CBSA postal-stream enforcement is tightening — what it means for CAD filings and de minimis claims

Key Takeaways

• CBSA has increased section 40 examinations on courier and postal shipments under CAD 150, mirroring U.S. CBP’s postal-data crackdown.
• Informal clearance no longer means automatic release — missing or incomplete commercial invoices trigger cargo holds and retroactive CAD filing demands.
• If your client ships samples, returns, or warranty parts via Canada Post or integrated carriers, build a CAD filing protocol now before the first exam notice arrives.
• Undervalued declarations below the CAD 150 threshold carry the same AMPS exposure as formal entries — Level 1 penalties start at CAD 400 per contravention under D22-1-1.

CBSA is examining low-value courier and postal shipments more often

U.S. Customs and Border Protection just published a notice tightening data requirements for postal imports, aiming to recover more than USD 100 million in annual duties from undervalued e-commerce parcels. The rule targets shipments claiming informal clearance — declarations that skip formal entry because they fall below the Section 321 de minimis threshold.

CBSA is running a parallel play. Over the past six months we’ve fielded a sharp uptick in section 40 examination notices on courier and Canada Post shipments declared below CAD 150. The pattern is consistent: CBSA pulls the parcel, requests a commercial invoice and packing list, recalculates duty and GST, then demands a formal CAD filing to account for the difference. If the importer can’t produce compliant documentation within 48 hours, the shipment sits in postal or courier holding until someone does.

The informal-clearance shortcut that worked for sample shipments, warranty returns, and inter-office transfers is no longer automatic. If you’re clearing regular volumes of low-value parcels via Canada Post, FedEx, UPS, or Purolator, the old protocol — “it’s under CAD 150, let the carrier handle it” — now carries exam risk and retroactive CAD filing liability.

What changed: de minimis thresholds and CBSA enforcement posture

Canada’s duty de minimis sits at CAD 20; the GST/HST threshold rose to CAD 150 effective July 1, 2025. Shipments valued below CAD 150 qualify for informal clearance, meaning the carrier or Canada Post releases the goods on minimum documentation without filing a formal Commercial Accounting Declaration. The importer still owes applicable duty if the shipment exceeds CAD 20, but in practice carriers collect at the door and remit to CBSA without broker involvement.

That release-on-minimum-documentation pathway depends on accurate declared value and a legible commercial invoice. CBSA has always held the authority under Customs Act section 40 to examine any import, informal or not, and demand full accounting if the declaration looks wrong. The difference now is frequency: exam rates on courier low-value parcels have visibly increased since Q4 2024, and the exam notices we’re seeing cite the same handful of triggers — missing or vague invoice descriptions, declared values that don’t match the product category, repeat shipments from the same foreign shipper with suspiciously uniform CAD 149 values.

When CBSA flags a parcel for section 40 examination, the informal pathway closes. The importer or their broker must file a CAD via the CARM Client Portal, recalculate duty and GST using the correct HS 6-digit classification, declare origin (CUSMA, CETA, or MFN), post any required security, and wait for release. The carrier or postal facility holds the shipment until CBSA accepts the CAD and issues the release notification. Typical hold time is three to seven business days if you have all the paperwork; longer if you’re chasing invoices from an offshore supplier who thought “sample — no commercial value” was sufficient.

Where the exposure sits: undervaluation, missing origin, and retroactive duty

Three scenarios keep showing up in the exam notices:

Undervaluation below threshold. Shipper declares CAD 145 to stay under the GST line, but the commercial invoice CBSA pulls during the exam shows USD 200. CBSA recalculates at the prevailing Bank of Canada exchange rate, applies MFN duty (if no origin statement was provided), adds GST, and bills the difference. The importer also faces a K011 AMPS contravention for inaccurate valuation. Per Memorandum D22-1-1, Level 1 penalties for undervaluation start at CAD 400 per incident. If CBSA sees a pattern across multiple shipments, they escalate to Level 2 and may launch a broader verification.

Missing or insufficient commercial invoice. Parcel arrives with a hand-written customs label that says “electronics parts, CAD 50.” CBSA opens it, finds six SKU codes, no unit prices, no country of origin, no shipper or consignee detail beyond a name. They issue a section 40 request for a proper commercial invoice, packing list, and origin statement. If the importer can’t provide those documents, the shipment doesn’t clear. We’ve had clients scramble to recreate invoices from email order confirmations because the overseas supplier never issued a formal document.

No origin declaration, MFN duty applied. Importer routinely ships warranty parts from a U.S. manufacturing plant, assumes CUSMA origin, never bothers to state it on the courier waybill because the shipments clear informally. CBSA examines one parcel, sees no origin claim, applies MFN duty. The importer calls us asking to fix it retroactively. Under Customs Act section 32.2, you have 90 days from release to file a correction and claim preferential duty, but you must file a formal CAD adjustment through CARM and provide a CUSMA origin statement. If the shipment already cleared informally without a CAD on file, retroactive origin claims are significantly harder — CBSA may require a full compliance review and proof of qualifying production.

Practical steps: build a CAD filing protocol for low-value parcels now

If your client ships samples, returns, warranty parts, or inter-office transfers via Canada Post or integrated carriers on a recurring basis, the informal-clearance assumption no longer holds. The question isn’t whether CBSA will examine a shipment — it’s when, and whether you have the documentation in place to clear it without a multi-day hold.

