The CAD field by field: which Commercial Accounting Declaration fields change the duty?

What is a CAD and why does each field matter after accounting?

The Commercial Accounting Declaration is how commercial goods are accounted for in Canada. CBSA Memorandum D17-1-10 calls it "a customs document (formerly known as B3) used to account for imported goods, regardless of value". It is filed through the CARM Client Portal, EDI or API, and for electronic CADs the CBSA system calculates the duties and taxes, except on type F CADs, where the filer calculates them.

When a CAD is accepted, CARM produces Form BSF863 (for a type C CAD) or BSF864 (for every other type). D17-1-10 says these forms "serve as the official invoice" and that "all corrections, audits, and appeals are based on the data submitted on this document". After the payment due date the CAD is final; any later change is an adjustment and a new version of the same CAD, under Memorandum D17-2-1.

A note on numbers before the walk-through. D17-1-10 says its CAD fields are "numbered for reference purposes only" and mirror the electronic submission. The numbers on this page are those of Appendix A, which runs from 1 to 117 (99 to 117 are declaration totals and the signed declaration). The paper exception CAD (BSF946) in Appendix J numbers its fields differently, and the portal and EDI use field names. Quote the name with the number when you raise a finding.

Which header fields identify the CAD?

D17-1-10 lists the declaration types:

Under Memorandum D17-1-5, a type AB CAD must be accepted within 5 business days of release, and a CAD 100 late accounting penalty applies automatically when it is not.

Which line fields set the classification and the value?

Each commodity line starts with what the goods are and what they cost:

Field 48 is the one auditors read quickly and filers fill in slowly. The first digit is 1 if vendor and purchaser are not related under subsection 45(3) of the Customs Act, and 2 if they are. The second digit is the method: 3 price paid or payable without adjustments, 4 with adjustments (both section 48), 5 identical goods (49), 6 similar goods (50), 7 deductive (51), 8 computed (52), 9 residual (53). A code of 13 on a line bought from a parent company is an audit finding by itself. What belongs in the value is set out in value for duty in Canada.

Which fields decide origin and the rate of duty?

D17-1-10 Appendix H lists the tariff treatment codes. The ones seen most on audits:

D17-1-10 says codes 010, 011, 014 and 021 may be used only when the importer or broker declares that the goods originate and that a valid certificate of origin is in their possession, and that deliberate misuse "may result in enforcement action". A preferential code with no certification on file, or an MFN code on goods that had one, is where the four-year refund and correction windows open. Those claims are covered in unclaimed preference on past Canadian entries.

Where do relief, remission and permits go?

Three special authority fields record why a line pays less than the tariff says, and each one is a claim that needs evidence:

• Field 53, Special Authority Duties Relief Licence. A Duties Relief Program licence number, on every line it covers.
• Field 54, Special Authority OIC. The order in council giving relief or remission. D17-1-10 says to quote the original order number even if it was amended, on every line it applies to, and to be ready to prove the conditions. For the United States Surtax Remission Order (2025), Customs Notice 25-19 says the special authorization code goes here and "surtax must be declared in addition to the applicable remission".
• Field 55, Special authority permit. A tariff rate quota permit, a General Import Permit or a Kimberley Process permit.

Field 104, Declaration Total Relieved, totals what these fields removed. Field 105, Total Amount, shows the duties, taxes and SIMA amounts before remission and relief. A large gap between them is worth checking line by line.

Where do surtax, SIMA and safeguard show up?

Two checks follow from this layout. A line with field 66 set must have a code in field 67 that matches its country of origin, tariff item and date, and a line from a covered country with field 66 empty may be missing a surtax. The orders and their codes are in why your CAD shows the wrong surtax.

How are value for tax and GST built?

Field 91, Value for Tax, is the base for GST. D17-1-10 says to add the value for duty, customs duties, excise duties, SIMA assessment and excise tax. Section 215 of the Excise Tax Act sets the legal rule: the value for duty plus all duties and taxes payable under the Customs Tariff, the Excise Act, 2001, the Special Import Measures Act and other customs laws. Surtaxes are imposed by orders under the Customs Tariff, so they are in the base too. Field 92, GST code, sets the status or exemption, and field 93 is the GST.

This is why a duty or surtax error is also a GST error. Change field 61 or field 68 and field 93 moves with it.

What does one CAD line look like, field by field?

A line from a US supplier, invoiced in US dollars, under a 25% surtax. The tariff item, rate, exchange rate and surtax order are illustrative. Check the real ones for your goods and date in the duty calculator.

The line owes CAD 5,254.35. Now suppose the importer had a CUSMA certification of origin for these goods on file at accounting. Field 46 becomes 010, and if the tariff item is free under the United States Tariff, field 61 drops to zero. Whether field 68 also drops depends on the surtax order, not on CUSMA: an order can apply to originating goods. Value for tax falls to CAD 17,250.00 and GST to CAD 862.50. One field changed and three amounts moved, which is why an audit reads the fields together rather than one column at a time.

How does the CAD line up with the old B3?

If your records cross October 21, 2024, you will compare B3s and CADs. The concepts carried over; the numbering did not. D17-1-10 notes that many CBSA documents still call the CAD a B3.

B3s accounted for before October 21, 2024 are adjusted by first creating a pre-CARM "as declared" CAD, which is covered in CARM mass adjustments and pre-CARM B3s.

How does this compare with Form 7501?

The two forms answer the same questions in different places. The 7501's line columns 33 to 38 hold what CAD fields 34 to 61 hold, origin sits in a header block on the 7501 but on each CAD line, and Canada adds value for tax and GST to every line, which the US entry summary does not carry. The US walk-through is Form 7501 field by field. If you import into both countries, the same invoice should produce consistent origin and value on both, and a mismatch is worth explaining before either customs administration asks.

How do you check a CAD field by field?

1. Pull the CADs from the portal, with versions, not the broker's working copies.
2. Tie each line to the invoice: fields 24 or 27, 37, 39 and 40 against the commercial invoice.
3. Test the value: field 41 against the rate for the field 31 date, field 48 against the relationship and any additions to the price.
4. Test the rate: field 34 against the goods, field 46 against the origin evidence you held at accounting.
5. Test each special authority: fields 53 to 55 against the licence, order or permit and its conditions.
6. Test the surtax and SIMA fields against the orders and measures in force on the date.
7. Recompute fields 91 and 93 after any change.

TariffSense reads CAD lines from the portal export or your broker's accounting export, checks each of these fields against the tariff measures in force on the line's date, and flags the line with the field, the direction and the corrected amount. The CAD audit guide covers the checks in depth, the reason code for each fix is in CARM adjustment reason codes, and the post-entry audit page shows what goes in and what comes back.