What importers need to know

The Canada Border Services Agency (CBSA) has released updated proposals to amend the Valuation for Duty Regulations; these changes could significantly impact how Canadian importers determine customs value on imported goods. The consultation is open until January 23, 2026, and now is the time for businesses to understand what’s changing and why it matters.

Why these changes?

CBSA has advised that industry feedback from the 2023 consultation highlighted ambiguity in determining which sale in a supply chain should be used for customs valuation. Their goal is to:

• Align Canadian rules with World Customs Organization (WCO) guidelines
• Provide clear, fair, and consistent valuation practices
• Reduce compliance risk and ensure a level playing field for Canadian businesses

Key Proposal Revisions

1. Excluded Arrangements - Certain transactions will no longer qualify as a “sale for export to Canada”. These include:

• Consignment agreements
• Inter-branch transfers
• Free of charge goods (samples, gifts)
• Goods imported for destruction
• Lease or rental agreements
• Loaned goods
• Transactions between non-separate legal entities – Branch transfers

2. Sequential Sale Rule - In multi-sale chains:

• If an excluded arrangement had been the last sale for export, the transaction value cannot be used. CBSA will require an alternative valuation method.
• If the excluded arrangement occurs earlier in the chain, the last qualifying sale before importation determines the value for customs.

3. Domestic Sales - Sales between 2 Canadian entities are excluded from being considered “sales for export” except when it’s the only sale in the export chain.

• Example – A Canadian company buys goods stored abroad and arranges direct shipment to Canada. This domestic sale qualifies because it’s the only sale leading to importation.

What If There Is No Qualifying Sale and Transaction Value is not applicable?

CBSA will apply the hierarchy of alternative valuation methods:

• Transaction value of identical goods
• Transaction value of similar goods
• Deductive value
• Computed value
• Residual value

Action Steps for Importers

• Review your supply chain to identify exclude arrangements
• Update valuation practices to ensure declared values align with the new rules
• Participate in the consultation – feedback is due by January 23^rd 2026 via email to ctpd/dpsce@cbsa-asfc.gc.ca or complete the CBSA survey.
• Engage your trade advisors to assess compliance impact

To learn more about the methods of valuation or assistance in assessing your compliance impact, please reach out to Tradewin