CBSA Importer Reviews. Are you at risk?

Normal value reviews are critical in maintaining and enforcing Canada’s regulatory framework for importing goods. Importers must stay aware of CBSA importer reviews in their sector to avoid unexpected liability for specific goods imported from some countries.

The review process happens under the Special Import Measures Act (SIMA) to ensure that export prices, normal values, and subsidy data remain accurate. For importers, a normal value review can quickly change the business landscape for key imports that drive profits. 

What is a normal value review?

A normal value review is a procedure performed by the Canada Border Service Agency (CBSA) to establish the official value of goods imported to Canada. The CBSA investigates specific product categories from individual importers, usually after a domestic business or industry representative launches a complaint. 

A normal value is the price of the item when sold under ordinary conditions in the exporter’s local market. This is meant to act as a baseline for the value of goods prior to subsidies, promotions, and other influences on the price.

Determining this benchmark is a crucial part of CBSA enforcement of anti-dumping and countervailing regulations. The CBSA will periodically conduct normal importer value reviews to ensure that decision-making includes the latest data for export prices, normal values, and subsidies. 

What determines a normal value review?

Typically, a normal value review by the CBSA involves the analysis of market and price data. The process includes a thorough investigation that can result in requests for information from both importers and exporters. Price discrepancies, shifts in market conditions, and Anti-dumping and countervailing investigations are among the most frequent triggers of a normal value review, along with price discrepancies and sudden shifts in market conditions for the import.

Some of the factors that the CBSA will examine as part of their normal value review includes the following:

Cost of production

Costs related to creating the product are considered as part of the review, ranging from raw materials to labour.

Exporter’s domestic market price

The CBSA will gather data on the price that the import is usually sold for in the exporter’s domestic market, prior to discounts or promotions.

Import price in Canada

How much does a Canadian company pay to import the goods? Import price is a key data point for normal price reviews.

Subsidies and market conditions 

In addition to pricing and production, the CBSA will investigate subsidies and the overall economic environment that surround the goods during the review.

The CBSA aims to complete reviews within 180 days of launching the investigation. Depending on circumstances, a review might require a longer period of time to ensure an accurate, complete, and fair assessment.

How normal value reviews impact importers

CBSA importer reviews help to maintain a fair and competitive market landscape in Canada. Imported goods sold at an artificially low price can harm local businesses and entire industries. Simultaneously, a normal value review can leave importers on the hook for unexpected liabilities.

If a CBSA review finds sufficient evidence of an import price discrepancy that contributes to financial injury for a domestic producer, the importer could experience unexpected liability. A CBSA reassessment can result in a jump in tariffs and taxes for certain items from specific countries - including the potential for retroactive duties and taxes owed.

Normal value reviews don’t always increase costs and risks. The CBSA can also choose to reduce tariffs on categories of goods after a normal value review. In this scenario, importers can benefit from lower costs that give their business a competitive edge.

Optimize import operations with a strategic approach

CBSA value reviews are a regulatory mechanism, but they also provide insight for Canadian businesses to adjust how they conduct importing activities. Companies can leverage lower duties on imports to increase profitability, or quickly adjust to a review that ends up increasing the overall tariffs and taxes that must be paid.

Cole International has more than a half century of experience with companies operating across the Canada and the U.S. Let an experienced professional broker handle crucial details and deliver insight into import tariffs and regulations. Reach out and connect with one of our customs leaders today.