Fully Briefed

Issue 001 | CUSMA Rules of Origin

We heard you. Here's your briefing.

You've been saying the rules keep changing and nobody's connecting the dots for you. Three government sources published updates in the last 90 days that tell one story — and none of them mentioned each other. This issue connects them.

A note before we start: I'm a CPA, not a customs lawyer or trade consultant. What I do is watch the sources — CBSA notices, Finance Canada announcements, StatCan data, CUSMA texts — and translate what I find into financial terms. This is synthesis, not regulatory interpretation. For your specific compliance situation, you need a licensed customs broker. For understanding what's happening and what it means for your costs, that's what Fully Briefed is here for.

The Dashboard

Indicator	Value	Source	Why It Matters
Canada-US trade balance	+$5.4B surplus (↓ from $5.7B)	StatCan, Jan 2026	Surplus narrowing — watch for shifts in trade flow pressure
CAD/USD	1.3825	Bank of Canada, Apr 10	Landed cost baseline for this week's import calculations
CanadaBuys	Buy Canadian policy active for contracts ≥$25M; $5M threshold Jun 15	CanadaBuys	Procurement threshold dropping — more contracts affected soon
CBSA enforcement	2026 verification priorities expanded to include CUSMA origin	CBSA	Origin documentation is now an active audit target
CARM status	Full implementation since Jan 1 — importers must hold own accounts	CBSA/CARM	CBSA sees your data directly now — no broker buffer

This issue: MFN duty rate on manufactured goods: ~5%. Combined exposure without CUSMA: up to 15% (MFN + Section 122). CBSA lookback window for origin audits: 4 years.

The Briefing

Something shifted in January that most Canadian importers haven't registered. CBSA published its 2026 trade compliance verification priorities and expanded its list to include CUSMA origin verification — more explicitly than it has in prior years. Automotive is the named category, but the broader signal is clear: CBSA is paying closer attention to whether CUSMA claims are documented, not just claimed.

The timing isn't random. As of February 24, 2026, the US imposed a new 10% global tariff (Section 122) on most imports. CUSMA-compliant goods are exempt. Non-compliant goods aren't. That exemption is now worth real money on every shipment — and when the financial stakes of qualifying go up, so does the motivation to verify whether you actually do.

Two government sources. One picture.

The Connection

Here's the part that doesn't make the press coverage: two changes happened at the same time, and they interact in a way that matters.

CBSA expanded its origin verification scope — that's the first piece. The second piece is CARM. As of January 1, 2026, customs brokers can no longer post security or clear goods on an importer's behalf. Importers now need their own CARM accounts, their own financial security enrolled, and their own import data visible directly in the system.

What this means practically: CBSA now has a cleaner, more direct data picture of your imports than it had before. The broker's account used to be the intermediary layer. Now it isn't. CBSA can see your import history, your CUSMA claims, and your origin certifications more directly — and it has said it intends to look.

Connect that to the upcoming July 2026 CUSMA joint review, where rules of origin are already flagged as a focal point for renegotiation. The US Trade Commission launched its own review of CUSMA automotive rules of origin in February. Whatever the rules look like post-review, CBSA is not waiting until July to start asking questions about current claims. The window between now and the review is when companies with documentation gaps are most exposed.

The Numbers

Let me put a dollar figure on this, because that's what actually matters.

If you're importing $400,000 of US-origin manufactured goods annually at a most-favoured-nation (MFN) duty rate of 5%, your annual duty exposure without CUSMA preference is $20,000. With a valid CUSMA qualification, that drops to zero. That $20,000 is either margin you're protecting or pressure landing in your pricing conversation with customers.

Now factor in February's Section 122 tariff. CUSMA-compliant goods are exempt. Non-compliant goods are not — they absorb both the MFN rate and the 10% additional layer. On that same $400,000 import stream, non-qualifying goods could face 15% or more in combined duties: $60,000 annually on a program that used to cost nothing.

The retroactive exposure is a different category of risk. A failed CBSA origin verification can produce duty assessments going back four years, plus interest and potential penalties. For a small importer, a surprise six-figure assessment doesn't fit in the operating budget. It fits in a crisis.

The cost of getting the documentation in order: a few hours with a customs broker, a CBSA self-certification template, and a supplier declaration request to your top three vendors. One-time cost. Every shipment after that is defended.

The Action

This week, go to the CBSA CUSMA certification page (cbsa-asfc.gc.ca — search "CUSMA certifying origin") and check two things. First: do you have a valid, current certification of origin for your top imported product lines? Blanket certifications are good for 12 months — if yours were issued before April 2025, they have lapsed. Second: does your certification include all nine required data elements CBSA lists? If you've never verified that list, that's the starting point. Under 90 minutes of actual work. It tells you exactly where your exposure is.

The Broader Picture

The July 1, 2026 CUSMA joint review deadline is the through-line behind all of this. Every country must confirm by that date whether it wants to extend the agreement for another 16 years. The US is already pushing on automotive rules of origin. The rules that determine whether your product qualifies today may look different after that review.

That's not an argument for paralysis. It's an argument for getting documented now, while you know the rules, rather than trying to retrofit compliance during a renegotiation. A company entering the review period with clean, current origin documentation is in a materially different position than one that doesn't. Whatever the rules become, documented compliance is the starting point — not the finish line.

The Question

Right now: do you have actual documentation — a certification of origin, a supplier declaration, or a producer's written statement — that you could hand to a CBSA auditor tomorrow to support your CUSMA claims? Not "I assume so." Not "my broker handles it." The actual paperwork.

Reply and tell me what sector you're in. I'm building a picture of where the documentation gaps are concentrated — and it'll shape the next few issues.

— Trevor

I'm a CPA watching public sources. This is not customs brokerage or legal advice. For your specific situation, talk to a licensed customs broker.

Reply anytime. I read every one.

CUSMA Rules of Origin: What Three Government Sources Are Saying Right Now