The Canada Border Services Agency (CBSA) recently released its verification priority list for January 2025. 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 they are focusing on for inspections and verification. Typically, this focus manifests as targeted checks on these listed commercial goods to ensure that they are following 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 three main components of compliant importing, with a few other details as necessary. Those main 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?

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.

January 2024 CBSA Trade Compliance Verification List

The January Trade Verification Priority List is the prior of the releases this year.

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

New compliance priorities 

The CBSA has identified the following compliance priorities:

• Tariff rate quota and classification of supply-managed goodssome text
  • Verifications on the classification of frozen desserts containing 5% of dairy products
• Tariff classification of glovessome text
  • Third round of verifications on gloves classified under headings 39.26 and 42.03
• GST and excise duties and taxessome text
  • GST exemption codes
  • Vaping products are subject to excise duties and taxes
• Import origin verifications under:some text
  • Canada-European Union Comprehensive Economic and Trade Agreement (CETA)
  • Canada-United Kingdom Trade Continuity Agreement (CUKTCA)
• Duties Relief Program (DRP)some text
  • Verifications of licensees importing supply-managed goods
• Most-Favoured-Nation (MFN) tariff treatment withdrawn from Russia and Belarus
• China Surtax Order (2024): Electric vehicles
• China Surtax Order (2024): Steel and Aluminum

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) (NEW) Harmonized System Number(s): Headings 39.26 and 42.03

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

Spent Fowl (Round 3) Harmonized System Number(s): Heading 02.07, 16.01 And 16.02

Freezers And Other Freezing Equipment Harmonized System Number(s): Heading 84.18

Washers And Dryers Harmonized System Number(s): Headings 84.50 And 84.51

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

Furniture For Non-Domestic Purposes (Round 4) Harmonized System Number(s): Headings 94.01 And 94.03

Bicycle Parts (Round 3) Harmonized System Number(s): Heading 87.14

Disposable And Protective Gloves (Round 5) Harmonized System Number(s): Subheadings 3926.20 And 4015.19

Valuation 

Apparel (Round 4) - Harmonized System Number(s): Chapters 61 and 62, with an emphasis on assists

Origin

Bedding and drapery (Round 3) New Harmonized System Number(s): Headings 63.01, 63.02 and 63.03

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 ensure that they provide accurate information to Customs and are in compliance 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: Customs can audit imports up to seven years after crossing the border. Importers should have records of all their imports filed using the customs transaction number.

Our Trade Advisory experts can help you understand how this release could affect your imports. They can also assist you with a preliminary review, internal audit, or a CBSA audit.