CBSA Publishes Update of Trade Verification Priorities for 2020

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The Canada Border Services Agency (CBSA) has posted an updated list of verification priorities for January 2020. Verification priorities are established throughout the year and reflect the CBSA’s assessment of non-compliance risk with customs rules for categories of imported goods. There have been no additions to the CBSA's priorities since we last reported in September 2019.

Audits cover tariff classification, customs valuation and origin, and during verification will focus on one of these customs programs for a defined “verification period” (generally the last complete fiscal year). The importer faces the requirement to amend non-compliant past import entry declarations made commencing up to four years prior to the date of amendment.

The following summarizes the CBSA's current verification priorities:

Tariff Classification
Air Heaters and Hot Air Distributors Heading 73.22
Articles of Apparel and Clothing Accessories Heading 39.26
Bags Heading 42.02
Batteries Heading 85.06
Cell Phone Cases Headings 39.26, 42.02 and 85.17
Disposable and Protective Gloves Subheadings 3926.20.91 and 4015.19
Flashlights and Miners’ Safety Lamps Heading 85.13
Footwear ($30 or more per pair) Heading 64.03
Furniture for Non-Domestic Purposes Headings 94.01 and 94.03
Gloves Headings 39.26 and 42.03
Import Permit Numbers
(i.e., for goods subject to tariff rate quotas under Canada's supply management system)
Chapters 2 and 4
Olive Oil Headings 15.09 and 15.10
Other Chemical Products Heading 38.24
Other Mountings and Fittings, Suitable for Furniture Heading 83.02
Parts of Lamps Heading 94.05
Parts of Machines and Mechanical Appliances Heading 84.79
Pasta Heading 19.02
Pickled Vegetables Heading 20.01
Safety Headgear Subheading 6506.10
Stone Table and Counter Tops Heading 94.03

Valuation
Apparel Chapters 61 and 62
Footwear Chapter 64

Origin
Bedding and Drapery Various goods of Headings 63.01, 63.02 and 63.03

A detailed list of all current verification priorities is available on the CBSA website.

Businesses that import goods listed as verification priority items should prepare for the possibility of a CBSA trade compliance verification in the near future, the results of which may include payment of additional duties, GST, interest and penalties. Importers of goods not included on this list should nevertheless be aware that the CBSA conducts random or complaint-based verifications. Best practices recommend that importers review their customs compliance practices to make sure they are compliant and can withstand audit by the CBSA. Our International Trade and Investment Practice group is available to help client importers assess their compliance/non-compliance and to assist them in steps that should be undertaken to correct errors resulting from past non-compliant practices and improve these practices going forward.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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