CBSA published its updated trade compliance verification priorities for 2026, and if you import steel, aluminum, or anything where origin matters for duty relief, you need to read this carefully. McMillan LLP, EY, and McCarthy Tétrault all flagged the same thing in their August 2026 analyses: CBSA auditors are expanding their focus on steel and aluminum classifications and trade agreement origin claims. That's not a coincidence. That's a signal.
Verification priorities are how CBSA tells the trade community where it's going to spend its audit budget. When steel and aluminum show up on that list with expanded scope, importers in those sectors are going to get letters. Some already have.
Here's what's on the list, what CBSA is actually looking for, and what you should do before they come looking at you.
What CBSA's Trade Verification Program Actually Is
A lot of importers confuse trade verifications with random audits. They're not random. CBSA's compliance verification program targets specific HS codes and compliance issues that the agency has identified as high-risk based on trade data, tip-offs, and its own internal analysis. Every year, CBSA publishes a list of what it's looking at. Every year, some importers ignore it. Those are usually the ones calling me in a panic six months later.
A trade verification can take a few forms. A desk review means CBSA sends you a letter asking for documentation on past transactions, typically going back four years. A field verification means an auditor shows up at your place of business. Either way, you're looking at a review of your accounting records, your supplier documentation, your tariff classifications, and your origin declarations.
If CBSA finds errors, you're on the hook for the duties and taxes you underpaid, plus interest. If the errors look intentional or show a pattern of non-compliance, penalties under the Administrative Monetary Penalty System can stack up fast. We're talking $25,000 per transaction in serious cases. I've seen importers walk away from a single verification owing over $200,000 when you add up reassessments across four years of entries.
The CARM portal is now where all of this gets managed. Your compliance history, your security, your account balance. If you're not set up properly in CARM, a verification gets even messier. Check your CARM readiness before anything else.
Steel and Aluminum: Why CBSA Is Watching These Sectors So Closely
This didn't come out of nowhere. Steel and aluminum have been politically and commercially sensitive for years. The Section 232 tariffs the US imposed, Canada's retaliatory surtaxes, the ongoing surtax framework under the CUSA, and persistent concerns about circumvention from third countries have all put these sectors under a microscope.
The core problem CBSA is trying to solve is transshipment and origin washing. That's where steel or aluminum produced in a country subject to high duties, China being the obvious example, gets shipped through a third country, minimally processed, and then declared as originating from that third country to avoid the surtaxes. It's fraud. CBSA knows it happens. And they've gotten better at detecting it.
The 2026 verification priorities reflect that. Importers claiming preferential origin under CUSMA for steel and aluminum products are going to face harder questions about whether their goods actually meet the rules of origin. And importers classifying steel mill products need to be confident their HS codes are right, because misclassification in this sector is expensive.
The HS Codes Under the Microscope
Steel and aluminum span a wide range of the tariff schedule. The chapters you need to pay attention to are Chapter 72 (iron and steel), Chapter 73 (articles of iron or steel), Chapter 76 (aluminum and articles thereof), and to a lesser extent Chapter 74 (copper, which sometimes gets pulled in when products have mixed metal content).
Within those chapters, CBSA has historically focused verification efforts on:
- Flat-rolled steel products under HS heading 72.08 through 72.12, where the distinction between hot-rolled and cold-rolled, and between coated and uncoated, affects both the tariff rate and the applicable surtax
- Tubes, pipes, and hollow profiles under headings 73.04 through 73.06, where country of origin claims have been a persistent problem
- Aluminum sheet and strip under heading 76.06, particularly where importers are claiming CUSMA origin
- Fabricated structural steel under heading 73.08, where the line between a manufactured article and a steel product can shift the applicable duties significantly
If your business touches any of these, pull your last 12 months of entries and look at what tariff treatment you've been claiming. Not what your broker filed. What your broker filed based on what you told them. Because when CBSA comes knocking, the importer of record is responsible, not the broker.
Origin Claims: Where Most Importers Get Into Trouble
The expanded focus on trade agreement origin compliance is the part of the 2026 priorities that I think catches the most importers off guard. Everyone knows about CUSMA. Not everyone understands what it actually takes to claim CUSMA preferential rates correctly.
To claim CUSMA origin, your goods need to meet the rules of origin set out in the agreement. For steel and aluminum, those rules are specific and, in some cases, quite demanding. The tariff shift rules, the regional value content thresholds, and the product-specific rules all have to be satisfied. And you need documentation to prove it.
