Issue 005 · Week of May 11, 2026
Three 2026 changes feed the same RPP security review — and May 6 is real relief for a narrow slice of importers
Section 17 (effective Jan 1), the May 6 expansion of the 2025 Steel Surtax Remission Order, and StatCan’s March trade-balance flip all feed one input — highest monthly A/R across the October 20, 2025 to October 19, 2026 review window. The new requirement bites January 15, 2027.
§ 1 — The Dashboard
| Indicator | Value | Source | Why it matters |
|---|---|---|---|
| Canada-US merchandise trade balance | +$1.8B surplus (March 2026) | StatCan, May 5 | First monthly surplus since September 2025. If your Q1 import mix shifted with the macro tape, the October-to-October base feeding your January 15 RPP-security update reads differently than last year’s. |
| CAD/USD (most recent close) | ~0.730 USD per CAD | Bank of Canada | Pulled back from 0.736 on April 30 after the soft April LFS print. Verify Friday close before any landed-cost calc. |
| BoC overnight rate | 2.25% (held Apr 29) | BoC press release, Apr 29 | Held since October 2025. Next decision June 10. April MPR projects 1.2% 2026 GDP. |
| CPI inflation (latest) | 2.4% (March 2026) | BoC April MPR | BoC projects April CPI near 3% before easing back to the 2% target. April release pending. |
| CARM IOR liability — status | In force since 2026-01-01 | CBSA CN25-32 | Section 17 amendments make the importer of record jointly and severally liable. The customs-broker BN transition measure ended December 31, 2025. |
§ 2 — The Briefing
Three 2026 inputs feed the same October-to-October window. One is a tailwind for affected importers.
Every CARM-enrolled importer with Release Prior to Payment privileges has an annual financial-security review. Per CBSA Memorandum D17-5-2 §7.8 (revised August 2025), CBSA reads the highest monthly accounts receivable across a 12-month window running October 20 of one year to October 19 of the next, then communicates the new requirement through the CARM Client Portal. Compliance is required by January 15. The window in play right now is open: October 20, 2025 to October 19, 2026, with the new requirement landing January 15, 2027.
Three changes hit that window. CBSA Customs Notice 25-32 codified the Section 17 Customs Act amendments effective January 1 — joint-and-several duty liability now sits with the importer of record, not the broker. Canada Gazette Part 2, P.C. 2026-334, gazetted May 6, expanded the 2025 Steel Surtax Remission Order — 84 product-specific items added to the schedule and a second in-transit window catching goods hit by the December 26 quota tightening. And StatCan reported May 5 that Canada’s merchandise trade balance with the US flipped to a $1.8B surplus in March — the first since September 2025. Three different beats; one rolling A/R window.
Three lenses on the same calc. Section 17 determines whose books the peak A/R sits on. P.C. 2026-334 may move duty out of A/R going forward (and as a refund retroactively) for importers whose products are now scheduled. The March trade flip shifts the historical base so the 2026 review doesn’t read like the 2025 review. Three named primary sources, one cash-on-hand number — communicated through the CCP after the window closes, due January 15, 2027.
§ 3 — The Numbers
$400K of non-FTA covered steel: how each lever moves the October-to-October number
Worked example. An SME importer of covered carbon steel from a non-FTA partner — flat-rolled product covered by Schedule 1, Class 1 of SOR/2025-148, HS chapters 7208 through 7212 — at $400,000 a year. CARM Client Portal registered, RPP-enrolled, customs-broker delegation in place. Even monthly distribution: ~$33,300/month.
Pre-May 6 base. The non-FTA quarterly TRQ for Class 1 dropped to 20% of 2024 import volumes on December 26, 2025 (SOR/2025-266). At that level quotas fill early; assume over-quota for most of each period. The 50% surtax under section 53 of the Customs Tariff applies on value for duty: 0.50 × $33.3K ≈ $16.7K/month of surtax into duty A/R, alongside base duty and GST. Annual surtax exposure: ~$200K. May 6 amendment input. P.C. 2026-334 added 84 items to the remission schedule (items 9 through 92, e.g., item 23, galvanized DX51D at 0.14 mm; item 60, heat-treated A-516 plate over 3.28 inches; item 30, welded stainless pipe). If this importer’s product description matches one of the 84, the surtax is remitted automatically at the Commercial Accounting Declaration going forward and refundable retroactively to June 27, 2025 within a two-year claim window. The $16.7K/month surtax line exits A/R going forward; up to ~$175K of June 2025–April 2026 surtax becomes a refund claim. If the description doesn’t match, the May 6 amendment is neutral. Section 17 input. Whatever the duty number is, post-January 1 it sits on the importer’s books per CN25-32 and D17-2-5 — not on the broker’s. StatCan March input. The Canada-US trade flip is informational at the individual-importer level; magnitude depends on this importer’s own Q1 mix.
Three inputs, one number. Per D17-5-2 §7.8, peak monthly A/R from the October 20, 2025 to October 19, 2026 window sets the new requirement; compliance is required by January 15, 2027. If this importer’s peak month sits inside the surtax window and the product is now scheduled, the May 6 amendment compresses the peak by ~$16.7K. At the 100% cash-deposit option, that’s ~$16.7K of cash freed. At the 50% surety-bond option, ~$8.4K of bonding capacity freed. Plus the retroactive refund. If the product isn’t scheduled — or if you’re not in covered steel at all — the May 6 amendment is neutral. Peak A/R is driven by base duty, applicable surtax, and GST on your highest monthly volume; for non-steel CARM/RPP importers the calc shape is identical, just with different inputs. Same window, same January 15 effective date.
§ 4 — The Action
One step to take this week
Walk the CARM Client Portal in one session and validate three things.
(a) Your business is the registered importer; the BN15 on accounting is yours, not your broker’s.
(b) Any broker still acting on your behalf has explicit delegated authority on your account post-2026.
(c) Your highest monthly A/R inside the October 20, 2025 to October 19, 2026 window — the input the RPP-security review will use to set the new requirement effective January 15, 2027.
The three checks apply whatever your commodity mix. Different 2026 inputs feed each importer’s October-to-October window, but the calc reads the same way: highest monthly A/R, new requirement effective January 15.
§ 5 — The Question
Are you the importer of record on shipments your broker handles?
If you’ve walked the BN15 + RPP + broker-delegation sequence post-2026-01-01, what surprised you? A piece of paperwork still routing through a broker BN by default? A delegation step that didn’t take? An A/R number that drifted as the macro tape shifted? Reply — the answer is genuinely different across SMEs, and walking into the October 20 review, that variation is what your security number looks like.
A note on framing: Fully Briefed synthesizes publicly available government source material and translates findings into financial terms. This is education, not regulatory or customs-law interpretation. For your specific CARM enrolment, RPP financial-security calculation, importer-of-record status, or remission-order eligibility, work with a customs broker, classification specialist, or trade lawyer.
Trevor Ryhorchuk, CPA, CIA, PMP
Fully Briefed — Canadian Trade Intelligence
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