D4-1-5 Storage of Goods: April 2026 CPI Adjustment and What Changes for Sufferance Filers

The CPI adjustment hit April 1, and D4-1-5 now reflects it

CBSA posted the updated version of Memorandum D4-1-5: Storage of Goods last week. The revision incorporates the annual Consumer Price Index adjustment to commercial storage fees that took effect April 1, 2026, plus accessibility and formatting cleanup. If you file CADs for goods sitting in sufferance warehouses or CBSA examination facilities, the daily storage rate you invoice just went up by the CPI delta—about 2.3 percent this year, in line with Bank of Canada trailing twelve-month inflation.

The memo itself is short. The practical consequence is not. Sufferance warehouse operators pass the indexed CBSA daily storage charge straight through to the importer of record, and most importers don’t budget for that line item until it appears on the release invoice. If your broker is also your sufferance operator, the charge shows up combined with drayage, exam fees, and RPP bond interest. If you’re using a third-party warehouse like FENGYE Montreal, it’s a separate reconciliation item on your monthly statement.

Fourteen days is still the window, and the clock starts at arrival

D4-1-5 has always been clear: goods may remain in sufferance for up to fourteen days from the date of arrival without requiring a warehouse licence extension or a formal application for extended storage. After fourteen days, you need explicit CBSA approval and you pay a penalty-tier daily rate that scales fast.

The fourteen-day clock starts when the conveyance reports arrival via eManifest (ACI for highway, pre-load air for commercial air, advance cargo for marine). Not when your broker files the CAD. Not when the exam is complete. Arrival date is the anchor, and if your documentation isn’t ready by day ten, you’re cutting it close.

Most problems we see fall into three categories:

• Late or incomplete commercial invoice. Shipper sends a pro forma, not the final CI. Broker can’t file the CAD until the actual invoice with Incoterms, HS detail, and currency is in hand. Two days slip to four, and you’re now at day twelve.
• CFIA or other OGD holds. If the shipment requires a CFIA permit and the permit wasn’t pre-cleared or wasn’t attached to the CAD, CBSA won’t release. The clock keeps running while you sort out the food import licence or the pest control product registration number.
• SIMA verification. If your goods are subject to Special Import Measures Act duties and CBSA flags the entry for an NRM check, you can lose three to five days waiting for the examiner’s report. The storage fee compounds daily while the file sits in the queue.

Any of those scenarios can push you past fourteen days. Once you cross that line, you’re filing for an extension and explaining to CBSA why the goods are still in sufferance. The approval isn’t automatic, and the elevated storage rate applies retroactively from day fifteen.

What the CPI adjustment means for your cost stack

The fee increase is modest in percentage terms, but sufferance storage is already expensive relative to commercial warehousing. CBSA’s daily rate is set to recover the cost of operating a secure bonded facility, and it’s not competitive with a standard public warehouse daily rate. The indexed rate for 2026 is now roughly CAD 1.45 per hundred kilograms per day for the first fourteen days, up from CAD 1.42 in 2025.

If you’re storing a 20,000 kg container for ten days while waiting on exam clearance, that’s CAD 290 in CBSA storage fees alone, before any warehouse handling, drayage detention, or RPP bond carrying cost. The CPI bump added about CAD 6 to that example. Small per shipment, but if you’re running fifty containers a month and half of them sit for seven-plus days, the annual delta is a few thousand dollars you didn’t budget.

The bigger cost isn’t the CPI adjustment—it’s the day count. Every extra day in sufferance is a day you’re not moving the goods to your own distribution facility or cross-docking to your retail network. If your typical release cycle is eight days and you can cut it to five by pre-filing documentation and pre-clearing OGD requirements, you save more in storage fees than the CPI increase will cost you all year.

Filing discipline cuts the day count

The importers who avoid sufferance cost blowouts are the ones who treat the fourteen-day window as a ten-day window and file CADs within 48 hours of arrival. That means:

• Commercial invoice, packing list, and bill of lading are transmitted to the broker before the container crosses the border.
• HS classification is settled in advance, especially if the goods are new or if there’s any risk of a D-memo interpretation question. If you’re importing something that straddles two tariff headings and you wait until arrival to ask your broker which one to use, you’ve already lost two days.
• CUSMA or CETA origin certificates are attached to the entry at filing, not requested after CBSA queries the preference claim. If you’re claiming preferential duty treatment, the certificate of origin must be valid and on file when the CAD is transmitted. Retroactive preference claims are possible, but they require a compliance amendment and they don’t stop the storage clock.
• OGD permits are cleared before arrival. CFIA, Health Canada, ECCC—whatever the commodity requires. If the permit lapses or the product isn’t listed on the licence, you’re starting over and the container is sitting in sufferance while you fix it.

None of this is new. D4-1-5 hasn’t changed the fourteen-day rule; it’s been there since the last major revision in 2016. The CPI adjustment just makes the cost of delay slightly more visible.

Bond and liability exposure when storage fees accumulate

If you’re operating under an RPP bond (Release Prior to Payment), CBSA accrues the storage fees against your bond alongside duties, GST, and any AMPS penalties. The storage charge is a Crown debt, and it’s senior to almost every other trade payable. If your bond is sized for monthly duty flow but you’re also carrying rolling sufferance storage charges from slow-release containers, your effective available bond capacity is lower than you think.

We’ve seen importers hit their bond ceiling mid-month because sufferance fees from exam holds in the prior period hadn’t been reconciled on the K84 monthly statement yet. CBSA won’t release new entries if your account is over the bond limit, even if the overage is a storage fee accrual and not unpaid duty. You’re stuck until you either pay down the account or request a bond increase.

The CPI adjustment doesn’t change the bond math, but it does mean the accrual rate is now 2.3 percent higher than it was last quarter. If your brokerage team hasn’t updated your monthly cost forecast to reflect the April 2026 fee schedule, the K84 reconciliation is going to show a variance.

The memo is open for comment until late May

CBSA’s Licensing Unit is accepting comments on the updated D4-1-5 through the end of May 2026. If you operate a sufferance warehouse or if you’re an importer with a recurring sufferance storage problem that you think the memo doesn’t address clearly, send your comment to the licensing mailbox they listed. Most years, the comment period closes with zero submissions. CBSA writes these memos for brokers and warehouse operators, and brokers rarely push back on fee indexing because it’s statutory.

That said, if you think the fourteen-day window should be extended for specific commodity classes (say, goods subject to mandatory CFIA lab testing that routinely takes twelve days), or if you think the penalty-tier rate after day fourteen is disproportionate, the comment period is your window. CBSA does read the submissions, and they do adjust language when the feedback is specific and operational.

If your release cycle routinely pushes past ten days, something upstream is broken

The CPI adjustment is a rounding error. The storage fees themselves are not. If you’re regularly paying for eight, ten, twelve days of sufferance time per container, the problem isn’t the fee schedule—it’s the filing process. Late documentation, unclear HS classification, missing OGD permits, SIMA holds that could have been flagged at the commercial invoice stage—all of those are fixable with better pre-arrival coordination.

We run through these timelines daily for clients who want to cut sufferance time and reduce the cost stack before goods even touch the dock. Run through it with us.

Source: CSCB