CBSA Audit Preparation

Why Audit Preparation Matters

CBSA conducts compliance audits to verify that importers are correctly classifying goods, claiming preferential treatment, and paying applicable duties and surtaxes. Since the introduction of multiple surtax orders in 2024-2025, CBSA has intensified audit activity on importers of US- and China-origin goods.

AMPS Penalty Ranges

Invalid CUSMA claims used to avoid surtax can trigger Level 3 or Level 4 penalties. In addition to penalties, CBSA assesses the full unpaid surtax plus interest retroactively.

What CBSA Looks For

Tariff Classification Accuracy

• Are goods classified under the correct 10-digit HS code?
• Were classification decisions verified against CBSA rulings?
• If the HS code falls within a surtax order schedule, was the surtax correctly applied?

Country of Origin Determination

• Is the declared country of origin accurate and supported by documentation?
• Does the commercial invoice identify the country of manufacture (not just shipment)?

CUSMA Preferential Treatment Claims

• Is there a valid certification of origin on file for each CUSMA claim?
• Does the certification cover the specific goods and shipment dates?
• Does the product actually meet the applicable PSRO?
• If the PSRO requires a tariff shift or RVC, can you demonstrate compliance?

Surtax Application

• Was the correct surtax rate applied to each shipment?
• Were stacking scenarios accounted for?
• What is the basis for any surtax exemption claims?

Record-Keeping

• Are records maintained for the required 6-year retention period?
• Can you reconstruct the compliance rationale for any given shipment?

Documentation You Need

Core Import Documents

• Commercial invoices for all shipments in the audit period
• Bills of lading or airway bills
• Customs accounting documents (B3 declarations or CARM transaction records)
• Packing lists and purchase orders

Classification Records

• Tariff classification worksheets for each HS code used
• Any advance rulings from CBSA
• Product specifications or technical data supporting classification
• Record of when each classification was confirmed or last reviewed

Origin and CUSMA Documents

• Certificates of origin for each product claiming CUSMA preferential treatment
• Supplier declarations confirming origin
• Origin assessment records (tariff shift analysis, RVC calculations)
• Bills of materials showing input origins

Surtax Records

• Record of which surtax orders were active at the time of each shipment
• Documentation of surtax determinations for each product/shipment combination
• Basis for any surtax exemption claims

Gathering Documentation from TariffTrail

Export the Full Audit Trail

1. Navigate to Reports > Audit Trail.
2. Set the date range filter to match the audit period.
3. Optionally filter by event type.
4. Click Export PDF (Professional and Enterprise) to download the formatted report.

The audit trail PDF includes every event with timestamps, details, and dataset versions. Each entry is immutable and cannot be backdated or modified.

Export Product Portfolio

Navigate to Products and click Export CSV. The CSV includes product name, HS code, country of origin, annual value, surtax status, CUSMA claimed status, and classification confirmation date.

Export Shipment History

Navigate to Shipments and review shipments for the audit period. Each shipment detail page shows per-line-item duty breakdown and dataset versions used.

Retrieve CUSMA Documentation

Navigate to CUSMA > Certificates (Enterprise) to review all certificates on file. Confirm each certificate covers the correct product, was valid during the audit period, and identifies the certifier. Navigate to CUSMA > Origin Assessment to retrieve tariff shift test results.

Generate Broker Sharing Link (Enterprise)

Navigate to Settings to generate a read-only sharing link for your customs broker to cross-reference records against filed declarations.

Pre-Audit Checklist

Classification Verification

• Review every product and confirm the 10-digit HS code is correct
• Use TariffTrail's Tariff Lookup to verify each code against the current Canadian Customs Tariff
• Click Confirm Classification on each product to log verification in the audit trail
• For uncertain classifications, consult a licensed customs broker or request an advance ruling from CBSA

CUSMA Claim Verification

• Confirm a valid certificate of origin is on file for every CUSMA-claimed product
• Verify each certificate's validity covers all shipment dates in the audit period
• Run the Origin Assessment for each CUSMA product to verify the tariff shift test is logged
• If any CUSMA claim cannot be supported, consider withdrawing it and filing a voluntary disclosure

Surtax Compliance Review

• Run the Surtax Checker on every product to confirm current status matches your records
• Verify that stacking scenarios were accounted for in duty calculations
• Cross-reference TariffTrail's determinations against amounts declared on B3 documents
• Identify discrepancies and consider filing BSF987 corrections before the audit

Shipment History Review

• Verify all shipments in the audit period are logged
• Check for gaps that auditors will question
• Confirm duty calculations match amounts declared to CBSA
• Review dataset version stamps on each shipment's audit entries

Financial Reconciliation

• Compare TariffTrail's Duty Summary report against accounting records and B3 declarations
• Ensure total MFN duty, surtax, and GST amounts are consistent across all sources
• Investigate and resolve discrepancies before the audit

Voluntary Disclosure Assessment

• If you identify errors, consider filing a Voluntary Disclosure with CBSA
• A valid voluntary disclosure filed before CBSA contacts you typically results in reduced or waived penalties
• Document your disclosure filing in TariffTrail so the audit trail reflects corrective action

Mitigating Factors CBSA Recognizes

• Voluntary disclosure filed before audit commencement
• Demonstrated compliance management system (such as a TariffTrail audit trail)
• Corrective action taken promptly after error discovery
• First occurrence with no prior compliance history issues
• Cooperation with the audit process

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This checklist is compliance guidance only. It does not constitute legal advice. For audit-specific legal counsel, consult a licensed customs broker or trade lawyer.