CBSA clarifies container reporting: a container imported for sale needs its own cargo transmission and its own CCD
Customs Notice 26-25, dated Oct. 30, separates containers in international commercial transportation from containers being sold into Canada. The second group gets stricter reporting, and penalties may apply.
The Canada Border Services Agency (CBSA) issued Customs Notice 26-25, "Cargo Containers Reporting Requirements," on Oct. 30, 2026. It explains how all containers, whether full, empty or part of a consolidated shipment, must be reported under the Advance Commercial Information (ACI) / eManifest program so the CBSA can run pre-arrival risk assessments. The notice also lists some exceptions and exemptions.
Two categories of container
1. Containers in international commercial transportation. These are cargo containers that are in Canada only temporarily and have not been, and will not be, sold in Canada. Under tariff items 9801.10.10, 9801.10.20 and 9801.10.30 (see Memorandum D3-1-5), such containers can be imported temporarily without duties or taxes. Their data goes to the CBSA through a cargo or empty-container ACI transmission.
2. Containers imported for sale. A container that is, or will be, imported into Canada for sale is not a container in international commercial transportation. It must be reported through its own ACI cargo transmission and released or accounted for with duties and taxes.
Highway and rail: what the notice says
| Situation | What to transmit | |---|---| | Container in international commercial transportation, carrying cargo | Container number goes in the ACI cargo transmission (Service Option 984) of each shipment | | Container registered under an Ottawa file or a container-bank number (shipper- or importer-owned empty containers used to carry goods, such as tanks, pallets, crates, totes or racks) | Report cargo exception code 02 on the conveyance data | | Imported-for-sale container carrying cargo | An ACI cargo transmission for each shipment inside the container, plus an ACI cargo transmission for each shipment of the container itself | | Imported-for-sale container, empty (highway and rail) | An ACI cargo transmission (Service Option 984) for each shipment of the imported container itself |
For marine, the notice says an empty imported-for-sale container needs ACI cargo data (Service Option 83) for the container itself. Sending the empty-container transmission (Service Option 695) is not acceptable.
Reporting rule to watch
For imported-for-sale containers, the notice says that putting the container numbers inside the shipment's cargo transmission is not an acceptable way to report the container itself, and penalties may apply. If the shipment is consolidated, the freight forwarder must transmit House Bill data for each individual shipment and for each individual imported container.
The notice adds one line that applies to all of these scenarios: a separate Cargo Control Document (CCD) is required for each container.
What carriers and forwarders should do
- Ask the broker or shipper which category the container falls into before the load is dispatched: a returning or temporary container, or a container being sold into Canada.
- Make sure the filing has one CCD per container.
- Remember the legal duty: the notice says carriers and freight forwarders must be aware of the goods they transport into Canada, and failure to comply may lead to enforcement action or Administrative Monetary Penalty System (AMPS) penalties.
Where to read more
The notice points to CBSA Memoranda D3-3-1 (freight forwarder pre-arrival and reporting), D3-4-2 (highway pre-arrival and reporting), D3-5-1 (marine), D3-6-6 (rail) and D22-1-1 (AMPS). Questions can go to the CBSA Border Information Service at 1-800-461-9999 inside Canada and the United States.