D4-1-5 Updated: CBSA Storage Rules and What Changes for Sufferance Warehouses

What Changed in D4-1-5

CBSA revised D4-1-5 (Storage of Goods) on May 21. The memorandum covers procedures for storing commercial goods that haven’t cleared customs yet, or goods CBSA has seized and is holding pending disposal. If you run a sufferance warehouse or bond your clients’ cargo through one, this matters.

The headline change: tighter wording around place of safe-keeping definitions and clearer timelines for when CBSA transfers storage liability to the warehouse operator after goods are abandoned or forfeited. The old version left enough ambiguity that some operators were surprised when CBSA billed them for storage after an importer ghosted a seizure notice. The new language closes that gap.

Most of the rest is administrative cleanup—updated CARM references, replaced “B3” with CAD filing language, clarified that payment obligations run through the CARM Client Portal and tie to your RPP bond if you’re operating release prior to payment. Nothing that changes your day-to-day filing workflow, but worth a skim if you haven’t looked at D4-1-5 since 2019.

Place of Safe-Keeping: The Part That Matters

A place of safe-keeping is any location CBSA approves for temporary storage of goods that haven’t been released yet. That includes sufferance warehouses, but also bonded facilities, customs-controlled areas at ports and rail terminals, and occasionally a carrier’s yard if CBSA grants a short-term hold.

The revision clarifies two things:

1. Warehouse operator liability starts the moment CBSA issues a notice of abandonment, not when the statutory disposal period expires. If an importer doesn’t respond to a seizure or missing-docs notice within 30 days, and CBSA posts abandonment, the warehouse is on the hook for storage fees from that date forward—even if the goods sit another 60 days waiting for Crown disposal.

2. CBSA can designate a place of safe-keeping on a per-shipment basis, not just through a blanket facility license. We’ve seen this used at Montreal and Vancouver when a container arrives with refrigerated pharma or controlled food products and the original sufferance facility can’t meet CFIA temperature-log requirements. CBSA moves it to a compliant cold-storage site, calls that the place of safe-keeping for that shipment, and the fees follow. The updated D-memo makes that explicit.

If you’re filing CADs on behalf of clients who use third-party warehousing, check that your warehouse has a current sufferance license and that your client’s name is on the CBSA-approved importer list for that facility. CARM won’t block the CAD if it’s missing, but you’ll eat a delay when the warehouse refuses release because the importer isn’t pre-registered in their system.

Timelines and Fees

Goods that sit in CBSA storage without clearance trigger fees after the first 40 days (general goods) or 20 days (perishables, live animals, certain CFIA-controlled categories). The fee schedule hasn’t changed, but the revised D-memo now references the CBSA fees page directly instead of listing rates in the text, which means future adjustments won’t require a new D-memo publication.

Practical consequence: if your client’s shipment is flagged for exam and they’re slow to provide commercial invoice corrections or a CFIA import permit, and the container sits at the warehouse past 40 days, CBSA bills storage daily until resolution. Those fees are separate from the warehouse’s own dwell charges. You’re paying both.

We routinely see this happen when an NRI (non-resident importer) files a CAD but forgets to register for a GST account and Business Number with CRA first. CBSA holds the release, the importer scrambles to get the BN15, and by the time everything clears, the shipment has been sitting 50 days. CBSA storage fees plus warehouse detention often exceed the duty bill.

If you’re working NRI accounts and you’re not walking them through SIN/BN registration before the first shipment, you’re setting up a costly hold. We cover the registration steps in our compliance service, but the short version: importer needs a CRA Business Number, GST account if revenue thresholds apply, and a CARM Client Portal account with financial security posted before the first CAD is filed.

Warehouse Types and What You Actually Use

D4-1-5 defines three warehouse categories:

• Sufferance warehouse: commercial goods awaiting release, operator licensed by CBSA, no duty deferral.
• Bonded warehouse: goods stored duty-unpaid under a bond, importer pays duty on withdrawal, not arrival. Rarely used since CARM’s RPP bond structure makes duty deferral less painful on the cash-flow side.
• Duty-free shop: consumer retail, irrelevant for commercial imports.

Most of our clients use sufferance. Bonded warehousing still makes sense if you’re importing high-duty goods (certain steel, SIMA subject goods with AD/CVD margins above 50%, some apparel under peak tariff lines) and you want to defer duty until you move product to customers. But CARM’s release-prior-to-payment model already gives you that deferral on a monthly settlement cycle if your RPP bond is sized correctly, so bonded warehousing is now a niche play.

If you run volume through Montreal and you need a facility that can handle both CBSA sufferance and CFIA cold-chain inspections, take a look at our partner FENGYE’s Montreal sufferance warehouse. Licensed, temperature-controlled zones, eManifest and ACI integration, and they’ll coordinate exam appointments with CBSA’s Dorval office without you needing to chase the cargo control number yourself.

What to Do If CBSA Moves Your Shipment

Occasionally CBSA will relocate a container from your chosen warehouse to a different place of safe-keeping—usually because the original facility can’t meet OGD requirements (CFIA, Health Canada, ECCC if it’s chemicals or wood packaging flagged for treatment verification). The revised D-memo clarifies that CBSA must notify the importer and the broker of record within 24 hours of the move, and the new location becomes the official place of safe-keeping for release purposes.

Your CAD filing doesn’t change—you still reference the original sufferance warehouse code in the declaration—but your client needs to arrange pickup from the new address. If CBSA moves a container to a facility farther from your client’s distribution center, the drayage cost jumps, and someone’s eating that difference. The importer of record is on the hook unless your brokerage agreement explicitly assigns freight-variance risk elsewhere.

We’ve seen this twice in the past six months with refrigerated seafood shipments arriving at Montreal. Original warehouse’s reefer monitoring didn’t meet CFIA’s new 2025 data-logger requirements, CBSA moved both containers to a compliant facility in Lachine, drayage cost doubled, and the importer tried to bill us for the difference because “you chose the warehouse.” We didn’t. The importer’s purchase order specified the original facility, and our engagement letter puts freight-routing risk on the client unless we’re booking the freight leg ourselves.

Document who picks the warehouse. If your client insists on a specific facility and CBSA moves it, that’s their cost.

Filing and Financial Security Under CARM

The updated D-memo references CARM financial security requirements and the K84 monthly statement process. If you’re filing CADs under release prior to payment, your RPP bond has to cover the highest single-day duty and GST liability in the monthly cycle, plus a 10% CBSA margin. D4-1-5 doesn’t change that math, but it does clarify that storage fees owed to CBSA (not the warehouse) count toward the monthly accounting and settle through the same portal.

If your client’s RPP bond is sized for typical duty but they suddenly have a container held 60 days with CBSA storage fees, and that pushes the month’s total liability above the bond limit, CBSA will flip the account to payment-on-release for subsequent shipments until the shortfall is cleared. You lose RPP privileges, your release times go from same-day to two-business-day holds, and your client’s inbound schedule falls apart.

We run bond-sizing reviews every quarter for active accounts. If your last K84 statement showed a peak-day liability within 15% of your bond ceiling, that’s a flag to increase coverage before a storage-fee surprise puts you over. Get in touch.

Source: CSCB