Tax & Trade Blog

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NEW FOOD LABELLING RULES INCOMING

AMENDMENTS TO FOOD AND DRUG REGULATIONS TAKE EFFECT IN THE NEW YEAR

After nearly four years, amendments to the Food and Drug Regulations (“FDR”) labelling regime, previously enacted in July of 2022, are set to take effect on January 1, 2026.

While the changes are laudable from a public health perspective, parties selling regulated food products (“Regulated Parties”) need to ready themselves for compliance with these changes, and in this report, we provide a brief overview of the key changes.

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CANADA-AUSTRALIA CUSTOMS PACT SIGNED

AUSTRALIA-CANADA'S LATEST PARTNER IN CUSTOMS MUTUAL ASSISTANCE AGREEMENT

Since 1979, Canada has been putting together a web of Customs Mutual Assistance Agreements (“CMAAs”) with a number of trading partners, including the US, Mexico, UK, EU, Israel, China, Korea, Chile, and Argentina.  Australia recently became the 15^th nation to agree to a CMAA with Canada, and we discuss below how these protocols allow Canada to tighten its enforcement on goods coming into Canada from foreign lands.

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MAJOR CHANGES TO CUSTOMS LIABILITY!

"IMPORTER OF RECORD" WILL BE JOINTLY LIABLE FOR PAYMENT OF DUTIES AND TAXES

On January 1, 2026, amendments to subsection 17(3) of the Customs Act (“CA”) come into force that make the “importer of record” jointly liable with the owner of the goods for duties and taxes on imports.

This development will impact customs brokers in the freight forwarding industry who have enjoyed protection from customs liability for the past few years. 

Following the coming into force of these amendments, there may no longer be any escape of liability for duties when a broker identifies itself as the “importer” (i.e., using its name and business number to obtain release of an import from the Canada Borde Services Agency (the “CBSA”)). 

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CBSA AUDITING STRUCTURAL STEEL

CBSA'S ONGOING SCRUTINY IN STEEL PRODUCTS CLASSIFICATION SIGNALS RISING COMPLIANCE RISK

As we have blogged here and here, the Canada Border Services Agency (the “CBSA”) sets out its priority areas for compliance audits and verifications in its Trade Compliance Verification Priorities publication.  Steel and metal products have long been among the CBSA’s primary focuses for compliance review.

Recently, the CBSA has intensified its challenges to the classification of steel containers, interpreting tariff headings in ways that go beyond prevailing industry practice.  This shift reflects a broader trend toward more aggressive enforcement in the steel sector.

For importers, this trend heightens compliance risk.  The best approach is to seek legal advice early in the audit process and resolve classification issues before they escalate into formal assessments.

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FORCED LABOUR REPORTING MADE EASIER

CANADA ADOPTS NEW GLOBAL TEMPLATE FOR ANNUAL FORCED LABOUR REPORTING REQUIREMENTS

Canada has in place now, for the last two years, a comprehensive set of legal reporting requirements for companies with supply chains that may be susceptible to products made through forced labour or child labour.

We have previously written on the reporting requirements and the reporting entity conditions here and here.

This report reviews the new global template that Canada has adopted to make this reporting process easier.