Western Grocer Serving the industry since 1916
What CBSA’s Own Data Is Telling Western Canadian Importers
By Carl Rodgers
Disclosure: I run ClearBorder, a Canadian customs compliance tool. I have a commercial interest in this topic. Every source below is public and can be checked directly.
For independent grocers and specialty food importers across Western Canada, managing margins has never been harder. But the biggest emerging threat to operating cash flow in 2026 isn’t coming from supply chain costs or inflation — it’s coming from a shift in Canadian customs liability that most importers haven’t fully priced in.
There is a chart on CBSA’s own website that tells the story.
| Verification priority | Cases targeted | Closed | In error | Error rate | Assessed revenue |
|---|---|---|---|---|---|
| Frozen desserts (HS 2105.00.10) | 26 | 18 | 12 | 67% | $55,211,681 |
| China Surtax (steel & aluminum) | 143 | 120 | 73 | 61% | $4,083,528 |
| US Surtax 2025-1 | 156 | 105 | 78 | 74% | $7,121,722 |
These are targeted verification results, not random-market rates. CBSA selected importers in these categories because risk-profiling flagged them. That distinction makes the numbers more meaningful, not less: when CBSA decides to look at a category, this is what they find.
The $55.2 million figure is from eighteen closed cases. That averages roughly $3 million in assessed revenue per closed case — a number large enough to be material for any independent importer it lands on.
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 named as importer of record on the customs accounting document is now jointly and severally liable, along with the importer and owner, for duties, taxes, and post-accounting reassessments. CBSA’s Memorandum D17-2-5 describes the importer of record as “the primary contact for verifications and the entity with direct liability for post-accounting obligations, including record keeping, making corrections, and payment of duties.”
The CARM transition period ended. From January 1, 2026, every entry filed produces structured, queryable data CBSA can analyze at scale.
The four-year reassessment window under Customs Act sections 59–61 started running entirely against the new regime. By 2030, the rolling lookback will be populated almost entirely by CARM-era entries filed under the new Section 17 liability framework.
Why this matters for Western Canada
Western Canada is the centre of Canada’s specialty food import economy. BC Asian importers, Prairie wholesale operators, Alberta specialty distributors, and Western independent grocers are disproportionately represented in the categories on CBSA’s January 2026 priority list: supply-managed goods (dairy, poultry, eggs), frozen desserts containing 5% or more dairy, spent fowl, animal feed, CUSMA/CETA/CUKTCA origin verifications, China and US surtax verifications, and the 25% steel derivatives surtax in force from December 26, 2025.
If your imports touch any of those categories, you are inside the current verification perimeter.
What “your business is liable” actually means
Section 17’s liability attaches to the importer of record as named on the customs accounting document. For most Western importers, that entity is the operating corporation — the BN account holder. This is not automatic personal liability for the human who owns the business. A properly incorporated business remains a legal shield. 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.
For an SMB owner, that matters because reassessed amounts come out of operating cash flow. The frozen-dessert results show per-closed-case assessments averaging in seven figures. For most Western independents, that’s not a line item — it’s an event.
The broker-model issue
Most customs brokers are paid per entry. That model prices the work of getting an entry through CBSA today. It does not necessarily price the cost of defending that entry against a reassessment years from now. Many brokers have done good work educating clients about CARM and importer-of-record liability. But release and post-entry defence are structurally different activities. Under Section 17, the entity CBSA pursues for the reassessment is the importer of record — not the broker.
Three things to check this week
First, map CBSA’s 2026 verification priority list to your imports. If you import supply-managed goods, frozen desserts, animal feed, goods claiming CUSMA/CETA/CUKTCA preference, or anything caught by the surtax orders, you are in the priority perimeter.
Second, pull a recent CAD and confirm who is named as importer of record. If your business’s BN is there, your business is the entity CBSA will contact first.
Third, reconcile your filings against your broker invoices and CARM Statement of Account. This surfaces both reassessment exposure and potentially unclaimed Input Tax Credits — claimable up to four years back.
Many importers have never done that reconciliation. CBSA now has a data environment that makes it easier for the agency to spot inconsistencies. Importers should give themselves the same visibility.
Carl Rodgers is the founder of ClearBorder (clearborder.ca), a Canadian customs compliance tool. A free one-page Section 17 importer checklist — no email required — is available at clearborder.ca/learn/section-17-checklist.
Primary sources: CBSA Trade Compliance Verification page; Customs Notice 25-32; Memorandum D17-2-5; Customs Act, sections 17 and 59–61; Auditor General of Canada, 2017 Report 2 — Customs Duties; CBSA Trade Compliance Verification Priorities (January 2026); SOR/2025-267.
