September 2026 has been a heavy month for Canadian importers. A new surtax on US goods took effect on September 8. Washington answered with 50% duties on some Canadian exports. Meanwhile, CARM keeps shifting paperwork from brokers to importers.

Below, we answer the 20 questions we're hearing most right now. Each answer is short and practical, and we flag where it pays to get help. 

Key Takeaways

• Declare the 2026 US surtax in CAD field 85 using codes 26186A, 26186B or 26186C (CBSA Customs Notice 26-23).

• The surtax applies to goods of US origin, not to goods that were simply shipped from the US.

• Once you have reason to believe an entry was wrong, you have 90 days to correct it. You have four years to claim a missed CUSMA preference.

The September 2026 surtax: what do importers need to do?

How do you declare the US surtax on the CAD?

CBSA Customs Notice 26-23 implements the United States Surtax Order (2026), effective September 8, 2026. Importers must calculate the surtax themselves and report it in field 85 of the Commercial Accounting Declaration (CAD). There are three codes: 26186A (Schedule 1, 15%), 26186B (Schedule 2, 25%) and 26186C (Schedule 3, 50%). Steel and aluminum have separate codes under an updated Customs Notice 25-11. If the code or amount is wrong, CBSA can reassess the entry and apply penalties.

Are goods in transit on September 8, 2026 exempt from Canada's surtax?

Yes. Goods that were already in transit to Canada on September 8, 2026 are exempt from the 2026 surtax. You have to be able to prove it, though, so keep the bill of lading, air waybill or carrier tracking that shows the departure date. If CBSA asks and you have no proof, you pay the surtax.

How do you prove goods are not US origin to avoid the surtax?

The surtax applies only to goods that are eligible to be marked as US goods, so origin decides it, not the shipping route. For example, Vietnamese shoes shipped from a Texas warehouse are not US goods. Back up your origin claim with a manufacturer's declaration, a bill of materials or mill certificates, and check that your invoices and markings match. We recommend reviewing origin now for every US-supplied SKU. That review is often the biggest saving available this year.

What are the US Section 338 tariffs on Canadian dairy, alcohol and vehicles?

This one affects Canadian exporters. Starting August 22, 2026, the US applied an extra 50% duty to Canadian dairy, alcoholic beverages and motor vehicles and parts, including ATVs, under Section 338 of the Tariff Act of 1930. For certain goods, import bans replace the duty on September 29, 2026. Qualifying under CUSMA does not exempt these goods. 

After release: what are you still responsible for?

What does "reason to believe" mean for correcting customs declarations?

Section 32.2 of the Customs Act says that once you have reason to believe an entry had the wrong tariff classification, value or origin, you must correct it within 90 days. You might find out from an audit, a supplier's price adjustment or a new ruling. If you miss the 90-day window, you risk AMPS penalties even though the original mistake was honest.

How do you claim CUSMA preference after importation?

If you paid duty on goods that actually qualified under CUSMA, you can claim the preference after importation and get a refund. CBSA gives you four years from the date the goods were accounted for (paragraph 74(1)(c.11) of the Customs Act). You'll need valid proof of origin, and you can't have already claimed the preference. Many importers are sitting on refunds they could claim. 

Who is liable when your customs broker makes a mistake on your entry?

In most cases, you are. The importer of record owes the duties and taxes and is responsible for accurate declarations, even when a broker files them. Your broker may owe you under your contract, but CBSA collects from the importer. That's why it matters to choose a licensed broker with errors-and-omissions coverage. [INTERNAL-LINK: choosing a broker → How to Choose a Customs Broker: A 2026 Guide]

What is a CBSA Detailed Adjustment Statement (DAS)?

A Detailed Adjustment Statement is CBSA's official record of a change to an entry, such as a correction, reassessment or refund. It shows the original amounts, the revised amounts and the net result. Keep every DAS with your import records, because it also starts the clock on your appeal (redetermination) rights.

CARM day to day: how does your import account work?

What is the CARM statement of account?