Set a floor rule: any commercial shipment, regardless of value, gets a complete commercial invoice at time of export. Invoice must include shipper and consignee name and address, detailed description of goods (not “parts” or “samples”), HS classification if you know it, unit price and currency, country of origin, and reason for shipment (sale, warranty replacement, return for repair, no-charge sample). If the shipment qualifies for CUSMA or CETA preferential duty, state it on the invoice. Carriers and Canada Post will still process the parcel informally if it’s under CAD 150, but when CBSA pulls it for exam, you have the documentation ready and the CAD filing is straightforward.

If your monthly parcel volume justifies it, consider switching from informal clearance to pre-filed CAD entries even for low-value shipments. Integrated carriers (FedEx, UPS, Purolator) can file CADs via PARS on your behalf if you provide commercial invoices in advance and hold an RPP bond for release prior to payment. You’ll pay the carrier’s brokerage fee (typically CAD 75 to CAD 150 per entry), but you eliminate exam holds and gain predictable clearance timelines. For clients running just-in-time production or tight fulfillment windows out of our Montreal warehouse, the brokerage cost is cheaper than the downstream penalty when a section 40 hold kills a delivery promise.

For sample shipments and no-charge warranty parts, accuracy matters more than value. If the part has no commercial value, state CAD 0.01 and write “warranty replacement — no commercial value” in the description. CBSA will still examine a percentage of these, but a clear statement avoids the suspicion that you’re lowballing value to dodge duty. The exam rate on accurately documented no-charge shipments is lower than the rate on vague “sample” declarations with round-number CAD 100 values.

The broader implication: informal clearance is not a compliance safe harbor

The U.S. CBP rule change and CBSA’s increased postal and courier enforcement both point to the same policy shift: revenue agencies are tired of watching e-commerce and cross-border parcel flows leak duty revenue through undervaluation, vague declarations, and informal-clearance volume that never gets a second look. The de minimis thresholds still exist, but the assumption that below-threshold shipments are invisible or low-risk is dead.

For Canadian importers, that means informal clearance is a processing convenience, not a compliance safe harbor. Every parcel carries the same documentation, valuation, and origin requirements as a formal CAD entry. If CBSA examines it and finds the declaration lacking, you’re filing a CAD retroactively, paying duty and GST you thought you’d avoided, and potentially facing AMPS penalties for inaccurate reporting. The carriers won’t warn you — they’ll forward the CBSA exam notice and wait for you to solve it.

If you’re clearing regular low-value volumes and the current protocol is “let the carrier handle it,” now is the time to audit your documentation, train your shipping department on commercial invoice requirements, and decide whether pre-filed CAD entries buy you enough hold-time protection to justify the brokerage cost. The exam rate is only going up, and the first time a section 40 hold kills a customer delivery promise, the cost equation flips.

We file CADs against courier exam notices every week. If your informal-clearance volume is starting to trigger CBSA attention, talk to us.

Frequently Asked Questions

What is the de minimis threshold for imports into Canada?

The duty de minimis threshold is CAD 20; the tax (GST/HST) threshold is CAD 150 as of July 1, 2025. Shipments below CAD 150 may qualify for informal clearance, but CBSA still requires accurate commercial invoices and origin declarations per Memorandum D17-1-10.

Does CBSA require a CAD for courier shipments under CAD 150?

Normally no — informal entries are released on minimum documentation. But if CBSA flags the shipment for a section 40 examination, the importer or broker must file a retroactive CAD within the correction window to account for duties, GST, and origin. We’ve seen exam rates on courier low-value parcels triple since Q4 2024.

What happens if my commercial invoice is missing or incomplete on a postal shipment?

CBSA holds the shipment under section 40 until you provide a compliant commercial invoice, packing list, and origin statement. If duties or taxes are owing after the exam, you’ll file a CAD and pay via the CARM Client Portal. Holds typically add three to seven business days to delivery.

Can I claim CUSMA origin on informal courier entries?

Yes, but you must declare origin at time of import. CBSA does not accept retroactive origin claims on informal entries unless you file a formal CAD correction within 90 days of release under Customs Act section 32.2. If the shipment clears informally without an origin statement, MFN duty applies and sticks.

What are the AMPS penalties for undervalued courier shipments?

Undervaluation on any entry — formal or informal — is a K011 contravention under Memorandum D22-1-1. Level 1 penalties start at CAD 400 per incident. If CBSA determines a pattern of undervaluation across multiple courier shipments, they may escalate to Level 2 (CAD 2,000 minimum) and refer the file for verification.

Should I use Canada Post or an integrated carrier for sample shipments?

Both channels are under increased CBSA scrutiny. Integrated carriers (FedEx, UPS, Purolator) file electronic manifests via PARS and can provide release prior to payment if you hold an RPP bond, but they charge brokerage fees. Canada Post does not file CADs automatically — if an exam is triggered, you’ll need to engage a licensed broker to clear the parcel retroactively.

How do I avoid courier holds on warranty parts and returns?

Attach a complete commercial invoice showing the original sale date, reason for return, and repair/replacement value. If the part is a no-charge warranty replacement, state CAD 0.01 value and mark “warranty replacement — no commercial value” in the description. CBSA will still examine a percentage of these shipments, but accurate documentation keeps the release timeline predictable.

Source: Supply Chain Dive