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Private Printing of CBSA Forms: Understanding Memorandum D17-1-11

  • Customs Law
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International trade depends heavily on accurate documentation. In Canada, the Canada Border Services Agency (CBSA) requires a number of official forms for customs accounting, adjustments, and export declarations.

To improve efficiency for importers, customs brokers, and logistics companies that handle large volumes of transactions, CBSA permits private printing of certain customs forms.

The rules governing this practice are explained in CBSA Memorandum D17-1-11 – Private Printing Policy and Procedures.

This article explains the purpose of the memorandum, the approval requirements, and the key compliance points every importer and customs broker should understand.


Purpose of Memorandum D17-1-11

The main purpose of Memorandum D17-1-11 is to regulate how businesses may privately print customs documentation that is normally issued in official format by the CBSA.

Many companies process thousands of customs entries every month. Purchasing pre-printed forms or manually preparing documents may slow operations. Therefore, CBSA allows companies to generate these forms directly through their own computer systems, accounting software, or printing systems.

However, because these documents form the legal basis for duty assessment, tax collection, and customs verification, CBSA requires strict control over their format and accuracy.

The memorandum therefore establishes a policy ensuring that privately printed forms remain identical to the official CBSA format and compatible with CBSA processing systems.


Forms That May Require Approval for Private Printing

Certain official customs forms may be printed privately, but prior CBSA approval is required before doing so.

Examples include:

  • B3 – Canada Customs Coding Form (now called Canada Accounting Document)
  • B2 – Adjustment Request
  • B13A – Export Declaration
  • E29B – Temporary Admission Permit

Because these documents directly affect customs accounting and duty assessment, CBSA must ensure the printed format matches the official layout exactly.


Format Requirements for Privately Printed Forms

Privately printed customs forms must strictly follow the official CBSA design. The following requirements generally apply:

  • The size and layout must match the official form
  • Data fields must appear in the same position
  • The document must be printed in clear black ink on white paper
  • All barcodes must be readable by CBSA scanning systems

Even small variations in spacing, field placement, or barcode quality may cause the form to be rejected.

These requirements protect the integrity of CBSA’s electronic processing and audit systems.


How to Obtain CBSA Approval

Before privately printing certain customs forms, businesses must request approval from the CBSA Forms Management Unit.

The approval process generally involves:

  1. Submitting a written request
  2. Providing two sample copies of the printed form
  3. Allowing CBSA to review the layout and barcode quality

If the form meets CBSA specifications, the agency issues an approval number.

This approval number must be printed on the form itself, usually in the lower corner, indicating that the format has been officially authorized.


Barcode Testing Requirements

Many customs documents include transaction numbers or cargo control numbers encoded in barcodes.

When privately printed forms contain barcodes, CBSA may require barcode readability testing to ensure that the codes can be scanned accurately by CBSA systems.

This step is critical because barcode errors could prevent CBSA from properly recording customs transactions.


Documents That Do Not Require CBSA Printing Approval

Commercial Invoices

CBSA does not review or approve commercial invoices, including the Canada Customs Invoice or invoices issued by exporters.

These documents are prepared by the exporter or importer and are used by CBSA to determine:

  • Value for duty
  • Tariff classification
  • Country of origin

Responsibility for their accuracy rests with the trading parties, not CBSA.

Cargo Control Documents

Certain cargo documents used by carriers also do not require prior approval for private printing.

Examples include:

  • Cargo Control Documents (CCD)
  • Carrier manifests
  • House bills

However, if these documents contain barcodes, the barcode format must still comply with CBSA technical requirements.


Validity of Approval

CBSA approvals for privately printed forms do not automatically expire.

However, if a company intends to reprint forms or modify the printing format, CBSA recommends submitting the form again for review to ensure continued compliance.

This ensures that any technological or format changes remain compatible with CBSA systems.


Why This Policy Is Important

The policy balances two important goals:

  • It allows businesses to operate efficiently by generating customs documents directly from their internal systems
  • It protects the integrity of Canada’s customs administration by ensuring standardization

In other words, the policy promotes efficiency without compromising compliance.


Practical Importance for Importers and Customs Brokers

For customs brokers, freight forwarders, and high-volume importers, understanding this memorandum is important because privately printed forms are commonly used in modern electronic customs environments.

Failure to follow CBSA printing standards may result in:

  • Rejected documents
  • Processing delays
  • Compliance concerns during audits

Therefore, companies should ensure that their software systems generate customs forms that comply fully with CBSA requirements.


Conclusion

CBSA Memorandum D17-1-11 provides the framework for private printing of customs forms in Canada.

While businesses are permitted to generate many customs documents themselves, certain forms require prior CBSA approval, and all printed documents must meet strict format and barcode standards.

Understanding these requirements helps importers and customs brokers maintain efficient operations while ensuring full compliance with Canadian customs regulations.


Disclaimer

This article is intended for educational and informational purposes only. It summarizes CBSA administrative guidance and should not be considered legal advice.

Importers and customs brokers should consult the official CBSA memoranda or seek advice from a licensed customs professional, barrister, or solicitor for specific compliance matters.