CBSA Trade Compliance Verification – List of 2025 Priorities
Tax Development
The Canada Border Services Agency (CBSA) regularly conducts trade verifications to ensure importers and exporters are compliant with various rules and regulations.
The CBSA manages this program primarily by conducting audits and other verification activities in the areas of tariff classification, valuation, and origin.
To monitor for compliance, the CBSA primarily uses two methods:
Random verification, which is designed to measure compliance rates and assess potential revenue loss
A list of verification priorities, which are determined through risk-based assessment processes
The verification priorities list (i.e., the CBSA “Hit List”) is helpful guidance for importers concerned about the potential risk associated with a compliance verification audit, as it details specific types of imported goods on which the CBSA intends to focus its compliance efforts.
The CBSA recently published its latest verification priorities (updated January 2025), and this year’s list contains several interesting items, including:
Tariff classification of frozen desserts containing 5% dairy products
Tariff classification of gloves (the third round of verification for certain items)
Proper use of goods and services tax (GST) exemption codes
Application of excise duty to vaping products
License verification for importers of supply-managed goods
Confirmation of origin of goods imported under both the Canada-European Union Comprehensive Economic and Trade Agreement and the Canada-United Kingdom Trade Continuity Agreement
Assurance that Most-Favoured-Nation treatment is withdrawn from Russia and Belarus
Application of the China Surtax Order (2024) to electric vehicles, steel, and aluminum
If you are selected for an audit and the CBSA identifies a compliance issue, corrective measures to your import documentation will be required for up to four years. Importers can avoid or mitigate potential audit issues by reviewing the priorities list and addressing any compliance concerns. Consider reviewing your internal processes in those areas to help ensure compliance and avoid the potential imposition of penalties under the Administrative Monetary Penalty System (AMPS). To learn more about the AMPS, please see our article The Importance of Complying with Customs Legislation.
The material presented in this communication is intended to provide general information only and should solely be seen as broad guidance and not directed to the particular facts or circumstances of any individual who may read this publication. No liability is accepted for acts or omissions taken in reliance upon the content of this piece. Before taking (or not taking) any action, readers should seek professional advice specific to their situation from Ryan, LLC or other tax professionals.