Customs Notice 26-25, dated 30 October 2026, splits CBSA container reporting in two. A loaded box that stays in international service is reported by its number inside each shipment’s cargo filing. A box imported for sale gets a filing of its own: the notice rejects listing its number inside the cargo filing, in marine, and warns that penalties may apply. For a forwarder booking a container into Canada, the first question is whether the steel box will leave again or be sold.
A communique ahead of the notice
The notice had a precursor. UUCargo reproduced a CBSA communique (the page’s URL carries the date 7 October): a policy clarification on how full, empty and consolidated containers are reported under ACI in the highway, marine and rail modes.
The communique warned both parties: the Agency, it said, is authorized to impose administrative monetary penalties and “take any enforcement measures against the carrier and/or freight forwarder for the non-reporting of cargo containers.” It also said that a customs notice would follow and that four D-memoranda, covering freight forwarders, highway, marine and rail, would be updated to match.
30 October: what the notice changed
Among other edits, the communique told highway and rail filers to report the exception code for shipper- or importer-owned empty containers as ITT02, and the notice gives it as 02, the form GHY International also uses. The enforcement language got shorter. Where the communique named carriers and forwarders and listed sanctions, the notice says only this:
“Failure to comply may result in enforcement action or Administrative Monetary Penalty System (AMPS) penalties.”
The notice keeps the split that organises CBSA container reporting: two kinds of box. Containers used in international commercial transportation, in Canada temporarily and never sold there, come in without duties under tariff items 9801.10.10, 9801.10.20 and 9801.10.30. In marine, a loaded one is reported by its number inside each shipment’s cargo transmission (Service Option 83), and an empty one needs its own empty container transmission (Service Option 695). In highway and rail, the number goes inside the cargo transmission of each shipment (Service Option 984).
Containers that “are, or will be, imported into Canada for sale” are outside that provision and are released and accounted for with duties and taxes. For a loaded box in that group, CBSA wants a cargo transmission for each shipment inside it and a further one for the container itself. An empty box for sale in marine goes under Service Option 83, and the empty-container option 695 that works for a box in international service is rejected here. The container number is also what Navo’s container tracking API takes in, and its page is built around live ETAs. On a consolidated load the forwarder sends House Bill data for each shipment and for each container.
One CCD per container, and what it costs
The notice’s list of reporting scenarios ends on one line: for all scenarios, a separate Cargo Control Document for each container.
CBSA’s own D3-1-5 memorandum defines a CCD as the control document that records a shipment entering, exiting or moving within Canada, so the container becomes a record of its own next to the cargo records inside it. The notice sends readers to five memoranda for the detail: D3-3-1 for freight forwarders, D3-4-2 for highway, D3-5-1 for marine, D3-6-6 for rail, and D22-1-1 for the penalty system. GHY International, a trade compliance firm, boiled the notice down to the same points: the right ACI transmission for each mode, separate transmissions for boxes imported for sale, and a CCD for every container.
Forwarder News flagged the notice in its 3 November brief and put CBSA’s penalties for advance-data breaches at CAD 250 to CAD 8,000 each. The notice itself names no figure or contravention. CBSA’s penalty sheet for C379, advance information sent outside the prescribed time or manner, runs $250, $375 and $750 for the first, second and third and later instance. Its sheet for C378, pre-arrival information not submitted before arrival, runs $2,000, $4,000 and $8,000 per instance, matching Forwarder News’s CAD 8,000 ceiling, though that brief does not name its source. The same sheet caps the total at $12,000, $24,000 and $48,000 where five or more pre-arrival cargo reports and their conveyance reports go untransmitted. The notice does not say which contravention applies to a container filed inside the cargo transmission.
The notice gives no start date. Trade With World, which summarised it on 30 October, says it explains rules that already apply under ACI/eManifest.