CBSA has issued Customs Notice 26-20 Customs Notice 26-20: Importing Goods Subject to Tariff Rate Quotas into a Customs Bonded Warehouse, clarifying critical rules for storing Tariff Rate Quota (TRQ) and steel goods in a Customs Bonded Warehouse (CBW).
While this is a clarification of existing policy rather than a new law, missing these procedural steps can result in unexpected surtaxes, delayed releases, and monetary penalties.
Here are the key takeaways every importer needs to know:
- Permit Timing is Everything: To qualify for “within access” lower duty rates, your Global Affairs Canada (GAC) shipment-specific import permit must be valid on the exact date the goods exit the warehouse (final release)—not just when they enter.
- Entering Under GIP? If goods enter a CBW under a General Import Permit, the surtax must be identified on the initial Type 10 CAD (though duties/taxes aren’t paid until warehouse exit). Before submitting a “within access” ex-warehouse movement (Type 20/21), you must submit a Type 10 CAD amendment once the specific permit is secured.
- Watch Out for Storage Expirations: If your permit expires while goods sit in storage, the shipment automatically loses “within access” status. You must submit a Type 10 adjustment to reflect “over access” status prior to exit.
- Strict Audits & Refunds: CBSA is actively auditing TRQ shipments post-release. Non-compliance risks back-duties, interest, and penalties. However, if surtaxes were declared/paid in error, refunds can be claimed via Memorandum D17-2-1.
Double-check your CARM entry workflow and audit permit expiration dates against plan removal schedules to protect your bottom line.
Concerns or questions can be directed to our Canadian regulatory team.