Here's where importers consistently get it wrong. They get a certificate or certification of origin from their supplier, they attach it to the file, and they think they're done. They're not. CBSA can ask you to prove that the certification is accurate. That means going back to your supplier and getting the underlying documentation: mill certificates, production records, bills of materials, supplier declarations tracing the inputs back to their origin.
A furniture importer we worked with had been claiming CUSMA on steel hardware sourced from a US supplier for three years. The supplier had provided certifications. What the supplier hadn't told them was that the steel inputs were sourced from a country that didn't qualify under CUSMA rules of origin. When CBSA verified, the importer owed duties and surtaxes on four years of entries. The supplier was sympathetic. The bill was still the importer's problem.
For a deeper look at how advance rulings can protect you on origin questions before you start importing, see our advance rulings guide.
What Documentation You Need to Survive a Verification
CBSA gives you 30 days to respond to a desk verification request. That sounds like a lot. It isn't, especially if your records are scattered across emails, your ERP system, your broker's portal, and a filing cabinet in the warehouse.
Here's what you need to have ready for steel and aluminum entries:
Commercial Documentation
- Commercial invoices showing the actual price paid, the seller, the buyer, and a description of the goods that matches what was declared at the border
- Bills of lading or airway bills showing the actual routing of the shipment
- Packing lists
- Any contracts or purchase orders that governed the transaction
Origin Documentation
- Certifications of origin (under CUSMA, these can be made by the exporter, producer, or importer, but someone has to own the claim)
- Mill certificates showing where the steel or aluminum was produced
- If you're the importer making the origin certification yourself, you need a basis for that certification, which means supplier declarations and production records
- Any advance rulings you obtained from CBSA on origin
Classification Support
- Technical specifications or product data sheets that support your tariff classification
- Any advance rulings on classification
- If you changed classifications at any point, documentation of why
Valuation Records
- Evidence that the declared value reflects the price actually paid or payable
- Records of any assists, royalties, or other additions to value that should have been included
- Transfer pricing documentation if you're importing from a related party
Keep these records for six years from the date of accounting. That's the statutory requirement under the Customs Act. Four years is the typical verification lookback period, but CBSA can go further in cases of fraud or gross negligence.
How to Self-Audit Before CBSA Does It for You
The best time to find a problem is before CBSA does. If you self-correct through a voluntary amendment or a re-determination request, you avoid penalties. You still pay the duties and interest, but the AMPS penalties don't apply to voluntary disclosures made before a verification is initiated.
Here's a practical self-audit process for steel and aluminum importers.
Step 1: Pull Your Entry Data
Get a list of all your entries for the past four years that involve Chapters 72, 73, and 76. Your broker can pull this from their system. You want the HS code, the tariff treatment code, the declared origin, and the duty paid on each entry.
Step 2: Check Your Tariff Treatment Codes
Look at the tariff treatment column. If you're claiming CUSMA (tariff treatment code 10), you need a valid origin certification on file for every one of those entries. If you don't have it, that's a problem you need to fix now, not when CBSA asks.
If you're claiming MFN (Most Favoured Nation) rates, check whether any surtaxes should have applied. Canada's steel and aluminum surtax framework has been updated multiple times. Entries from 2022 onward need to be checked against the surtax schedules that were in effect at the time of import.
Step 3: Verify Your HS Codes Against the Goods
Take your top 10 steel or aluminum products by import volume and look at the HS codes that were declared. Then look at the actual product: what is it, how is it made, what are its physical characteristics. Does the code match? If you're not sure, that's what advance rulings are for. Get one before CBSA tells you the code is wrong.
Pay particular attention to the distinction between articles of steel (Chapter 73) and steel mill products (Chapter 72). An importer we worked with was classifying fabricated steel frames under Chapter 72 because they thought of them as "steel." They were actually finished articles under Chapter 73, which had a different duty rate and different surtax treatment. Four years of entries, wrong classification, significant reassessment.
Step 4: Trace Your Origin Claims Back to the Mill
For every CUSMA claim, go back to your supplier and ask for the mill certificate. The mill certificate will show where the steel or aluminum was actually produced. If the mill is in a CUSMA country, great. If it's not, your origin claim may not hold up.
This step takes time. Start it now. If you find a problem, you want time to assess the exposure and decide whether to file a voluntary amendment before CBSA initiates a verification.
Step 5: Document What You Find
Keep a record of your self-audit. If CBSA does initiate a verification later, being able to show that you conducted a good-faith review and corrected any errors you found is meaningful. It doesn't eliminate liability, but it demonstrates the kind of reasonable care that can affect how CBSA treats you during the process.
