Memorandum D11-6-11: Post-Accounting Obligations of Authorized Agents as Importer of Record has been published today, October 23, 2024.
This memoranda comes into effect January 1, 2026
https://www.cbsa-asfc.gc.ca/publications/dm-md/d11/d11-6-11-eng.html
This new D-memo contains information such as:
1. The Trade Culpability Framework (the framework) is the policy cornerstone of CBSA's trade compliance strategy. The framework guides operational efforts to nudge, direct or enforce compliance based on the relative risk posed at an entity and transaction level. The framework is behaviour-based and integrates the recognition that there are different degrees of non-compliance. By developing a variety of tools to address these varying circumstances, the CBSA is in a position to respond to trade chain partners (TCPs) in a manner best suited to foster compliance in a consistent manner.
6. The CBSA considers the entity that reimburses the authorized agents for duties and fees to be the importer or owner of the goods.
19. While the CBSA appreciates that authorized agents who account for goods as the importer of record refer to the information provided by supply chain partners, the CBSA expects authorized agents to use sound judgment, risk management practices, and industry knowledge to assess if the information provided by their supply chain partners is reliable and sufficient to substantiate the declarations the tariff classification, valuation, and tariff treatment.