Disclosure upfront: I run ClearBorder, a Canadian customs compliance tool. I have a commercial interest in this topic. Every source is named so you can check the underlying documents directly.
There is a chart on CBSA's own website that I think every Canadian importer should be looking at right now. It is not a forecast. It is not a prediction. It is the published, official results of CBSA's most recent rounds of trade compliance verifications. Here it is, taken directly from the CBSA Trade Compliance Verification page:
| Verification priority | Cases targeted | Cases closed | Cases in error | Error rate | Assessed revenue |
|---|---|---|---|---|---|
| Frozen desserts (HS 2105.00.10) | 26 | 18 | 12 | 67% | $55,211,681 |
| China Surtax Order (steel & aluminum) | 143 | 120 | 73 | 61% | $4,083,528 |
| US Surtax Order (2025-1) | 156 | 105 | 78 | 74% | $7,121,722 |
Three things about that table I want to make sure don't get lost.
These are targeted verification results, not random-market rates. CBSA selected importers in these categories because risk-profiling flagged them. The 67%, 61%, and 74% figures describe the populations CBSA chose to look at — not every importer in those categories. That distinction matters, and it makes the numbers more meaningful, not less: it means when CBSA decides to look at a category, this is what they find.
The $55.2 million figure is from eighteen closed cases. Not 1,800. Eighteen. That averages out to roughly $3 million in assessed revenue per closed case — a number large enough to be material for any SMB importer it lands on.
These are not the results of some future enforcement wave. These are results CBSA has already collected, on verification priorities CBSA is currently still actively pursuing. The January 2026 priority list includes frozen desserts, supply-managed goods, and surtax verifications among its active targets.
I want to walk through what those numbers mean, what changed in 2026 that makes them matter more than ever, and what specifically a Canadian importer should do this week if they read this and recognize their own situation. Everything below is sourced; nothing is invented.
What changed on January 1, 2026
Three things came into force on the same day.
Section 17 of the Customs Act was amended. The entity identified as the importer of record on the customs accounting document is now jointly and severally liable, along with the importer and owner of the goods, for any duties, taxes, and post-accounting reassessed amounts. CBSA's own Memorandum D17-2-5 states the importer of record is "the primary contact for verifications and the entity with direct liability for post-accounting obligations, including record keeping, making corrections, and payment of duties." (Customs Notice 25-32; Memorandum D17-2-5.)
The CARM transition period ended. CARM had been the official system of record since October 21, 2024, but transition measures were in place through 2025. On December 31, 2025, those measures expired. From January 1, 2026, CARM is unambiguously the system every importer accounts through. Every entry filed produces structured, queryable data that CBSA can analyze at scale against every other importer's data.
The four-year reassessment window started running against the new regime. Under sections 59 through 61 of the Customs Act, CBSA can re-determine or further re-determine tariff classification, origin, and value of any entry for up to four years from the date of accounting. That window has always existed. What's new is what's at the other end of it.
The 2030 math
Here is what the legal structure produces when you run the numbers forward.
An entry filed on January 1, 2026 is reassessable through December 31, 2029. An entry filed on January 1, 2027 is reassessable through December 31, 2030. By January 1, 2030 — four years from now — every entry an importer has filed under the new Section 17 regime since the regime came into force will simultaneously be inside the reassessment window, and CBSA will have four full years of CARM-collected data covering those entries.
In 2024, CBSA had data on importer filings, but not in a structured, centralized, queryable form. In 2030, they will. The reassessment window doesn't change. The data CBSA can use to drive reassessments inside that window does.
The Auditor General of Canada, in a 2017 report, found that across the population of importers CBSA examined, approximately 20% of goods were misclassified, and that this rate had been consistent over a 15-year period. The same report documented that in 2015-16, targeted verifications identified that importers should have paid an additional $42 million — roughly half of which was due to misclassification. That was 2015-16, in a world where CBSA had to manually pull and analyze each importer's records.