Your Statement of Account is a monthly summary of duties, taxes, adjustments and payments. It's posted in the CARM Client Portal on the 25th of each month. Payment is due 10 weekdays after the 17th, holidays included. If you pay late, CBSA may charge penalties and interest, and unpaid balances can go to the CRA after 30 days. You can check the transaction history in the portal at any time.

What changed when the CAD replaced the B3?

The CAD replaced the B3 when CARM Release 2 went live in October 2024. It collects more detailed data, including field 85 for surtaxes. More importantly, it's tied to your importer account and financial security. 

How do you add users and set roles in the CARM Client Portal?

In the CARM Client Portal, only a Business Account Manager can invite employees and assign each one a role. Give at least two trusted people manager access so a vacation or resignation doesn't lock you out. Grant your customs broker access separately through delegation.

What do you need to know about importing tires into Canada?

Tires sold in Canada must meet the Motor Vehicle Tire Safety Regulations, 2013, including the required safety markings. Tires that don't comply can be refused at the border. Passenger car tires generally attract MFN duty, commonly around 7%. Check your exact HS 4011 subheading and whether a free trade agreement applies before you price the shipment.

What are the rules for importing drones into Canada?

At the border, drones are classified under HS 8806. Their radio transmitters must meet ISED Canada radio standards. After import, Transport Canada rules apply: drones weighing 250 g to 25 kg must be registered, and the pilot needs a certificate. Retailers should confirm ISED certification before importing large quantities.

How are jewelry imports taxed, and what's the precious metals marking rule?

Jewelry usually attracts MFN duty (often around 8.5%, depending on the HS 7113 subheading) plus GST/HST. Under the Precious Metals Marking Act, a quality mark such as "14K" must be accurate. When a quality mark is applied, a registered trademark is generally required alongside it. Jewelry that's marked incorrectly can be detained.

What is the footwear import duty rate in Canada?

Footwear carries some of Canada's highest MFN rates, often up to 18%, depending on the upper and sole materials in HS Chapter 64. Footwear that qualifies under CUSMA, CPTPP or CETA can enter duty-free, so small material changes and valid origin proof can make a big difference to your margins.

What are the excise stamp rules for importing vaping products?

Under CBSA Memorandum D18-3-2, packaged vaping products entering Canada's duty-paid market must carry an excise stamp before CBSA releases them. Importers of packaged products must register with the CRA to get stamps. Unstamped goods must be exported, abandoned or moved to a sufferance warehouse for stamping. Individuals may bring in up to 5 units for personal use.

Is there GST or duty on imported gold and silver bullion?

Bullion that meets the "precious metal" purity thresholds (gold at least 99.5%, silver at least 99.9%, platinum at least 99%) is generally free of GST/HST at importation and usually duty-free as well. Collectible coins, jewelry and lower-purity products don't qualify, so declare the purity and form precisely.

Customs value: what counts when there's no normal sale?

What customs value do free samples and no-charge shipments get?

"No charge" doesn't mean no value. CBSA still requires a value for duty, usually based on identical or similar goods, or on cost plus profit. Put a realistic value on the invoice and mark it "no charge, value for customs purposes only." Some samples qualify for duty relief, so ask before you pay.

Do royalties, assists and licence fees count in customs value?

Sometimes. Under section 48(5) of the Customs Act, you add royalties and licence fees to the price when you pay them as a condition of the sale. You also add assists, which are tooling, molds or designs you supply to the manufacturer for free. Leaving them out undervalues the goods, and CBSA auditors look for it often.

How do customs valuation and transfer pricing interact for related-party imports?

When the buyer and seller are related, the price is accepted only if the relationship didn't influence it. Transfer pricing adjustments made at year-end can change the value for duty. An upward adjustment triggers a correction within 90 days, and a downward adjustment may allow a refund. Set up one process that covers both customs and tax.

The Bottom Line

• Review US-origin and in-transit status now, because the surtax is costly when you get it wrong.

• Keep track of your 90-day correction window and your four-year CUSMA refund window.

• Check your CARM user roles and payment dates before a missed deadline costs you.

• Check the product-specific rules for tires, drones, jewelry, footwear, vapes and bullion before you order.