Key Takeaways
- Canada's CAD $20 duty de minimis and CAD $40 GST threshold are under tighter CBSA scrutiny as courier volumes climb.
- CARM now requires explicit tariff classification and importer-of-record data even for low-value shipments that used to slide through on simplified clearance.
- Misclassifying goods to stay under de minimis triggers AMPS penalties that can exceed the duty saved.
- Switching from air courier to consolidated freight or bonded warehouse fulfillment changes your CAD filing requirements and security obligations.
Customs Tariff Canada Enforcement Is Tightening on Ecommerce Shipments
Canada's customs tariff de minimis thresholds have been CAD $20 for duty and CAD $40 for GST since 2015, and for years those limits allowed most direct-to-consumer ecommerce parcels to clear without formal duty assessment. That environment is shifting. CBSA enforcement on low-value courier shipments has intensified over the past 18 months, driven by the same pressure other G7 customs agencies face: ecommerce volumes climbing 15-20% annually while traditional merchandise trade stays flat, and a growing share of cross-border online sales originating from jurisdictions where tariff avoidance is baked into seller pricing models.
The pattern is visible in courier manifest data. Small-parcel air volumes into Canada crossed 240 million pieces in 2024, per Statistics Canada trade data, and an estimated 65% of those shipments declared values under CAD $40. CBSA is now routinely auditing declared HS codes, unit prices, and shipping-versus-goods splits on courier manifests, and importers who treated low-value clearance as a compliance-free zone are encountering AMPS penalties and mandatory examinations.
How CARM Changed Low-Value CAD Filing
Under the pre-CARM paper B3 process, courier brokers could batch-clear low-value shipments with minimal importer-of-record detail and generic tariff line entries. CARM Phase 2 Release 3, which went mandatory in October 2024, requires explicit HS 6-digit classification, full consignee business number or NRI registration, and value breakdown by line item for every Commercial Accounting Declaration, including courier entries that used to slide through on a single summary line.
The practical effect: a shipment valued at CAD $35 that previously cleared in four hours now sits in CBSA review if the HS code is missing, implausible, or contradicts the goods description. Release prior to payment under an RPP bond does not waive classification accuracy. CBSA verifies tariff codes at release and assesses duty retrospectively if the filed CAD is wrong, which means importers who guessed at HS codes to stay under de minimis are now facing corrected duty assessments weeks after delivery.
This is not theoretical. We filed 1,200 courier CADs in January 2026 alone, and 18% required post-release corrections because the original shipper-provided HS code did not match Canadian Customs Tariff nomenclature. Each correction costs the importer filing time, potential duty uplift, and exposure to AMPS penalties if CBSA decides the original misclassification was negligent.
What Counts as Tariff Avoidance Under CBSA Policy
CBSA's enforcement guidance treats these behaviors as circumvention:
- Splitting single customer orders into multiple sub-CAD $20 parcels to avoid duty
- Declaring retail-packaged goods as samples or gifts to bypass commercial clearance
- Using HS codes for lower-duty categories when the actual goods fall under higher-duty tariff lines (common example: declaring synthetic-fiber apparel as cotton blend to drop from 18% MFN to 8.5%)
- Under-declaring FOB value by booking freight separately and omitting it from the CAD value line
Each of these triggers AMPS Level 1 or Level 2 contraventions under the Customs Act. A Level 1 penalty starts at CAD $400 and scales with the duty evaded. A Level 2 penalty for repeat or wilful misclassification can reach CAD $25,000. CBSA does not issue warnings first. The first notice most importers see is a formal AMPS penalty assessment in the CARM Client Portal, with a 90-day correction window to dispute.
When It Makes Sense to Switch from Courier to Bonded Warehouse Fulfillment
Importers moving consistent volume above 500 parcels per month often hit a point where courier per-entry CAD fees and duty unpredictability outweigh the convenience of door-to-door air service. The alternative is to consolidate inventory into a Canadian bonded sufferance warehouse, clear duty only on sold units as they leave for domestic customers, and file CADs in controlled batches.
This model requires upfront RPP bond security (typically CAD $25,000 minimum for a new importer) and daily CAD accounting through the CARM Client Portal, but it shifts duty payment from unpredictable per-shipment to predictable per-withdrawal, and it allows accurate HS classification under broker review before goods ever touch CBSA examination. We work with ecommerce importers at CanFlow's compliance desk who switched from courier to warehouse fulfillment and cut their effective duty rate by 3-5 percentage points simply by filing correct HS codes instead of defensive over-classifications.
The trade-off is lead time. Courier shipments clear same-day or next-day if the CAD is clean. Warehouse entries take 2-3 business days from consolidation arrival to duty-paid withdrawal, which means you need demand-forecast cushion. For seasonal or promotional spikes where air speed matters, hybrid models work: bulk via ocean container to bonded warehouse for baseline inventory, air courier for top-up on fast movers.
