CBSA Updates Memorandum D3-1-1 to Enforce CARM Compliance

The update reflects Canada’s move toward a fully digital customs environment, with new procedures introduced for using the CBSA Assessment and Revenue Management (CARM) system.

The Canada Border Services Agency (CBSA) has issued a revised version of Memorandum D3‑1‑1: Policy Respecting the Importation and Transportation of Goods, with updates effective from August 1, 2025.

The memorandum provides an overview of the CBSA’s rules and policies for how goods must be reported and transported when entering Canada or transiting through the country, regardless of the mode of transport.

Revisions to D3-1-1 include updating several legacy processes to align with CBSA’s digital-first approach to customs clearance, in addition to the implementation of the CBSA Assessment and Revenue Management (CARM) system.

Key changes to D3-1-1

In the updated memorandum, references to the traditional B3‑3 Canada Customs Coding Form have been replaced with the Commercial Accounting Declaration (CAD), which is filed through the CARM Client Portal (CCP).

To ensure consistency across carriers and modes of transport, pre‑arrival reporting has been replaced with Advance Commercial Information (ACI)/eManifest.

Additionally, a new process for obtaining carrier codes through the CARM system has been introduced for carriers and freight forwarders.

The revised D3-1-1 updates and clarifies other policies, including but not limited to:

• Carrier requirements
• Timeframes
• Sealing requirements
• Cargo reporting
• Shortages
• Overages, company-owned material (COMAT), and goods found astray
• Re-manifested cargo control documents
• Emergency diversions
• Delivery requirements and exemptions
• Movement and cargo control of unreleased goods

How this impacts Canadian importers

The memorandum mainly applies to carriers and freight forwarders, but it also affects Canadian importers. 

With CARM now serving as the official system of record, importers must be registered on the CCP, with delegated roles set up and financial security posted.

Moreover, it’s essential to find a trusted partner who is fully compliant with the new D3‑1‑1 standards to prevent delays, penalties, and increased costs.

Recommended next steps

If you import goods into Canada, we recommend you take the following steps to ensure compliance with the updated D3‑1‑1 memorandum:

• Verify that the information you provide, including HS codes, valuations, and quantities, is complete and accurate.
• Partner only with carriers and freight forwarders that are fully compliant with the new reporting and documentation requirements.
• Consult your customs broker to confirm that your processes align with the updated rules and to address any potential risks.

How Cole International can help

At Cole International, we provide customs and compliance consulting and customs brokerage services to help you navigate changing regulations and streamline importing goods into Canada.

Please get in touch with one of our trade professionals to discuss the impact of these changes on your business and how we can help ensure your compliance.