The compounding effect that arrives by 2030 isn't a forecast. It's what happens when the same baseline error rate meets a system that lets CBSA identify discrepancies at scale, across every importer, every entry, every category, in a way the pre-CARM regime simply could not.
What the 2026 priority list is telling you
CBSA publishes its trade compliance verification priorities annually. The January 2026 list is unusually broad. The categories on the active list include:
- Tariff rate quota and classification of supply-managed goods (dairy, poultry, eggs)
- Classification of frozen desserts containing 5% or more dairy
- Classification of spent fowl products
- Classification of cheese treats for dogs (animal feed, heading 23.09)
- Origin verifications under CUSMA (automotive), CETA, and CUKTCA
- Surtax verifications under the China Surtax Order (2024)
- Surtax verifications under multiple US Surtax Orders
- The 25% steel derivatives surtax in force from December 26, 2025
If your imports touch any of those categories, you are not at hypothetical future risk. You are inside the current verification perimeter. The error rates in the table above are from this list.
What CBSA is doing differently now
The old enforcement model was binary: CBSA either audited you or didn't. Audits were resource-intensive on their side and rare per importer.
Under CARM, CBSA now uses three escalating tools alongside traditional verifications:
A Trade Advisory Notice (TAN) is a friendly warning. No penalty. A signal that CBSA has flagged your entries for review.
A Compliance Validation Letter (CVL) is a formal request for information where CBSA suspects non-compliance. The importer has 30 days to respond. Monetary assessment may follow.
A Directed Compliance Letter (DCL) is a formal assessment. It arrives with a bill — unpaid duties, interest, and Administrative Monetary Penalties.
The implication: significantly more importers will receive some form of CBSA contact under CARM than under the old system. Many of those will be TANs. But TANs are not nothing — they go on a record, they signal a flag in CBSA's risk profiling, and when the issue underlying the TAN persists, the next letter is harder.
Why the per-entry brokerage model can't absorb this
This is where I want to be careful, because the easy version of this argument is wrong and I don't want to write it.
The easy version is "your broker isn't telling you about Section 17." That isn't true as a generalization. CSCB has run member webinars on IOR liability through 2024 and 2025. Major brokers — Cole, Livingston, Universal, PCB, Mohawk Global — have all published explainers. The information is out there if an importer goes looking.
The harder, truer version is this: the traditional brokerage business model is built on a fee-per-entry basis. That model prices the cost of getting an entry through CBSA today. It does not price the cost of retroactively defending that entry against a reassessment three years from now. The broker who filed the entry is not contractually or commercially obligated to defend it later. And under Section 17, the entity on the hook for the reassessment is the importer of record — typically the importer's business — not the broker who filed.
Brokers built their pricing around release. Section 17 changed where the liability lives during the four years after release. The economics don't update automatically.
What "your business is liable" actually means
A subtle but important point. Section 17's joint and several liability attaches to the importer of record as that entity is named on the customs accounting document. For most Canadian importers, that entity is their business — the corporation with the BN account.
This is not automatic personal liability for the human who owns the business. A properly incorporated business is a legal shield against personal exposure for ordinary commercial obligations, including duty reassessments. What Section 17 does is make the business the primary party CBSA pursues — not the broker who filed, not the freight forwarder, not the supplier. Your business.
For the owner of that business, this matters because the assessed amounts come out of operating cash flow. A reassessment for misclassifications going back four years lands on the company P&L. The frozen-dessert results above show CBSA's per-closed-case assessments averaging in seven figures. For most SMB importers, that's not a line item — it's an event. And because the liability is joint and several, CBSA can pursue any of the named parties, which means the importer of record is the first phone call, not the last.
In practice, for a Canadian SMB importer, the simplest accurate framing is this: when CBSA wants the money back, the named importer of record is who they come to. That is the importer's business. The broker is not.
