The Canada Border Services Agency (CBSA) recently released its verification priority list for January 2026. In this week’s post, we are going to give you an overview of the contents of the recently released verification list, its importance to importers, and some tips for importers to stay compliant in the face of a Customs inspection.

What is a CBSA Trade Verification Priorities List?

Twice a year, the CBSA releases a list of commercial goods it is focusing on for inspections and verification. Typically, this focus manifests as targeted checks on the listed commercial goods to ensure they comply with trade rules. The Government of Canada sets priorities for these verifications based on risk, with new targets added or removed twice a year, typically in January and July. 

What is the CBSA Looking For?

Pre and post-release assessments evaluate the components of compliant importing, with other details as necessary. Those components include:

1. Tariff Classification: Does your import use the appropriate application of HS codes?
2. Valuation: Does your import use the correct application of the six methods of valuation to ensure the correct payment of duties and taxes on the goods?
3. Origin: Is your import accurate in its application of origin rules in accordance with legislative requirements?
4. Exemptions and Remissions: Are duty and tax exemptions and remissions being applied accurately?

What to Expect from the CBSA?

Should CBSA feel it necessary, they can issue the following communications to importers, notifying them of CBSA intervention:

• Trade Advisory Notice (TAN): Functionally, the TAN is a 'nudge' indicating a potential area of non-compliance. This letter serves as a request for the importer to review the declaration in question, but carries no monetary assessment.
• Compliance Validation Letter (CVL): The CVL comes when the CBSA suspects an instance(s) of non-compliance and requests additional supporting information within 30 days.
• Directed Compliance Letter (DCL): The DCL is the letter you most want to avoid. It is when CBSA knows of an instance(s) of non-compliance and issues a monetary penalty.

Additionally, with the full implementation of CARM, the CBSA intends to use it to validate duties and taxes and conduct compliance interventions to address areas of known or suspected non-compliance. CARM is the CBSA’s primary point of contact and notification for importers, so be sure to keep an eye on your portal for any relevant information regarding the verification of your import. 

January 2026 CBSA Trade Compliance Verification List

January’s list includes the following as compliance priorities in addition to the list of concerned goods. This list is pulled, in brief, from the trade priority page. For full details on each entry, you are encouraged to visit the trade verification site. 

Compliance Priorities 

The CBSA has identified the following compliance priorities:

• Tariff rate, quota, and classification of supply-managed goods
  
  • Verifications on the classification of frozen desserts containing 5% of dairy products
  • Verifications on the classification of cheese treats for dogs (preparations of a kind used in animal feeding under heading 23.09)
  • Verifications on the classification of spent fowl products
• GST and excise duties, and taxes
  
  • Verifications on the classification of frozen desserts containing 5% of dairy products
  • Verifications on the classification of cheese treats for dogs (preparations of a kind used in animal feeding under heading 23.09)
  • Verifications on the classification of spent fowl products
• Canada-United States-Mexico Agreement (CUSMA) origin verifications:
  
  • Automotive industry
• Import origin verifications under:
  
  • Canada-European Union Comprehensive Economic and Trade Agreement (CETA)
  • Canada-United Kingdom Trade Continuity Agreement (CUKTCA)
• Duties Relief Program (DRP)
  
  • Verifications of licensees importing supply-managed goods

The following additions to the Trade Verification Compliance List indicate a new initiative on the Trade Compliance Verification list, namely, a focus on the correct application of surtaxes on imported goods. 

• China Surtax Order (2024): Electric vehicles
• China Surtax Order (2024): Steel and Aluminum
• United States Surtax Order (2025-01)
• United States Surtax Order (Steel and Aluminum 2025)
• United States Surtax Order (Motor Vehicles 2025)
• Order imposing a Surtax on the importation of Certain Steel Goods
• Steel Goods and Aluminum Goods Surtax Order
• Energy commodities and final accounting
  
  • Verifications on electricity imports under Chapter 27 of the Customs Tariff

As this is a new section for this list, it is worth highlighting, and it should be noted that these surtaxes will affect a broad swath of Canadian importers. 

If you have determined that you are affected by these additions, you are encouraged to get in contact with our Trade Advisory Services Team to take advantage of a Sample Audit. It is among the best ways to rest easy knowing that your business is currently meeting the necessary requirements set out by these surtaxes. 

As the risk environment evolves, CBSA can change priorities at any time during the course of the year.

The CBSA Targeted Verification Priorities Are:

Tariff Classification 

Gloves (Round 3) | Harmonized System Number(s): Headings 39.26 and 42.03

Bags (Round 3) | Harmonized System Number(s): Heading 42.02

Led Lamps (Round 2) | Harmonized System Number(s): Heading 85.39

Frozen desserts | Harmonized System Number(s): Tariff Item 2105.00.10

Spent Fowl | Harmonized System Number(s): Heading 02.07, 16.01 And 16.02

China Surtax Order (2024): Electric vehicles Harmonized System Number(s): Tariff items covered in Schedule 1 of the China Surtax Order (2024).

China Surtax Order (2024): Steel and aluminum | Harmonized System Number(s): Tariff items covered in Schedule 2 of the China Surtax Order (2024).

United States Surtax Order (2025-1) | Harmonized System Number(s): Tariff items listed in Schedule 1 of the Order Amending and Repealing Certain Orders Made Under the Customs Tariff (United States Surtax) and in Schedule 1 of the United States Surtax Order (2025-1).

United States Surtax Order (Steel and Aluminum 2025) | Harmonized System Number(s): Tariff items listed in Schedule 1 of the United States Surtax Order (Steel and Aluminum 2025) and in Schedule 2 of the Order Amending and Repealing Certain Orders Made Under the Customs Tariff (United States Surtax).

Ways To Practice Trade Compliance

When it comes to compliance, knowledge is key. Here are some suggestions to assist you in maintaining an excellent importing relationship with Customs:

• Ensure Accurate Customs Declarations: Importers must provide accurate information to Customs and comply with the Customs Act. This includes the origin, tariff classification, valuation, and other relevant areas as they apply.
• Review and Resolve Issues Once Found: Even the most compliant importer, with the most accurate customs broker, can discover inaccuracies. We recommend that all importers review declarations made on their behalf. Post-entry corrections must be made within 90 days of establishing Reason to Believe.
• Practice Excellent Record-Keeping: Importers are required to keep records for 6 years plus the current year. Customs can audit imports up to four years after they cross the border. Importers should have records of all their imports filed using the customs transaction number. 

Take advantage of our Trade Advisory team, who can help you understand how this release could affect your imports.