Import Ban Gets Sharper Teeth

Introduced in Parliament on June 12, 2026, Bill C-35 would create a new standalone statute strengthening Canada's existing prohibition on goods produced with forced labour. The bill would allow the Minister of Foreign Affairs to publish a list of specific goods — identified by producer, country, or region — where there are reasonable grounds to suspect forced labour. Importers of listed goods would face mandatory supply chain disclosure requirements, including documentation on parties, production locations, and traceability. Goods could be deemed prohibited if an importer fails to provide requested information. Public consultations on the regulatory approach were open as of July 2026; no goods are listed yet, but the framework, once enacted, creates real compliance risk for importers sourcing from high-risk regions.

Steel Surtaxes Still Active — and Enforced

Canada's 50% surtax on non-CUSMA, non-FTA steel above country-specific tariff-rate quota levels remains in effect, as does a 25% surtax on derivative steel products that took effect December 26, 2025. The CBSA has flagged surtax compliance as an active enforcement priority in 2026, alongside misclassification of supply-managed goods such as dairy and poultry, which can trigger over-access tariffs of up to 300%.

What this means: The combination of CARM's full activation, the new aluminum traceability mandate, and the pending last-sale valuation reform means the compliance burden for Canadian importers has risen materially in 2026. Bill C-35 adds a forward-looking risk that supply chain due diligence — not just tariff classification — is now a regulatory obligation in the making.

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