Canada Customs Invoice Requirements: CI1 Form Guide for AP Teams

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Updated
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22 min
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David
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Tax & ComplianceCanadacustoms invoicingcross-border tradeCUSMA
Canada Customs Invoice Requirements: CI1 Form Guide for AP Teams

Article Summary

Canada customs invoice requirements guide: CI1 form fields, $2,500 threshold, CUSMA documentation, and GST/HST import rules for AP teams.

The Canada Border Services Agency (CBSA) requires a customs invoice for all commercial goods imported into Canada. When the declared value of a shipment exceeds $2,500 CAD, importers must submit the official Canada Customs Invoice form CI1. For shipments valued at or below that threshold, a standard commercial invoice is accepted, provided it contains every mandatory field the CBSA specifies.

This guide covers the full scope of Canada customs invoice requirements that AP and finance teams encounter during cross-border trade:

  • When the CI1 form is required versus when a commercial invoice suffices
  • Mandatory fields on the CI1 and how to complete each one accurately
  • CUSMA certificate of origin and supporting tariff documentation
  • How customs invoice values determine import GST/HST calculations
  • Managing customs invoice data in AP workflows for duty reconciliation and tax compliance

Rather than treating customs invoicing as a pure regulatory topic, this guide approaches it from the AP and financial document processing perspective. Each section connects CBSA requirements to the practical workflows your team uses for duty reconciliation, cost allocation, and ongoing compliance, so the documentation that clears your goods at the border also feeds accurate data into your financial systems.


When Is the CI1 Form Required

CBSA Memorandum D1-4-1 is the authoritative regulation governing customs invoice requirements for goods imported into Canada. It defines who must provide a customs invoice, what information each invoice must contain, and the documentation standards the Canada Border Services Agency (CBSA) expects from importers and their suppliers.

A critical detail that the threshold rule alone does not convey: the $2,500 CAD threshold applies to the transaction value of goods per individual shipment, not to aggregate annual import volume. A company importing $50 million in goods annually still uses commercial invoices for any single shipment valued at or below $2,500 CAD. Conversely, a single shipment at $2,501 CAD requires the full CI1 form regardless of how infrequently the company imports.

Getting the form selection wrong creates measurable downstream problems. Submitting a commercial invoice when a CI1 is required, or submitting a CI1 with incomplete fields, can trigger CBSA shipment holds at the port of entry. Those holds lead to additional duty assessments, penalty interest, and delays in goods release that cascade directly into AP reconciliation backlogs. Invoices that should have matched to purchase orders and cleared within days instead sit unresolved while compliance teams scramble to produce corrected documentation.

The financial stakes of customs documentation compliance are substantial. According to CBSA's 2025 year-in-review data, the Canada Border Services Agency processed 30.7 million releases of commercial goods into Canada and collected $47.5 billion in duties and taxes in 2025. Each of those releases required compliant invoice documentation, and errors at any point in that volume create audit exposure that compounds over time.

Understanding exactly which fields the CI1 form requires, and how each one affects duty calculation and goods clearance, is where compliance moves from policy to practice.


Mandatory Fields on the CI1 Canada Customs Invoice

CBSA Memorandum D1-4-1 specifies 25 data fields on the Canada Customs Invoice form CI1. For AP teams responsible for preparing or validating these forms, knowing what each field requires and why it matters is far more useful than simply knowing the fields exist. The following breakdown organizes these fields into five logical groups that mirror how AP practitioners typically work with the data.

Transaction Parties

The CI1 requires complete identification of every party involved in the transaction:

  • Vendor name and address: the supplier or exporter selling the goods.
  • Purchaser name and address: the entity contractually buying the goods, which may differ from the importer of record.
  • Consignee name and address: the party in Canada to whom the goods are shipped. In many cross-border transactions, the consignee and purchaser are the same entity, but not always.
  • Country of transhipment: if goods pass through an intermediate country before arriving in Canada, this field must identify that country.

