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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 20, 2026 | ATN Trade & Finance

Five regulatory developments are reshaping what Canadian importers must document, declare, and prove — from a new aluminum data requirement that took effect October 1 to a forced labour import overhaul making its way through Parliament.

New: Aluminum Smelt and Cast Country Reporting (Effective October 1)

The most immediate change for aluminum importers: as of October 1, 2026, reporting the country of production origin is now mandatory through Canada's Single Window Initiative Integrated Import Declaration (SWI IID), under amendments to General Import Permit No. 83 (CBSA Customs Notice 26-15). Importers must now declare three data elements at entry: the Country of Largest Smelt (CLS) and Country of Second-Largest Smelt (C2S) for goods containing primary aluminum, and the Country of Most Recent Cast (CRC) for all goods covered by GIP 83. Exemptions apply only to Customs Self-Assessment importers releasing under paragraph 32(2)(b) of the Customs Act and to shipments with a total value for duty of CAD $5,000 or less. The key compliance risk: country of export and country of smelt are often different, and importers must get the upstream production-chain data from their mills and suppliers — not just from the invoice.

Bill C-35: Forced Labour Import Ban Gets a Structural Overhaul

Introduced June 12, 2026 and currently at first reading, Bill C-35 would replace Canada's 2020 blanket forced labour import ban with a targeted, list-based model. Under the new framework, the Minister of Foreign Affairs could 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 — and failure to provide it would deem the goods prohibited. Critically, CBSA determinations under Bill C-35 would not be subject to administrative appeal; the only recourse is judicial review. Enforcement of the existing ban is already ramping up: CBSA detained approximately 50 shipments in 2025, of which nine were denied entry. Consultation "What We Heard" reports were released October 8, informing the next legislative steps.

Modern Slavery Reporting: Enforcement Window Opening

The second annual reporting cycle under Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act had a May 31, 2026 deadline for reports covering 2025 fiscal-year activities. Public Safety Canada is developing an assessment tool — expected by early 2026 — to evaluate report quality, and enforcement of reporting obligations is considered possible in 2026 or later. Importers who produce or import goods into Canada must assess applicability annually; late filing carries enforcement risk and is publicly flagged. Reports require governing-body approval, PDF format, and alignment with the online questionnaire.

Steel Surtax Regime: Hierarchy and Compliance Checks

Canada's steel surtax framework has two layers in force simultaneously. A 50% surtax on non-US/non-Mexican steel imports above country-specific TRQs has applied since August 1, 2025, and requires a shipment-specific GAC import permit to access in-quota rates. A 25% surtax on derivative steel products from all countries took effect December 26, 2025. The surtaxes are non-stackable: the over-quota surtax takes priority, followed by the US, China, or melted-and-poured surtaxes, then derivative surtaxes. CBSA has flagged surtax classification and origin accuracy as a 2026 compliance priority, meaning audit exposure is elevated for importers who haven't reviewed their steel HS codes and country-of-origin documentation.

CBSA Valuation Proposal: Watch the Canada Gazette

A proposed amendment to Canada's customs valuation rules would move toward a "last sale" approach for determining transaction value, which could raise declared values and — in turn — duties owed. The December 2025 revision excludes sales between two Canadian-resident entities meeting eight defined "substantial presence" criteria. Public consultation closed January 23, 2026. The amendment has not yet appeared in the Canada Gazette and is not in force, but importers with related-party transactions or multi-tier supply chains should review their valuation methodology now and consider requesting advance rulings before the rule is finalized.

What this means: The aluminum smelt reporting requirement is live and operational today — any importer with GIP 83 goods who has not yet updated their SWI IID declarations and supplier data requests is already out of compliance. The Bill C-35 and forced labour threads are moving more slowly but will raise the documentary bar significantly once in force: the shift to a list-based regime with no administrative appeal means the risk of a wrong import decision is considerably higher than under the current framework.

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