For most importers, the first sign of a CBSA audit is a letter: a ‘trade compliance verification’ notifying you that your imports for a given period are under review. It is not an accusation — verifications are a routine instrument of how CBSA enforces the Customs Act — but the distance between a quiet close-out and an expensive one is decided almost entirely by how prepared you were before the letter arrived.
Some verifications are random. Most are not. CBSA publishes semi-annual verification priorities — product categories where misclassification, undervaluation or unsupported origin claims are common — and selects importers whose declaration patterns fit. Beyond the published lists, certain behaviours reliably raise the odds: the same product classified differently across entries, duty rates that look too good for the goods, frequent post-entry amendments, and CUSMA claims filed without certifications on hand.
Verifications focus on one or more of three declaration elements. Tariff classification: is the 10-digit code correct for what the goods actually are — by composition and function, not by marketing name? Valuation: does the declared value include everything the transaction value method requires — assists, royalties, and the prescribed adjustments? Origin: can every CUSMA or other preferential claim be supported by a valid certification and a real rules-of-origin analysis, not just a ‘Made in USA’ sticker?
The notification identifies the program under review and requests records for a sample of transactions — sometimes a handful, sometimes dozens. From this point, the file you hand over frames everything that follows.
Expect to produce, per transaction: the commercial invoice, purchase order, proof of payment, freight and customs documents, and your B3 accounting entry — plus product literature or specifications where classification is at issue. Importers are legally required to keep these records for six years; ‘we don't have it’ reads as non-compliance, not as an excuse.
CBSA reviews the sample, asks follow-up questions, and issues an interim report you can respond to before the final report lands. The final report states findings per transaction and, where errors were found, the corrections required.
If errors are found, CBSA reassesses the affected entries — and the correction can reach back up to four years, with interest. Administrative Monetary Penalties (AMPS) may be layered on top, and they escalate for repeat findings. You will also be directed to correct future entries, which changes your landed cost from that day forward. A clean verification, on the other hand, is genuinely valuable: it documents, in CBSA's own paperwork, that your compliance program works.
The system deliberately rewards self-correction: find an error and file a voluntary correction before CBSA notifies you of a verification, and penalties are generally avoided — you pay what was owed, not what was owed plus AMPS plus a damaged compliance record.
Keep entry records organized by transaction and retrievable in days, not weeks. Maintain one verified code per product — our HS code classification service exists for exactly this. Hold a valid certification of origin for every preferential claim you file, and check that its HS code matches the entry. Reconcile a sample of your own entries once or twice a year, the way a verification officer would. And when a letter does arrive, involve your broker before you respond: the first submission sets the tone and the scope of the whole review.
Do respond by the deadlines, completely and in an organized package — volume without structure reads as evasion. Do answer the question asked rather than volunteering the history of your supply chain. Don't guess: ‘we will confirm and follow up’ beats a confident wrong answer that ends up in the final report. And don't treat the interim report as a formality — it is your structured chance to correct the record before findings harden.
Facing a verification, or want your files reviewed before one starts? Audit response and pre-audit reviews are part of our brokerage services.
Get your files reviewed before the letter arrives — or get expert support responding to one.