A common error here is listing only the freight forwarder or customs broker as the consignee rather than the actual receiving business. CBSA expects the true consignee, and discrepancies between the CI1 and the commercial invoice on party details will trigger review delays.

Goods Identification

This group captures what is being imported and where it was produced:

  • Number and kind of packages: the physical packaging count and type (pallets, cartons, drums).
  • Detailed description of goods: a plain-language description specific enough for a customs officer to identify the product without opening the shipment. Generic entries like "parts" or "supplies" are insufficient and will cause holds at the border.
  • Harmonized System (HS) tariff classification codes: the internationally standardized codes (6 digits at the international level, extended to 8 or 10 digits for Canadian tariff purposes) from the Customs Tariff that determine applicable duty rates. Each line item on the CI1 needs its own HS code.
  • Country of origin of the goods: the country where the goods were manufactured or substantially transformed, which is distinct from the country of transhipment.

Missing or incorrect HS codes are among the most frequent CI1 errors AP teams encounter. An HS code that is even one digit off can change the duty rate substantially. When validating a CI1 against a supplier's commercial invoice, verify that HS codes match what your customs broker has classified, not just what the vendor listed on their paperwork.

Valuation and Pricing

CBSA uses the transaction value, the price actually paid or payable for the goods, as the primary basis for duty assessment:

  • Unit price for each item: the per-unit cost for every distinct line item on the invoice.
  • Currency of settlement: the currency in which the transaction will be settled. If the invoice is in USD but your AP system records CAD, ensure the CI1 reflects the actual transaction currency, not a converted amount.
  • Total transaction value: the aggregate value of all goods on the invoice.

Incorrect currency declarations create cascading problems. If an AP team enters CAD values on a CI1 when the actual settlement currency is USD, the dutiable value will be wrong, the GST/HST calculation will be wrong, and the resulting assessment will need correction through a re-determination request.

Conditions of Sale

This is the section AP teams most frequently overlook, and it carries real financial risk:

  • Conditions or considerations affecting price: any factor beyond the base purchase price that could influence the dutiable value. This includes royalties, license fees, assists (tooling, molds, or engineering work provided to the vendor at no charge), and related-party pricing arrangements.

AP teams must disclose these elements because CBSA can add them to the transaction value, increasing the amount on which duties and taxes are assessed. For example, if your company provides proprietary tooling to a foreign vendor to manufacture parts, the value of that tooling is an "assist" that must be declared even though it does not appear on the vendor's commercial invoice. Related-party transactions receive particular scrutiny from CBSA, and failing to disclose a related-party relationship when one exists can result in penalties and retroactive duty reassessments.

Transportation and Insurance

The final group addresses logistics costs and how they relate to the declared value:

  • Cost of transportation to the point of direct shipment to Canada: freight charges incurred to move the goods to the port or point from which they are shipped directly to Canada.
  • Insurance charges: the cost of insuring the goods during transit.

For each of these, the CI1 requires you to specify whether they are included in or excluded from the unit price. This distinction matters because CBSA needs to determine the correct customs value, and freight/insurance treatment varies depending on the terms of sale (Incoterms). If your supplier quotes DDP (Delivered Duty Paid), transportation and insurance are embedded in the unit price. If they quote FOB or EXW, these costs are typically separate and must be itemized.

Bilingual Documentation Considerations

Businesses operating in Quebec should be aware that provincial language laws can affect customs-related documentation workflows. While federal customs forms follow their own language rules, supporting commercial documents used alongside the CI1 may need to comply with bilingual invoicing requirements under Quebec Bill 96. AP teams handling Quebec-destined shipments should confirm their documentation practices account for both federal customs requirements and provincial language obligations.

Bridging CI1 Data to Your Existing Documents

In practice, AP teams rarely create CI1 data from scratch. Most of the information on the Canada Customs Invoice form CI1 already exists on the commercial invoice your supplier provides with each shipment. The challenge is that these two documents serve different purposes, contain overlapping but not identical fields, and follow different formatting standards.


