Quick answer: Do not pull an import container out of a marine terminal, rail ramp or sufferance warehouse until the Canada Border Services Agency (CBSA) has released the goods, unless your company is a bonded carrier authorized to move them, still unreleased, to another customs office or sufferance warehouse. Before dispatch, confirm the release against the shipment's cargo control number, check for any CBSA hold, and if the move is in bond, make sure the permission, security, seal and paperwork are in place.
Customs release is the first of three releases a container needs before pickup. The other two, the shipping line's release and the terminal's own clearance, are covered in our guide to container drayage in Canada. This article goes deeper on the customs part, because that is the one with legal consequences for the trucker.
What CBSA release means in law
The Customs Act defines release, for goods, as authorizing their removal from a customs office, sufferance warehouse, bonded warehouse or duty free shop for use in Canada. Section 31 then sets the rule: no goods shall be removed from any of those places by anyone other than an officer on duty, unless the goods have been released by an officer or by prescribed means.
Release depends on the importer, not the trucker. Section 32 says goods are not released until they have been accounted for by the importer or owner in the prescribed manner and the duties have been paid, subject to exceptions such as release before accounting under prescribed conditions. In practice the importer's customs broker handles this and receives the release decision.
So the drayage dispatcher's role is narrow but important: confirm that release has been granted for the right shipment before the truck goes, and never treat a customer's assurance that "customs is done" as a substitute for the release itself.
Cargo control numbers and release notifications
Every imported shipment is reported to CBSA under a cargo control number (CCN). CBSA Memorandum D3-1-1 describes the CCN as the carrier code followed by a unique reference number assigned by the carrier or its representative, with no spaces, where the first four alphanumeric characters are the CBSA-approved carrier code.
The same memorandum describes the Release Notification System (RNS): a system message sent to a client about the status of a release. It also warns about the most common failure. If the CCN quoted in a release request does not exactly match the cargo data the carrier transmitted, RNS subscribers will not receive release messages, and the shipment may not be released at all.
For a container that arrived by ship, the CCN on the release belongs to the marine carrier's cargo report or a forwarder's house bill, not to the drayage company. The dispatcher's job is to make sure the release the customer's broker forwards quotes the same CCN as the container you are about to collect. If you also haul Canada-bound loads across the land border, our article on PARS numbers explains how highway carriers build their own CCNs.
Holds at the terminal
Release can be reversed or delayed while goods are still in a terminal's hands. CBSA Memorandum D3-5-1, on marine reporting, notes that a hold message may still be issued for goods as long as they remain within the terminal's control, and that carriers are responsible for checking their systems for coded messages such as Hold, Do Not Load and Do Not Unload. A container selected for examination will not be available until CBSA finishes with it.
Practical rule: check the container's status with the terminal or railway on the day of pickup, not only the day the release arrived.
Where the container is destined: sub-location codes
Marine cargo reports carry a sub-location code, a four-digit number that identifies where the goods are going, such as a specific sufferance warehouse. D3-5-1 explains that when goods are not destined to a sufferance warehouse, a generic 9000 code may be used in some cases.
The memorandum also covers the situation drayage carriers meet most often with inland moves. When the first port of arrival differs from the port of destination, so the goods move in bond, and there is a suitable warehouse or terminal with a CBSA-issued sub-location code at the destination, the cargo report must show that code. The sufferance warehouse then sends a Warehouse Arrival Certification Message to arrive the goods electronically. D3-5-1 also notes that the importer or its broker may instead seek release at the first port of arrival, avoiding manual CBSA intervention inland.
For a dispatcher, the takeaway is simple: know whether the container is released at the port or is travelling in bond to an inland warehouse, because the paperwork and the permitted destination are different.
Moving unreleased goods inland: the in-bond move
The Customs Act allows unreleased goods to move only in specific ways. Section 19 lets a person authorized by an officer, or by prescribed means, deliver reported goods from a customs office to another customs office or a sufferance warehouse, and from one sufferance warehouse to another. Section 20 says anyone transporting imported goods that have not been released within Canada does so under prescribed conditions and bonds or other security, and makes the transporter liable for the duties unless it proves, within the prescribed time, that the goods were destroyed in transit, received in a customs office, sufferance warehouse, bonded warehouse or duty free shop, or met one of the other outcomes the section lists.
The Transportation of Goods Regulations fill in the conditions. Under section 3, no one may transport unreleased imported goods within Canada unless they have:
- applied for and received permission to transport the goods from the chief officer of customs for the area, or from the President of CBSA for regular movements;
- deposited the security required by section 6;
- presented a description of the goods in the prescribed form to an officer; and
- sealed the conveyance or container with a seal issued or approved by CBSA, unless the container cannot be sealed, the goods are live animals, or an officer has authorized an unsealed move.
