On the first business day of the new year, the 6th of January 2015, the Canada Border Services Agency (CBSA) issued its customs compliance verification priorities for 2015. After first noting that trade program verifications of tariff classification, customs valuation and origin are not limited to targets but rather are also initiated randomly to assess risk and revenue, and to promote voluntary compliance, the CBSA shared its priorities for each of its customs compliance programs. In some cases, targets are experiencing a second round of trade verification, and in other cases, the CBSA is either continuing an existing round of verification or is planning a new round.

Brand new tariff classification verifications will be conducted for cereals, geophysical and oceanographic instruments, articles of apparel, clothing accessories, parts for power trains, and generating sets.

First round verifications will continue in 2015 on certain imports of furniture for non-domestic purposes, various chemical products, batteries, apparel samples, bags of polymers of ethylene, footwear “customs valued” at $30 or more per pair, hair extensions, machinery for public works, sacks and bags, special purpose motor vehicles, and polyurethanes in primary forms.

Importers of fresh cut flowers, pickled vegetables, curling irons, spectacle lenses, palm oil, safety headgear, seaweed, dextrins and other modified starches, disposable and protective gloves, wheel rims and spokes, coconut milk (Asian countries), and gazebos will experience a second round of customs audits of tariff classification practices.

Customs valuation audits will be commenced or continue for fresh cut flowers, apparel, footwear, and preparations and pastrycooks’ products.

Finally, origin verifications will continue or be initiated on mattress upholstery, t-shirts and jewelry.

Importers of the indicated goods would be prudent to prepare themselves for CBSA trade verifications by conducting internal reviews of their compliance practices, thereby getting out in front of audit results that may include application of administrative monetary penalties. Given the random application of CBSA audits, the same would apply to all other importers. As business priorities and judgments necessarily colour decisions as to whether or not to become compliant retroactively or prospectively, if at all, it is very important that internal reviews be conducted under the auspices of solicitor-client privilege to retain confidentiality. This is achieved by retaining actual legal counsel; no other professional advisors can offer the same privilege.