Tariff Classification Is Not Optional Anymore
The enforcement shift means Canadian importers selling online can no longer treat HS codes as courier-broker boilerplate. CBSA expects 10-digit Canadian tariff precision, and the CARM system cross-checks filed codes against product descriptions, country of origin, and historical entry patterns for the same importer. Mismatches trigger examination holds.
If you are importing apparel, electronics, or home goods with hundreds of SKUs, the safest approach is to run an HS classification audit before you scale past CAD $100,000 annual import value. That threshold is where CBSA post-release verification letters start appearing, and where an incorrect tariff code stops being a one-time correction and becomes a pattern-of-negligence file that AMPS enforcement tracks.
We maintain HS code libraries for our clients' product catalogs using CBSA's D-memoranda and CARM's HS classification tool, and we flag SKUs where Canadian tariff treatment diverges from U.S. HTS or EU CN codes. Most ecommerce sellers assume HS codes are universal. They are not. A product that clears duty-free into the U.S. under Section 321 may hit 18% MFN duty in Canada under Chapter 62, and guessing wrong costs you the full duty difference plus penalties on every unit sold since first import.
CBSA Verification Cadence Is Increasing
Post-release CBSA verification requests are up 40% year-over-year for courier importers, based on our client sample. These are not random. CBSA's risk engine flags importers with any combination of:
- High shipment counts with values clustered just under CAD $20 or CAD $40
- Frequent HS code changes for the same product description
- Country-of-origin declarations that do not align with known supplier geographies
- Importer business numbers registered in the past 12 months with no prior trade history
A verification letter gives you 30 days to produce commercial invoices, packing lists, supplier contracts, and proof of payment for the flagged entries. If you cannot substantiate the declared value or HS code, CBSA re-assesses duty and interest retroactively, often going back 12-18 months. The correction bills we have seen range from CAD $8,000 to CAD $60,000 depending on volume.
Most of these situations are fixable if caught early. Run your courier manifest export from your broker quarterly, sort by HS code and declared value, and look for patterns that would look suspicious to an algorithm: same HS code, same value, 500 shipments in a row. If it looks like template data instead of real product variance, it probably is, and CBSA will notice before you do.
CBSA publishes its compliance expectations in D-memorandum D17-1-10 on post-release verifications. Read it. The importers who survive these audits without penalty are the ones who kept clean records from day one and can prove every declared value and tariff code with third-party invoices.
Importers running cross-border ecommerce at any serious scale need classification hygiene, duty-payment predictability, and a CAD filing process that survives CBSA review on first pass. The courier shortcut worked when enforcement was light. That window has closed.
Frequently Asked Questions
What is Canada's de minimis threshold for customs duty?
Canada's de minimis threshold is CAD $20 for customs duty and CAD $40 for GST/HST, per CBSA policy. Shipments above these values require full duty and tax payment and a Commercial Accounting Declaration (CAD) filing through CARM.
Does CBSA verify HS classification on low-value courier shipments?
Yes. CBSA now routinely audits courier manifest data against declared HS codes, even for shipments under CAD $40. Persistent misclassification to avoid duty triggers AMPS Level 1 contraventions, which carry penalties starting at CAD $400 per incident under the Customs Act.
Can I use simplified courier clearance for all my direct-to-consumer sales?
Only if each shipment stays under the CAD $20 duty and CAD $40 GST thresholds and you are not structuring orders to avoid duty. CBSA treats order-splitting as circumvention, and repeated violations can disqualify your importer-of-record number from courier low-value processing.
What changes when I move ecommerce fulfillment into a Canadian bonded warehouse?
Goods enter Canada duty-unpaid under a warehouse accounting declaration, then individual customer orders clear domestic duty-paid on removal. You need a customs sufferance warehouse license, a Release Prior to Payment (RPP) bond, and daily CAD filings through the CARM Client Portal for each withdrawal.
How do I classify products for customs tariff purposes if I sell hundreds of SKUs?
Each SKU needs a 10-digit HS code at the Canadian tariff level. CBSA publishes D-memoranda (such as D11-4-2 on tariff classification principles) and maintains a Customs Tariff online. Most importers use broker classification services or the CARM HS lookup tool to assign codes before first import.
What happens if CBSA finds I've been under-declaring value to stay under de minimis?
CBSA can retroactively assess duty, GST, and AMPS penalties for up to four years. We routinely see importers facing CAD $15,000 to $50,000 in back duties and penalties after a courier shipment audit, plus mandatory high-risk examination on future entries.
Originally published at https://www.canflow-global.com/en/insights/customs-tariff-canada-cbsa-tightens-low-value-ecommerce-enforcement/.
