The CBSA has been busy on the classification, valuation and origin side of its D-memoranda library. Two memoranda have been formally updated and now govern current practice, and two more are out for consultation — giving importers and their brokers a direct chance to shape the interpretations they will have to live with. Here is what changed, what to action now, and where to weigh in.
D11-4-4 updated: Rules of Origin for the GPT and LDCT (June 25, 2026)
The CBSA has issued a revised Memorandum D11-4-4, Rules of Origin Respecting the General Preferential Tariff and Least Developed Country Tariff. This is the first refresh of the memo since October 2017, and it restates the origin and shipping rules for two of Canada’s preferential tariff programs:
- General Preferential Tariff (GPT) — goods must contain a minimum of 60% originating content from GPT beneficiary countries and/or Canada.
- Least Developed Country Tariff (LDCT) — goods must contain a minimum of 20% originating content from least developed countries and/or Canada.
The memorandum reconfirms the proof-of-origin documentation importers must hold — including the Form A Certificate of Origin or an exporter’s statement of origin — together with the direct-shipment requirements that must be met for a preferential rate to be claimed. Action for importers: if you claim GPT or LDCT rates, revisit your origin and direct-shipment records against the current text, because a preference claim that cannot be supported on audit becomes a duty assessment plus interest. The CBSA notes the memo was revised to reflect changes to the rules of origin and shipping requirements; no separate effective date is stated beyond the June 25, 2026 publication.
Read the full memorandum on the CBSA D-memoranda site
D19-10-2 updated: Administration of the Export and Import Permits Act (Importations)
Memorandum D19-10-2 sets out the import-permit requirements for goods on Canada’s Import Control List, and the CBSA has refreshed it (date modified July 13, 2026). It walks through the two permit routes importers use — General Import Permits, which authorize importation without a case-by-case approval, and Specific Import Permits, which require shipment-level authorization — across controlled categories such as agricultural products, textiles, steel and aluminum.
Two revisions matter most for day-to-day filing:
- The memo now incorporates instructions for declaring controlled goods under the Commercial Accounting Declaration (CAD) process in the CARM environment.
- It addresses newly regulated Chinese-made electric vehicles (controlled effective March 1, 2026), which require a shipment-specific permit until applicable quota limits are reached.
Action for importers and exporters: confirm which permit type each controlled commodity needs and that permit references are being captured correctly on the CAD — a missing or mismatched permit is a common cause of held shipments and post-release corrections.
Read the full memorandum on the CBSA D-memoranda site
Open consultation: D10-14-38 — tariff classification of furniture imported unassembled or disassembled
The CBSA’s Tariff Classification Unit is seeking input on proposed updates to Memorandum D10-14-38. The current published memo — Tariff Classification of a Piece of Furniture Imported Unassembled or Disassembled — applies General Rule of Interpretation 2(a) so that furniture arriving unassembled in a single shipment is classified as the complete assembled good, while components split across separate shipments are each classified on their own. The consultation title signals a broadening to cover furniture “pieces and sets,” which points to updated guidance on how multi-item and set scenarios should be treated.
This is a genuine opportunity for importers and brokers who move furniture — particularly flat-pack, kit and set merchandise — to submit real-world scenarios and argue for workable, predictable rules before the interpretation is finalized. The public D-memo page does not post a consultation deadline; the response date is set through the CSCB member channel, so members should check the CSCB notice for the closing date and route comments accordingly.
Read the current memorandum on the CBSA D-memoranda site
Open consultation: D10-15-15 — interpretation of tariff items 9958 and 9959
The Tariff Classification Unit is also consulting on Memorandum D10-15-15. The currently published memo is titled Interpretation of Tariff Item 9959.00.00 and explains when materials — plastic sheeting, textiles, paper products and artificial plastic moulding pellets, not cut to size or shape — qualify for duty-free entry when used in manufacturing passenger automobiles, buses, trucks, ambulances and hearses. Notably, the consultation is framed around both 9958 and 9959, whereas the published memo addresses only 9959.00.00 — so the update looks set to fold the related tariff item 9958 into a single interpretation.
For manufacturers and importers claiming these Chapter 99 duty-relief provisions, the wording of the eligibility conditions has direct dollar consequences. If you rely on 9958 or 9959, this consultation is the moment to test the proposed interpretation against your actual product mix and flag any wording that would narrow a legitimate claim. As with the furniture memo, no deadline is posted on the public page; the response window is communicated through the CSCB member channel.
Read the current memorandum on the CBSA D-memoranda site
Whether the change is already in force or still open for comment, D-memo revisions quietly reset what “compliant” means. NGB reviews these updates against your actual tariff lines, origin claims and permit requirements, and can help you prepare and submit consultation comments so your operational realities are on the record before the rules are locked in.
