CBSA Clarifies Shipment-Specific Import Permits for TRQ Goods in Bonded Warehouses
Importers using customs bonded warehouses need to make sure the correct shipment-specific permit is valid when TRQ goods are released.
The Canada Border Services Agency (CBSA) has published Customs Notice 26-20 to clarify how shipment-specific import permits apply when goods subject to tariff rate quotas (TRQs) are stored in customs bonded warehouses.
The notice does not introduce a new policy. Instead, it explains when a shipment-specific permit must be valid and how the Commercial Accounting Declaration (CAD) must be updated when goods enter under a General Import Permit or remain in storage after a shipment-specific permit expires.
For goods held in a customs bonded warehouse, a valid shipment-specific permit is required for TRQ goods to be accounted for at the within-access rate.
The permit may be obtained after the goods enter the warehouse, provided its validity period covers the date the goods exit or are finally released from the warehouse.
If already available, the permit number and applicable tariff classification or harmonized system (HS) code can be entered in the Type 10 CAD. The same permit must be declared when the goods leave.
If goods enter under a General Import Permit, the applicable surtax should be identified on the Type 10 CAD at entry.
Once a valid shipment-specific import permit is obtained, the importer must amend the Type 10 CAD to update the permit number, applicable duties, and tariff classification or HS code, if required.
Only then can a Type 20 or Type 21 ex-warehouse declaration reflect the within-access rate.
If a shipment-specific import permit expires while the goods remain in storage, the importer must amend the original CAD to reflect the goods’ over-access status.
Goods stored under an invalid shipment-specific permit, or released as within-access after the permit expires, are considered non-compliant. Applicable duties and taxes may be assessed, and the importer may also face enforcement action, including penalties.
Cole International provides trade consulting and customs brokerage services to help Canadian businesses manage TRQ requirements and customs declarations.
Reach out to one of our trade professionals for help managing shipment-specific import permits for TRQ goods entering or leaving a customs bonded warehouse.