The Canada Border Services Agency (CBSA) is moving ahead with one of the more consequential changes facing Canadian importers: a reform of the Valuation for Duty (VFD) Regulations. On May 22, 2026, CBSA signalled that it is gathering real-world examples of valuation challenges before publishing updated regulations for a further round of consultation. This is a follow-up to the agency’s April 20 response to feedback from the Canadian Society of Customs Brokers (CSCB), and it confirms that the file remains active and open to industry input.
What the reform would change
The proposed amendments would move Canada toward a “last sale” approach to customs valuation. Rather than valuing imported goods at an earlier price in a multi-tiered supply chain, the value for duty would be based on the final sale that causes the goods to be exported to Canada. In practice, that means the price relevant to the Canadian buyer, not an earlier price negotiated further up the chain between foreign parties.
Why non-resident importers should pay attention
The change would hit non-resident importers hardest. Many currently declare the price they paid a foreign supplier rather than the downstream price paid by the Canadian buyer. Under the proposed rules, the higher “last sale” value would apply, raising the duty base and, with it, the duties owed. Importers who have structured their supply chains around an earlier sale price should expect a meaningful increase in their landed costs if the regulations are finalized as described.
The consultation window is still open
Because CBSA is still collecting examples and intends to publish updated regulations for further consultation, importers have a genuine opportunity to shape the outcome. The agency wants concrete, real-world scenarios that illustrate where valuation becomes difficult or produces unintended results. Well-documented submissions carry more weight than general objections.
What importers should do now
- Review your valuation methods. Map out which sale in your supply chain you currently declare as the value for duty, and model the impact of valuing at the last sale instead.
- Document VFD issues. Capture specific examples where the proposed approach would raise costs, create ambiguity, or conflict with how your transactions are structured.
- Engage the consultation. Submit your examples and concerns while the regulations are still being shaped, rather than waiting for a final rule.
NGB can help importers assess how the proposed VFD changes would affect their specific import programs and prepare meaningful input for the consultation.
