CN25-29 Cancelled: RMD Port-of-Release Corrections Move to D-Memo

The Short Version

CBSA pulled Customs Notice 25-29 last month. That’s the notice that covered how to correct port-of-release and sub-location codes on Form A48 when you’re filing RMD (Release on Minimum Documentation) corrections. The reason: the policy is now in the updated D-memo, so the standalone notice became redundant. No process change. Same correction rules. Just one fewer document to track.

If you’re filing CADs through CARM and using RMD release for time-sensitive shipments, this is housekeeping. But it’s worth understanding why CBSA still cares about port-of-release codes and when getting them wrong creates friction.

Why Port-of-Release Codes Matter

The port of release is the CBSA office that processes your release. The sub-location is the specific facility under that office’s jurisdiction. If you’re clearing at a sufferance warehouse in Lachine, your port code might be Montréal (0442) and your sub-location the warehouse’s FIRMS code. If you’re doing direct delivery at the commercial border crossing in Lacolle, it’s a different port and no sub-location.

These codes determine:

• Which CBSA officer reviews your CAD and release request
• Where an examination happens if your shipment gets flagged
• How cargo control and conveyance reporting tie to your accounting declaration
• What shows up in CBSA’s internal tracking when an importer or broker has multiple concurrent shipments

Get it wrong on the initial A48 and you might file your CAD to the wrong office. That can mean a delay while CBSA routes it internally, or worse, a request to refile. For RMD shipments where the importer is racing a production line cutoff or a retail delivery window, a day’s delay is real money.

What Changed (and What Didn’t)

CN25-29 told brokers how to correct port or sub-location errors on Form A48 after RMD release but before final CAD accounting. The steps: note the correction reason, reference the original A48 control number, submit the corrected A48 with the updated port code, then file your CAD to the correct office.

That process hasn’t changed. What changed is where you find the instructions. Instead of citing CN25-29, you now cite the relevant D-memorandum published by CBSA. CBSA’s position is that once a policy goes into a D-memo, the standalone notice is redundant and gets pulled. Standard practice.

For brokers, this is a minor win. Fewer scattered notices to cross-reference. One authoritative D-memo. The CARM Portal doesn’t care which document you’re following as long as the correction follows the published process.

When You Actually Need to Correct Port of Release

Most of the time, you don’t. If your drayage carrier delivers to the facility you declared, the port and sub-location are locked in from the eManifest and A48. But there are a few scenarios where corrections come up:

Importer changes destination mid-transit. Container was supposed to go to a Montreal sufferance warehouse for deconsolidation but the importer reroutes to direct delivery at the border. Different port, different CBSA office. You file a corrected A48 before the goods arrive, update the port code, and the release flows to the right office.

Carrier delivers to the wrong facility. Rare but it happens. Drayage driver drops at the wrong warehouse. Your A48 says FIRMS code X, the container is sitting at FIRMS code Y. You correct the A48, notify CBSA, and refile to the office that has jurisdiction over the actual location. If the goods have already been released, this gets messier.

Broker error on the initial filing. You’re clearing a consolidated shipment with multiple delivery points and you fat-finger the sub-location. Catch it before release, file the correction, move on. Catch it after release and you’re documenting why your CAD shows a port that doesn’t match the physical movement.

None of these are daily occurrences, but when they happen, having the correction process documented in the D-memo instead of a years-old customs notice is cleaner.

CARM CAD Filing and Port Codes

Under CARM, the port of release you declare on Form A48 ties to the CAD you file in the CARM Client Portal. If you correct the port after RMD but before final accounting, your CAD has to reference the corrected A48 and match the updated port. The portal won’t stop you from filing to the wrong office, but CBSA’s back-end will flag the mismatch and you’ll get a query.

For importers running bonded or sufferance warehouse operations with Release Prior to Payment (RPP) arrangements, port-of-release accuracy matters for your monthly K84 statement. Every CAD you file ties to a port and a bond. If your CADs are split across multiple ports because of inconsistent A48 filings, your financial security calculation gets harder to audit. CBSA won’t reject your bond, but your broker will spend extra time reconciling.

The Real Benefit: Single Source of Truth

The operational upside here is not about the correction process. It’s about CBSA slowly consolidating scattered customs notices into updated D-memos. When you’re training a new clerk or onboarding a new client, you hand them the D-memo library, not a mix of D-memos, customs notices, and CBSA emails from 2019. That consolidation makes compliance documentation cleaner.

For importers who run their own customs compliance programs in-house, this is the kind of administrative tidying that saves time during audits. CBSA verification officers pull D-memos, not customs notices. If your SOP references a cancelled notice, it looks dated even if your process is current.

Bottom Line

CN25-29 is gone because the policy is in the D-memo. If you’re filing RMD corrections with port-of-release changes, the process is the same. The only thing that changed is where you look for the instructions. That’s a documentation win, not a procedural headache.

If your current A48 filing process still cites CN25-29 in your internal checklist, swap in the updated D-memo reference and move on. We handle RMD port corrections weekly. Get in touch if you’re not sure your process matches what CBSA expects.

Source: CSCB