Commercial Invoice vs Canada Customs Invoice

Cross-border AP teams frequently encounter two documents that appear to serve the same purpose: the commercial invoice and the Canada Customs Invoice (CI1). Both declare the goods being shipped and their value, but they differ in format, regulatory standing, and the level of detail required. Understanding exactly where they diverge prevents clearance delays and compliance gaps.

A commercial invoice is a standard trade document issued by the seller to the buyer. It has no mandated format. Sellers can structure it however they choose, and the fields included vary widely depending on the vendor, the industry, and the country of origin. It typically covers the description of goods, quantity, unit price, total value, and payment terms.

The CI1, by contrast, is a prescribed Canada Border Services Agency (CBSA) form with 25 specific fields. It requires information that commercial invoices routinely omit: Harmonized System (HS) tariff classification codes, country of origin for each line item, detailed conditions of sale, and itemized transportation cost breakdowns. The CI1 also requires the vendor's and purchaser's signatures or authorized certification, a formality that most commercial invoices do not include.

FeatureCommercial InvoiceCI1 Canada Customs Invoice
FormatNo mandated layoutPrescribed CBSA form, 25 fields
HS codesOften omittedMandatory per line item
Country of originSometimes includedRequired for each good
Conditions of saleRarely includedRequired disclosure
Transportation costsLump sum or omittedItemized breakdown required
SignaturesNot requiredVendor and purchaser certification
When accepted by CBSAShipments at or below $2,500 CADRequired above $2,500 CAD

When Both Documents Are Needed

For shipments valued over $2,500 CAD, the CI1 is mandatory. However, CBSA may still request the original commercial invoice as a supporting document to verify the declared values and transaction details. The commercial invoice does not replace the CI1 at this threshold; it supplements it.

For shipments valued under $2,500 CAD, a commercial invoice is accepted in place of the CI1, but only if it contains all the fields that CBSA requires for customs clearance. If any mandatory fields are missing, the shipment can still be held or assessed penalties.

The AP Reconciliation Step

This distinction creates a specific workflow burden for AP teams. Suppliers send commercial invoices as a matter of course, but those documents rarely contain every field CBSA demands. Before customs clearance can proceed, AP staff must cross-check the commercial invoice data against CI1 field requirements and either request missing information from the vendor or populate the CI1 form separately.

This reconciliation step is where errors concentrate. A commercial invoice might list goods in broad categories while CBSA requires line-item HS codes. The invoice might state a single lump-sum shipping cost while the CI1 requires transportation charges broken out between the origin country and Canada. AP teams that treat the commercial invoice as sufficient without validating it against CI1 requirements risk assessment penalties and shipment delays.

Related trade documents add further volume to this process. Freight invoices, bills of lading, and packing lists all flow through AP alongside customs documentation in cross-border transactions. Teams that handle high volumes of imports often find that automating freight invoice data extraction reduces the manual burden of reconciling these parallel document streams.

Beyond the invoice form itself, businesses trading under the Canada-United States-Mexico Agreement (CUSMA) face an additional documentation layer. Preferential tariff rates under CUSMA require separate origin certification that neither the commercial invoice nor the CI1 provides on its own.


CUSMA Certificate of Origin and Tariff Documentation

The Canada-United States-Mexico Agreement (CUSMA) provides importers with a direct path to reduced or zero duty rates on goods originating in the United States, Mexico, or Canada. For AP teams and trade compliance professionals, understanding how customs invoice documentation connects to CUSMA origin certification is essential because the financial stakes are significant: without a valid certificate of origin, goods automatically default to the Most Favoured Nation (MFN) tariff rate, which is often substantially higher than the preferential rate.