The structural visibility problem
Three reasons the importers most at risk are the least likely to be paying attention.
CBSA's enforcement infrastructure is now in place but its operational ramp is internal. The first wave of TANs and CVLs is going out in 2026, but the volume is still modest compared to what it will be in 2027-28 once the system is running at full scale. Most importers haven't received a letter yet, and human risk perception doesn't price slow-building statistical exposure well.
The information is technically public but practically buried. The CBSA memos, the verification priority page, the Auditor General reports — these exist, but they live in places SMB owners don't routinely look. The accountants and brokers who do read them are mostly communicating in their professional networks, where the conversation has been active for some time; it just hasn't reached the day-to-day operational conversations importers have with their teams.
The 2026 priority list itself reads like a niche regulatory bulletin until you map it to your own imports. The importer of frozen desserts who looks at the list sees "frozen desserts containing 5% or more dairy" as one of nine bullet points. The mapping from that bullet point to "the chart at the top of this post applies to me" requires a leap that the document itself does not make.
What this means in 2026
Three predictions, each built on what is already in the public record:
The first wave of CARM-driven enforcement is hitting in 2026, concentrated in the published priority categories. Recipients of TANs and CVLs will begin telling their networks. The "I know someone who got a letter" moment will become common by late 2026.
By late 2027, the conversation that is today mostly confined to trade circles will become general. Trade publications will run case studies. Accountants will begin flagging CARM compliance in year-end reviews. Insurance providers will start asking about it on E&O and D&O renewals. Brokers will face client questions about retroactive responsibility that the per-entry model can't answer.
By 2030, the four-year reassessment window fully overlaps with the post-Section 17 era. Every entry filed since January 1, 2026 will simultaneously be inside the window. CBSA will have four years of CARM data. The reassessment letters that today are exceptional will be the operating pattern, not the surprise.
If you are an importer reading this
Three things to do this week, in priority order:
Check the 2026 verification priority list. If you import frozen desserts (HS 2105.00.10), supply-managed goods, animal feed, anything claiming CUSMA/CETA/CUKTCA preference, or anything that could be touched by the China or US surtax orders or the steel derivatives surtax — you are inside the current priority perimeter.
Find out who is named as importer of record on your customs accountings. Pull a recent CAD — or, for older entries, a B3. Look for the importer-of-record field. If your business's BN is there, you — meaning your business — are the entity CBSA pursues if anything is found wrong with that filing. This is true even if you've never actually read a CAD. Especially if you've never read one.
Reconcile your filings against your broker invoices and your CARM Statement of Account. This is the work that almost nobody does and that CBSA can now do at scale. The reconciliation surfaces both the misclassifications that create reassessment exposure and potential unclaimed Input Tax Credits — claimable up to four years back, depending on the documentation that supports each entry. Most importers find issues worth investigating when they look.
A closing note
I'm not a neutral party. I disclosed that at the top. But the documents I cited above are not my documents. Every figure in the table is from CBSA's own verification page. The 20% misclassification finding is from the Auditor General. The Section 17 framework, the four-year window, the priority list — all of it is public, all of it is verifiable, all of it can be checked against the sources I've named.
What I am doing is connecting documents that already exist into a picture that, when I look at it, is the most consequential change in Canadian customs in a generation — and one that the importers it most affects have largely not been told about in operational terms they can act on. If you read this and recognize your own situation, the next step is the reconciliation work. If you disagree with anything I've written, I'd genuinely like to hear why.
Carl Rodgers, Founder, ClearBorder (clearborder.ca)
Primary sources: CBSA Trade Compliance Verification page (current); CBSA Customs Notice 25-32 (December 2025); CBSA Memorandum D17-2-5 (January 2026); Customs Act, sections 17, 59-61; Auditor General of Canada, 2017 Report 2 — Customs Duties; CBSA Trade Compliance Verification Priorities (January 2026); SOR/2025-267 (Steel Derivative Goods Surtax Order).