CBSA Extends DONP2 Preliminary Phase: What Another 30 Days Means for Your Plywood Imports

The Extension

CBSA published notice on July 2, 2026 extending the preliminary phase of the decorative and other non-structural plywood investigation (DONP2) by 30 days. The Special Import Measures Act normally caps preliminary investigations at 90 days from initiation, but CBSA cited complexity, novelty, and the number of parties involved. The new preliminary determination deadline sits at the end of August 2026.

If you’re importing subject goods, that 30-day shift cascades through every subsequent milestone: provisional duty imposition, final determination, and the five-year injury review clock. The delay is procedural, but the operational consequences are not.

What Changes for Active Importers

Provisional duties get imposed the day after CBSA issues a preliminary determination of dumping or subsidizing. Under the original timeline, importers expected that trigger around late July. The extension pushes it to late August at the earliest.

That’s an extra month of importing at normal-duty rates before provisional AD/CVD kicks in. If you were planning a Q3 inventory build to front-run provisional duties, the window just widened. If you already placed orders with a July provisional-duty assumption baked into your landed-cost math, your working capital model changed.

Provisional duty rates won’t be known until CBSA publishes the preliminary determination. We’ve seen provisional margins on Chinese plywood range from 15% to over 100% depending on the exporter’s cooperation and NRM methodology. The extension doesn’t signal leniency; CBSA is sorting through more data, not backing off.

Surety and Release Prior to Payment

If you’re importing under an RPP bond, the extension affects your surety calculation. SIMA subject goods trigger higher security requirements the moment provisional duties are imposed. Your broker files CADs with provisional AD/CVD line items, and CBSA adjusts your monthly K84 to reflect the new exposure.

Most RPP bonds are sized to cover duties, GST, and expected AMPS exposure over a rolling 30-day period. Add provisional duties at an unknown margin, and your bond may fall short. CBSA will hold release if the surety cushion isn’t adequate. We’ve seen clients scramble to top up bonds mid-month when provisional duties hit harder than forecasted.

If your current bond is sized for standard MFN duty on plywood (typically around 0% to 6% depending on HS classification), and provisional duties land at 40%, you’re not covered. Talk to your broker now, before the preliminary determination drops. Bond amendments take time, and release holds cost more than the amendment fee.

HS Classification and Subject Goods Scope

The DONP2 investigation covers decorative and other non-structural plywood. CBSA’s product definition includes specific construction parameters: core material, face veneer species, finish treatments, and intended end-use. The scope document is detailed, but real-world classification is messier.

If you import plywood at HS 4412.31 (at least one outer ply of tropical wood), HS 4412.33 (other plywood with at least one ply of non-coniferous wood), or HS 4412.34 (other plywood with both outer plies of coniferous wood), and it’s non-structural, you’re in scope. If you import hardwood plywood at HS 4412.99 and it fits the decorative/non-structural definition, you’re in scope.

CBSA won’t care that your invoice says “furniture-grade panel” if the physical goods meet the product definition. Scope determinations are technical. If your importer of record is filing CADs on Chinese plywood and you’re not certain whether it’s subject goods, get a ruling now. The extension gives you time to sort it before provisional duties hit.

We’ve helped clients reclassify goods that were borderline structural vs decorative, and request advance rulings on laminated panels that didn’t fit neatly into the scope language. That work takes weeks. Don’t wait for the preliminary determination to figure out if your SKU is in scope.

NRI Complications

If you’re importing as a non-resident importer (NRI) and selling into Canada, the SIMA liability sits with you, not the Canadian consignee. Provisional duties, final duties, and retroactive assessments all attach to the NRI’s CARM account.

CBSA has been tightening NRI enforcement under CARM. If your NRI entity isn’t registered properly in the CARM Client Portal, doesn’t have a Canadian business number on file, or is using a third-party surety arrangement that doesn’t cover SIMA exposure, you’ll hit a release block the first time provisional duties apply.

We see this most often with U.S. exporters who ship plywood from China to Canadian buyers on a delivered basis. The U.S. entity is the importer of record, files CADs through a broker, but hasn’t updated their CARM financial security to account for SIMA risk. The extension buys you time to fix that gap before it becomes a dock problem.

What CBSA Is Actually Doing

CBSA is running two parallel investigations: dumping and subsidizing. The dumping investigation compares export prices to normal values (usually Chinese domestic selling prices or a surrogate-country benchmark). The subsidy investigation looks at government assistance: grants, preferential loans, VAT rebates, land-use subsidies, and other support programs.

The extension notice cites complexity and the number of parties. That usually means CBSA received incomplete or late responses from Chinese exporters, or the subsidy programs are layered in a way that requires deeper digging. It doesn’t mean the investigation is weak. CBSA extended the corrosion-resistant steel investigation twice and still landed provisional duties north of 50%.

The preliminary determination will include exporter-specific margins if CBSA has adequate data, and an “all others” rate for non-cooperating or uninvestigated exporters. The “all others” rate is almost always higher. If your supplier didn’t respond to CBSA’s dumping and subsidy questionnaires, expect the worst margin.

Timing for the Final Determination

The extension shifts the final determination timeline as well. SIMA gives CBSA 90 days from the preliminary determination to issue a final dumping and subsidy decision. That puts the final determination window around late November 2026 if the preliminary lands in late August.

The Canadian International Trade Tribunal (CITT) runs a separate injury inquiry in parallel. CITT has 120 days from CBSA’s preliminary determination to decide whether the dumping/subsidizing caused or threatens material injury to Canadian producers. If CITT finds injury, duties become permanent for five years. If CITT finds no injury, the file closes and any collected provisional duties get refunded.

The extension doesn’t change CITT’s statutory timeline, but it delays the start. Importers who were planning for a Q4 final determination now face a decision point in early 2027. If your supply contracts with Chinese mills run calendar-year, the duty uncertainty just bled into your 2027 planning cycle.

What to Do Before Late August

Pull your last six months of CAD filings and filter for HS codes 4412.31, 4412.33, 4412.34, and 4412.99 where the origin is China. Cross-reference the product descriptions against CBSA’s DONP2 scope document. If anything is borderline, request an advance ruling or at minimum get your broker’s written opinion on whether it’s subject goods.

Review your RPP bond. If you’re importing subject goods at volume, model your security requirement assuming provisional duties at 30%, 50%, and 70%. Those aren’t predictions—they’re stress tests. If your bond can’t cover the middle scenario, line up an amendment or a standby letter of credit now.

If you’re an NRI, confirm your CARM Client Portal registration is current, your business number is on file, and your financial security arrangement explicitly covers SIMA liabilities. CBSA won’t remind you when provisional duties hit. The first notice will be a release hold.

If your supply chain includes sufferance warehousing for Chinese plywood, talk to your warehouse about how provisional duty CAD amendments will affect monthly statements and per-pallet accounting. Goods sitting in sufferance when provisional duties are imposed get assessed at the new rate when you file the final CAD for release. That’s not a surprise you want to discover during month-end reconciliation.

CBSA’s preliminary determination will be public. The extension gave you 30 extra days to get your house in order. We help importers model SIMA exposure and file advance rulings every quarter.

Source: CSCB