The same section requires the carrier to notify the consignee of the goods' arrival. Section 4 requires the carrier to report an accident or other unforeseen event that breaks a seal or disables the container or vehicle, and limits transfers of the goods to another container. Section 5 gives the carrier 70 days to prove the goods arrived, counted from the day they were reported or required to be reported. Section 7 requires the carrier to keep the invoices, bills and statements for the move, along with the description of the goods.
CBSA Memorandum D3-1-1 adds that only bonded carriers or freight forwarders that have filed security with CBSA may transport in-bond goods between points within Canada. The US system works differently; for loads entering the United States, see our in-bond shipment guide.
Sufferance warehouses and their time limits
A sufferance warehouse is a place licensed under the Customs Sufferance Warehouses Regulations to hold goods that have not been released. CBSA Memorandum D4-1-4 describes several types; Type A warehouses include those operated by marine and railway companies and those at a marine wharf run by a harbour commission, stevedoring company or similar operator for unloading and storing imported, unreleased cargo.
Two rules matter to drayage carriers. Under section 14 of the regulations, the licensee must acknowledge receipt of goods in the warehouse electronically. Under section 15, goods not removed within 40 days after the day they were reported may be moved to a place of safe-keeping; perishable goods have a 4 day limit, and some classes, including firearms, tobacco and vaping products and spirits, become forfeit after shorter periods. A container that sits waiting for a release does not wait forever.
A dispatcher's customs checklist
| Before pickup | Why it matters |
|---|---|
| Release received, with the CCN matching the container's cargo report | A mismatched CCN can block release messages and the release itself |
| No CBSA hold or examination on the container today | A hold can be issued while goods remain in the terminal's control |
| If moving in bond: permission, security and a carrier code on file | Only bonded carriers may move unreleased goods within Canada |
| If moving in bond: CBSA seal recorded, destination warehouse confirmed | The goods must reach a customs office or sufferance warehouse, sealed unless exempted |
| Copies of the documents kept for the move | The Transportation of Goods Regulations require records |
How TruckerPro supports customs readiness
In TruckerPro's Intermodal & Drayage workspace, available on the Elite plan and up once switched on in company Settings, customs release is one of five readiness checks staff record on each container, together with shipping-line release, terminal release, terminal access and equipment inspection. Each check is set to Not verified, Verified clear, On hold or Not required, and pickup, pre-pull, export delivery and street-turn moves stay blocked until the checks clear. The container job also records the seal, and every change is logged on the container. TruckerPro does not receive CBSA release messages: there are no live terminal, port, rail or shipping-line feeds, so your team confirms release with the customs broker and records it.
Frequently asked questions
Can a drayage carrier move a container that CBSA has not released?
Only as an in-bond move. The Customs Act lets a person authorized by an officer, or by prescribed means, deliver reported goods to another customs office or a sufferance warehouse before release. The Transportation of Goods Regulations require permission, security, a description of the goods and, in most cases, a CBSA-issued or approved seal. CBSA guidance says only bonded carriers or freight forwarders that have filed security may transport in-bond goods within Canada.
What is a cargo control number on an import container?
It is the number that identifies a shipment in CBSA's systems. CBSA describes it as the carrier code, whose first four characters are the CBSA-approved carrier code, followed by a unique reference number assigned by the carrier, with no spaces. The release request and the cargo data must quote exactly the same number.
How long can an unreleased container sit in a sufferance warehouse?
Under the Customs Sufferance Warehouses Regulations, goods not removed within 40 days after they were reported may be moved to a place of safe-keeping. Perishable goods have a 4 day limit, and some classes such as firearms, tobacco, vaping products and spirits have shorter limits after which they are forfeit.
Who arranges CBSA release, the trucker or the customs broker?
The importer, usually through its customs broker, accounts for the goods and requests release. The carrier's job is to report the cargo accurately, quote the correct cargo control number, and not move unreleased goods except as an authorized in-bond move. A dispatcher's job is to confirm release before sending a truck.
Sources
- Customs Act, R.S.C. 1985, c. 1 (2nd Supp.), sections 2, 19, 20, 31 and 32 (Justice Laws)
- Transportation of Goods Regulations, SOR/86-1064 (Justice Laws)
- Customs Sufferance Warehouses Regulations, SOR/86-1065 (Justice Laws)
- CBSA Memorandum D3-1-1, Policy Respecting the Importation and Transportation of Goods
- CBSA Memorandum D3-5-1, Marine Pre-load/Pre-arrival and Reporting Requirements
- CBSA Memorandum D4-1-4, Customs Sufferance Warehouses
- CBSA: Cargo and warehouse business requirements