Two developments now moving through CBSA and Finance Canada touch the economics of how imported goods are stored and how duties can be recovered. Relayed in part through Canadian Society of Customs Brokers (CSCB) member bulletins, both trace back to public Government of Canada sources. Here is what importers and warehouse operators should be watching as of mid-May.
Storage of Goods: a D4-1-5 update is coming
CBSA has signalled a forthcoming update to Memorandum D4-1-5 — Storage of Goods, the memorandum that governs how imported goods are held in sufferance, bonded, and King’s warehouses pending clearance, including time limits, forfeiture, and storage charges. The pending revision follows the April 1, 2026 CPI-based adjustments to CBSA commercial fees.
The key change in approach: rather than embedding fixed dollar figures in the memorandum’s text, CBSA is directing readers to its current Fees Report for the exact storage rates in effect. This keeps the published rates current as they are adjusted for inflation, but it also means the memorandum alone no longer tells you what you will pay.
Practical impact: Importers and warehouse operators should budget for the adjusted warehousing and storage charges and confirm current rates against the Fees Report rather than relying on older regulatory text. It is worth recalling that storage charges can begin as early as day one in some warehouse types, so the difference between the old and adjusted figures compounds quickly for goods that sit awaiting clearance.
Drawback for donated goods under Bill C-15
Division 26 of Bill C-15, the Budget 2025 implementation legislation, includes a change relevant to duty drawback on donated goods. The measure opens the door to recovering duties on imported goods that are subsequently donated — a category that has historically offered no clear recovery avenue.
Practical impact: Importers and charitable organizations handling donated imports should track this provision as it moves through Parliament. If enacted, it could create a new path to duty recovery worth building into landed-cost and compliance planning, particularly for businesses that regularly donate surplus or returned imported stock.
What importers should do
Together, these items affect warehousing economics and duty recovery. Confirm your current storage fees against the Fees Report ahead of the D4-1-5 update, and watch the Bill C-15 drawback provision if donated imports are part of your operation. NGB can help assess how each change affects your specific import program.