How CUSMA Origin Certification Works

Unlike its predecessor NAFTA, CUSMA does not require a dedicated certificate of origin form. Instead, the exporter, producer, or importer can certify origin by including a set of minimum data elements on any document, including the commercial invoice itself. The certification must contain:

  • The certifier's name, title, address, and contact information
  • The exporter and producer details (if different from the certifier)
  • The importer's name and address
  • A description of the goods sufficient to identify them
  • The Harmonized System (HS) tariff classification for each good (at the six-digit level)
  • The origin criterion under which the good qualifies
  • The blanket period, if the certification covers multiple shipments of identical goods
  • The date of certification and the certifier's signature or authorized stamp

This flexibility means AP teams may encounter origin certifications embedded within commercial invoices, attached as separate documents, or provided as standalone declarations. Regardless of format, the required data elements must all be present for CBSA to accept the claim.

Aligning Customs Invoice Data With Origin Claims

The CI1 Canada customs invoice contains several fields that must align precisely with the CUSMA origin certification. The country of origin declared on the customs invoice, the HS codes assigned to each line item, and the goods descriptions all serve as cross-reference points for CBSA officers reviewing preferential tariff claims.

Inconsistencies between these documents create real problems. If the customs invoice lists a different country of origin than the certificate of origin, or if the HS classification on the CI1 does not match the tariff code on the CUSMA certification, CBSA can flag the shipment for verification. In many cases, this results in outright denial of preferential treatment, meaning the importer pays the full MFN duty rate on the affected goods.

For AP teams, the practical risk is receiving a CBSA duty reassessment weeks or months after the original import. Reconciling these reassessments requires tracing back through the customs invoice, the certificate of origin, and the CBSA detailed adjustment statement to identify where the documentation mismatch occurred.

Financial Impact for AP Teams

When preferential tariff treatment is denied, the cost difference between the CUSMA rate and the MFN rate can be substantial. For example, certain manufactured goods carry an MFN tariff rate above 10% while the CUSMA preferential rate is zero. On a $100,000 shipment, that documentation gap translates to over $10,000 in avoidable duty payments. AP teams reconciling import duty assessments need a systematic process to verify that CUSMA origin claims match across three document sets: the customs invoice (CI1 or commercial invoice), the certificate of origin, and the CBSA duty statement.

This verification process becomes particularly important for businesses importing goods under blanket CUSMA certifications, where a single origin claim covers multiple shipments over a period of up to 12 months. Any change in the goods' composition, sourcing, or production process during that period can invalidate the certification for subsequent shipments.

Record Retention Requirements

CBSA requires importers to maintain origin certification records for six years from the date of the import transaction. This obligation applies to all supporting documents, including the customs invoices, certificates of origin, commercial invoices, and any correspondence with exporters or producers regarding origin determinations. Businesses handling cross-border trade at volume should maintain organized digital records of all customs documentation to meet both CBSA and CRA electronic record-keeping requirements, reducing the risk of penalties during audits or verification requests.

Beyond duty classification, the values declared on customs invoices also determine the GST/HST assessed on imported goods, adding another layer of financial impact that AP teams must track and reconcile accurately.


How Customs Invoice Values Determine Import GST/HST

Most commercial goods entering Canada are subject to the Goods and Services Tax, and in participating provinces, the Harmonized Sales Tax. What makes import GST/HST distinct from domestic transactions is how the tax base is calculated. Rather than applying the tax rate to a simple purchase price, CBSA uses a layered formula that starts with the customs invoice valuation and builds upward.

The calculation chain works as follows: the transaction value declared on the CI1 customs invoice establishes the value for duty. Any applicable customs duties are then added to that figure, along with excise taxes and excise duties where relevant. The sum of these three components forms the total value on which GST/HST is assessed. This layered structure means that an error in the original customs invoice transaction value does not just affect the duty calculation. It cascades through every subsequent layer, inflating or understating the GST/HST owed on that shipment.