CARM and Trade Verifications: How They Connect
CARM changed how duties and taxes are managed, but it didn't change CBSA's authority to verify past entries. What it did change is how your compliance history is tracked and how quickly CBSA can see patterns in your import data.
Under CARM, your import history is more centralized and more accessible to CBSA analysts. That's good for legitimate importers with clean records. It's not great if you've been filing entries with recurring errors. The data that CBSA uses to select verification targets is increasingly drawn from the CARM system, which means patterns that might have been harder to spot before are now more visible.
Make sure your CARM account is current, your financial security is adequate for your import volumes, and your delegate access is set up correctly so your broker can act on your behalf during a verification. If any of that is unclear, our CARM readiness checklist walks through the account setup requirements.
What Happens If CBSA Finds Errors
If a verification turns up underpaid duties, CBSA will issue a re-determination or a further re-determination under section 59 of the Customs Act. You'll owe the difference in duties and taxes, plus interest calculated from the date the duties were originally due.
On top of that, AMPS penalties can apply. The penalty amounts depend on the type of violation and whether it's a first, second, or subsequent occurrence. For origin-related violations, penalties under AMPS can reach $25,000 per transaction. For classification errors, the scale is similar. Multiply that across four years of entries and you can see how quickly this becomes a serious financial problem.
You have the right to appeal a re-determination. The process goes from a request for re-determination to CBSA, then to the Canadian International Trade Tribunal, and ultimately to the Federal Court of Appeal. Most importers settle before it gets that far, but knowing your appeal rights matters.
The D-memoranda that govern trade verifications, voluntary amendments, and appeals are worth reading if you're facing a verification. D11-6-6 covers the reason to believe standard that CBSA uses when initiating verifications, and it's useful to understand what triggers the process.
A Note on Working With Your Broker
Your customs broker files entries on your behalf. They're not responsible for the accuracy of the information you give them. If you tell your broker the goods are from the US and they're actually from China via a Mexican facility that did minimal processing, your broker filed what you told them. The liability is yours.
That said, a good broker should be asking you the right questions. If your broker has never asked you for a mill certificate or asked you to explain the basis for a CUSMA claim, that's a conversation worth having. Not because they're doing anything wrong, but because the importer and broker need to be aligned on what documentation exists and what it supports.
Honestly, most importers don't think about this until they get a verification letter. By then, the entries are filed, the goods have been sold, and the documentation is wherever it ended up. Getting organized before that happens is the whole point of this exercise.
Frequently Asked Questions
How do I know if my company is on CBSA's verification target list?
You won't know in advance. CBSA doesn't publish a list of specific companies it's targeting, only the sectors and compliance issues it's prioritizing. If you import in the priority sectors, you should assume you could be selected. The best preparation is the same regardless: clean records, solid documentation, accurate classifications.
Can I claim CUSMA origin based on my supplier's certification alone?
You can use a supplier's certification as the basis for your claim, but you're responsible for the accuracy of that claim. If CBSA asks you to support it, "my supplier gave me a certificate" isn't enough. You need to be able to show that the certification is accurate, which means having access to the underlying documentation. Talk to your supplier now about what records they can provide if you're ever asked.
What's the difference between a desk review and a field verification?
A desk review is conducted by correspondence. CBSA sends you a letter requesting specific documents for specific entries, you send them in, and CBSA reviews them. A field verification involves an auditor visiting your business to review records on-site. Field verifications are more intensive and typically happen when CBSA has identified a more significant compliance concern or when the volume of documentation makes a desk review impractical.
If I find an error in my past entries, should I file a voluntary amendment?
Generally, yes. A voluntary amendment filed before CBSA initiates a verification avoids AMPS penalties. You'll still owe the duties and interest, but the penalty exposure is eliminated. Talk to your broker or a trade counsel before filing, because how you frame the amendment matters and you want to make sure you're capturing the full scope of the error rather than partially disclosing and leaving yourself exposed on the rest.
How far back can CBSA go in a trade verification?
The standard lookback period is four years from the date of accounting. In cases involving fraud or misrepresentation, there's no statutory limitation. For most commercial importers dealing with classification or origin errors, four years is the practical window you need to worry about.
My steel comes from a US service center. Does that automatically qualify for CUSMA?
Not automatically. The US service center needs to have added sufficient value or processing to meet the CUSMA rules of origin for the specific product. If the service center is just cutting, slitting, or repackaging steel that originated in a non-CUSMA country, that processing may not be enough to confer CUSMA origin. Ask your service center where the underlying steel was melted and poured, and get that in writing.