Tuesday, November 3, 2026
The news that moves freight
Ocean Nov 3, 2026 · 7 min read

Canada spells out how to report containers sold into the country

Canada draws a line between a container that carries cargo and a container that is cargo

On 30 October the Canada Border Services Agency (CBSA) published Customs Notice 26-25, Cargo Containers Reporting Requirements. The notice is short. Its section on containers imported for sale closes with one sentence every forwarder moving freight into Canada should read: “For all scenarios above, a separate Cargo Control Document (CCD) is required for each container.”

A CCD is the unique control number that links a shipment to its electronic filing under ACI/eManifest. ACI stands for Advance Commercial Information. It is Canada’s system for getting cargo data before the goods arrive. The notice says the reporting exists so CBSA can “conduct pre-arrival risk assessments”.

Our view: the headline reading, that Canada now wants a separate report for every box, misses the point. Most of the notice restates long-standing rules for boxes that come in, unload and leave. The real message sits in one section about containers that stay in Canada and are sold. Here CBSA is drawing a hard line. If the box is being sold, it is goods, not equipment. A forwarder who treats it like equipment is filing the wrong way and can be fined.

What the notice actually says

The notice splits containers into two groups.

The first group is containers used in international commercial transport. These can enter Canada temporarily without duty or tax under tariff items 9801.10.10, 9801.10.20 and 9801.10.30. The condition is that they are only in Canada temporarily and are not sold there. For these boxes the rules are familiar:

  • Marine, loaded: the box is reported in the cargo transmission under Service Option 83.
  • Marine, empty: an empty cargo container transmission is sent under Service Option 695 for each shipment.
  • Highway and rail, loaded: the box is reported in the cargo transmission under Service Option 984.
  • Highway and rail, empty boxes owned by a shipper or importer and registered under an Ottawa file or container bank number: these are reported in the conveyance data with cargo exception code 02.

The second group is “Cargo containers that are, or will be, imported into Canada for sale”. These do not count as containers in international transport. Each must be reported through its own ACI cargo transmission and released or accounted for with duties and taxes. CBSA then sets out the detail:

  • A loaded box needs its own ACI cargo transmission, separate from the shipments inside it. Putting the container number inside the shipment’s cargo transmission “is not an acceptable means of reporting the imported container,” the notice says, adding that penalties may apply.
  • An empty marine box imported for sale is reported as cargo under Service Option 83. An empty-container transmission under Option 695 is not acceptable.
  • On highway and rail, each imported box needs its own cargo transmission under Service Option 984.
  • For consolidated shipments, “the freight forwarder is responsible for transmitting House Bill data” for each individual shipment and for each individual imported container.
  • A closing note: “For all scenarios above, a separate Cargo Control Document (CCD) is required for each container.”

GHY International, a Canadian customs broker, published a summary on 2 November that calls the notice a clarification. On empty marine boxes imported for sale, it backs the Option 83 rule: “An empty cargo container transmission (Service Option 695) does not satisfy this requirement,” it writes. GHY also writes that “Including the container number in the shipment’s cargo transmission does not satisfy” the separate container reporting requirement.

The notice states no effective date. It does not call the rules new. It cites existing memoranda, D3-1-5, D3-3-1, D3-4-2, D3-5-1, D3-6-6 and D22-1-1, as the basis. Our reading is that CBSA thinks these rules already apply and is telling the trade to stop getting them wrong.

Why we think CBSA wrote it now

CBSA has not said why it issued the notice. What follows is our interpretation.

Containers that stay in Canada are a real trade. Buyers use them for storage, site offices, farm buildings and conversions. Many arrive as “one-trip” boxes. These are new containers that carry a load on their first voyage and are then sold to a buyer at destination, rather than returning to a carrier’s pool. Paperwork tends to treat a box like that as equipment, even though it is really a sale.

That creates two problems for a border agency. First, a sold box owes duty and tax, and if it is filed as equipment that money is never collected. Second, CBSA’s risk targeting works on data. A box that appears only as a number inside someone else’s cargo line has no importer, no value and no description of its own. The notice’s stress on “pre-arrival risk assessments” suggests the second problem matters as much as the first.

The line about carriers and forwarders also deserves attention. “Carriers and freight forwarders have an obligation to be aware of the goods they are transporting into Canada,” CBSA writes. In our view, that sentence is there to remove the defence that the forwarder did not know the box was being sold.

What the penalties look like

The notice says “Failure to comply may result in enforcement action or Administrative Monetary Penalty System (AMPS) penalties.” AMPS is CBSA’s civil fine system. The notice does not say which contravention code would apply. Two codes on CBSA’s own schedule cover advance data:

  • C378: “Person failed to submit the prescribed pre-load/pre-arrival information relating to their cargo and/or conveyance.” The penalty is CAD 2,000 for a first contravention, CAD 4,000 for a second and CAD 8,000 for the third and later ones.
  • C379: “Person failed to submit advance information in the prescribed time or prescribed manner to the Agency.” The penalty is CAD 250 for a first occurrence, CAD 375 for a second and CAD 750 for the third and later ones.

Both are issued against “the party responsible for providing the required data”. Under this notice, for house bills, that is the forwarder.

The amounts are per breach. A consolidation carrying several sold boxes, filed the wrong way week after week, could reach the higher tiers quickly. That is our inference, not a CBSA figure.

What happened last time

Canadian forwarders have been here before. The house bill obligation under eManifest was phased in. Livingston International, writing on 31 May 2021, said the zero-rated penalty period for electronic house bills “will end July 4th, 2021”. It added: “As of July 5th, 2021, ACI related AMPS may be issued to freight forwarders when non-compliance is detected.”

That was a new duty, so CBSA phased it in with a period of penalties set at zero. Notice 26-25 is different. It describes no transition, gives no start date and presents itself as clarifying rules that already exist. In our view, that framing points to enforcement first and leniency only if the trade pushes back hard.

What forwarders should check this week

Our suggestions for forwarders and NVOCCs (non-vessel operating common carriers, which issue their own bills of lading) moving consolidated freight into Canada:

  • Find the sold boxes. Ask origin agents and shippers which containers are one-trip or sold units. If the consignee keeps the box, it is goods.
  • Fix the house bill template. Each sold container needs its own house bill data and its own CCD, separate from the cargo inside it. A container number in a cargo line is not enough.
  • Check the empty-box option. For empty marine boxes sold into Canada, the notice says the filing goes under Service Option 83, not 695. Make sure your software does not default to 695 for every empty.
  • Line up the duty side. A sold box owes duty and tax and must be released or accounted for. Make sure a customs broker is engaged on the box as well as on the freight.
  • Brief the trucking side. On highway and rail the option for a sold box is 984, with its own transmission. The cargo exception code 02 shortcut applies only to registered, shipper- or importer-owned empties in international transport, not to boxes being sold.

For shippers and buyers, the practical effect is more paperwork and possibly a separate customs entry for the box itself. Expect some forwarders to price that in. On lanes where one-trip boxes are common, such as Asia to Canadian inland points, we expect quotes to start asking whether the box is being sold.

Our prediction

Our call: CBSA will not announce a grace period, phase-in or zero-rated penalty period for container-for-sale reporting before 31 December 2026. We also expect at least one major Canadian broker or eManifest software provider, beyond GHY, to publish filing guidance on Notice 26-25 within six weeks, by mid-December. That would be the first sign the trade is treating this as an operational change, not background reading.

If CBSA does announce leniency before year end, that would tell us the trade’s systems were further behind than the notice assumed. We would revisit the call then.

Sources

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