How import GST/HST is collected depends on the importer's registration status. For businesses that are not registered for GST/HST, the tax is collected directly by CBSA at the time of release or accounting. For GST-registered importers, a deferral mechanism exists: rather than paying GST/HST at the border, these businesses can report the import tax on their periodic GST/HST returns. However, the deferral does not reduce the need for accurate customs invoice data. To claim input tax credits on imported goods, the registered importer must substantiate the exact GST/HST amount with documentation that ties back to the customs invoice valuation. Overstated or understated values on the CI1 translate directly into incorrect input tax credit claims, which can trigger reassessments.

The reconciliation responsibility falls squarely on AP teams. When CBSA processes an import shipment, it issues a B3 Customs Accounting Document that records the assessed value for duty, the duty amount, and the GST/HST charged. AP staff must cross-reference each B3 against the original CI1 customs invoice to confirm that the declared transaction value matches, that duty rates were applied correctly, and that the resulting GST/HST assessment is accurate. When discrepancies surface, whether from currency conversion differences, valuation adjustments, or data entry errors, the importer must file an adjustment request with CBSA to correct the record.

Businesses already navigating Canadian GST/HST invoice compliance rules for their domestic transactions encounter a separate layer of complexity when import shipments enter the picture. Domestic GST/HST invoicing follows requirements set under the Excise Tax Act, while customs invoice valuations operate under the Customs Act and CBSA administrative frameworks. AP teams must track both regulatory streams independently, applying different validation rules to domestic purchase invoices versus import duty statements.

Across dozens or hundreds of import shipments per month, this documentation workload compounds quickly. Each shipment generates its own CI1, B3 statement, and potentially a CUSMA certificate, all requiring cross-referencing and validation before GST/HST amounts can be confidently reported or claimed as input tax credits. For AP teams handling this volume manually, the data extraction and reconciliation burden represents one of the most time-intensive aspects of cross-border trade compliance.


Managing Customs Invoice Data in AP Workflows

Cross-border imports into Canada generate a document stack that AP teams must process for every single shipment. A typical import transaction produces a commercial invoice, the CI1 Canada customs invoice, a CUSMA certificate of origin (if applicable), the CBSA B3 Customs Accounting Document, a freight invoice, and a bill of lading. Each document contains overlapping but non-identical data points, and AP must extract values from all of them, cross-reference those values for consistency, and reconcile the final duty and tax assessments before approving payment.

The CI1 form alone presents significant data extraction challenges. Its 25 fields span multiple sections covering vendor and purchaser details, goods descriptions, HS tariff classifications, unit prices, conditions of sale, and currency declarations. HS codes are alphanumeric classification strings that must precisely match the customs tariff schedule to determine the correct duty rate. Currency conversion between the invoice currency and Canadian dollars must be verified against the Bank of Canada exchange rate applicable on the date of direct shipment. Conditions of sale disclosures in fields like "Other costs" and the terms of sale declaration directly affect whether additions or deductions apply to the dutiable value.

The Reconciliation Workflow

AP teams follow a multi-step reconciliation process for each import shipment:

  1. Transaction value verification. Compare the declared transaction value on the CI1 against the commercial invoice total and the value for duty on the CBSA B3 Customs Accounting Document. Any discrepancy signals either a data entry error or an incorrect valuation method applied by the customs broker.

  2. Preferential tariff rate confirmation. If a CUSMA certificate of origin was filed, verify that the B3 reflects the preferential tariff rate rather than the Most Favoured Nation (MFN) rate. A missed preferential claim means the importer paid full duties unnecessarily.

  3. GST/HST assessment validation. Confirm that GST (or HST in applicable provinces) was calculated on the correct value for duty, which includes the transaction value plus applicable duties, freight to the point of entry, and any other charges not already included.

  4. Freight and ancillary cost allocation. Reconcile freight invoice amounts against the transportation costs declared on customs documentation, ensuring costs are allocated correctly across line items when a shipment contains goods with different HS classifications.

Consequences of Errors

When extraction or reconciliation errors slip through AP review, the financial and compliance consequences are concrete:

  • Overpaid duties are recoverable, but filing a CBSA adjustment request (B2 form) requires staff time, supporting documentation, and can take months to process.
  • Underpaid duties trigger penalties and interest once identified during a CBSA trade compliance verification or audit.
  • Incorrect GST/HST input tax credit claims create CRA audit exposure. If the GST amount claimed as an ITC does not match what was actually assessed and paid, the difference becomes a tax liability with interest.
  • Failed CUSMA origin claims result in full MFN duty rates applied retroactively, potentially across all shipments of that product during the review period.

Where Automation Fits

At scale, performing this four-step reconciliation manually for each shipment means AP staff spend the majority of their cross-border processing time on data extraction rather than analysis. Businesses processing high volumes of cross-border shipments increasingly use AI-powered document extraction to convert customs invoices, duty statements, and related trade documents into structured spreadsheet data for reconciliation. Rather than manually keying 25 fields per CI1 form across dozens or hundreds of monthly shipments, AP teams can automate customs invoice data extraction and focus their effort on exception handling and variance analysis.

Purpose-built extraction platforms handle the specific challenges of cross-border invoicing workflows. For example, a platform like Invoice Data Extraction can batch-process up to 6,000 mixed-format customs documents in a single job, using goal-oriented prompts such as "I'm reconciling customs invoices against duty assessments" to structure the output accordingly. Multi-language support covers both English and French Canadian customs documents, and every row in the structured Excel output includes a source page reference for audit verification.

The priority for AP teams building a compliant customs documentation process is establishing consistent extraction, validation, and reconciliation steps that apply uniformly across all import shipments, whether those steps are performed manually, through automation, or through a combination of both.


Building a Compliant Customs Documentation Process

The regulatory framework governing Canada customs invoice requirements is well-defined in CBSA Memorandum D1-4-1. The operational challenge for AP teams is building consistent, repeatable processes to extract, validate, and reconcile customs invoice data at scale across every import shipment.

Pre-clearance validation. Establish a verification step before any CI1 form is submitted to CBSA. Confirm that all 25 mandatory fields are complete, that declared values match the underlying commercial invoice, and that the currency and terms of sale are stated accurately. Catching errors before clearance prevents AMPS penalties and costly post-entry amendments.

Duty statement reconciliation. Create a workflow that cross-references every customs invoice against the corresponding CBSA B3 Customs Accounting Document once goods have cleared. Compare the declared transaction value, duty rates applied, and GST/HST assessed. Flag discrepancies for immediate follow-up with your customs broker. This single step protects both duty spend accuracy and downstream input tax credit claims.

Document retention. Maintain digital copies of all customs documentation for the six-year retention period mandated by the Canada Border Services Agency (CBSA). This includes CI1 forms, commercial invoices, CUSMA certificates of origin, B3 statements, and any supporting correspondence. Centralized digital storage ensures your organization can respond to a CBSA verification or audit request without scrambling to locate paper records.

CUSMA origin review. Periodically audit CUSMA origin claims to confirm that preferential tariff rates are being correctly applied and that the supporting certification data remains valid. Rules of origin can shift as supply chains change, and a tariff preference claimed in error creates retroactive duty liability plus interest.

Valuation accuracy monitoring. Track customs invoice valuations against GST/HST assessments on an ongoing basis. Overstated values inflate GST/HST paid at the border, tying up cash unnecessarily. Understated values trigger reassessments, penalties, and jeopardize input tax credit eligibility. Either direction costs money.

Use the CI1 form whenever goods exceed $2,500 CAD in value. Ensure consistency between customs invoices and CUSMA origin certifications. Verify that declared values correctly feed into GST/HST calculations. These are not optional best practices. They are baseline compliance requirements, and the AP teams that build structured processes around them spend less time on corrections, audits, and penalty disputes than those that treat customs documentation as a broker-only concern.

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