Memorandum D10-13-3: Interpretation of the Expressions “Open Vessels” and “Lifeboats and Inflatable Rafts Imported by Societies Dedicated to Saving Lives” in Chapter 89 of the Customs Tariff
ISSN 2369-2391
Ottawa, July 18, 2026
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Plain language summary
Target audience: Importers of commercial goods.
Key content: Interpretation of certain terms for the purpose of tariff classification of vessels, within Chapter 89 at tariff item level.
Keywords: Tariff classification, Importer, Open Vessels, Lifeboat, Inflatable Raft, Lifesaving Societies.
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Updates made to this D-memo
This D-memo:
- Merges the policy for the interpretation of the expressions used in Chapter 89 of the Customs Tariff of “open vessel” and “Lifeboats and inflatable rafts imported by societies dedicated to the saving of lives” in Departmental Memoranda D10-13-3 and D10-14-48, for clarity.
- Has been updated to reflect accessibility and plain language considerations.
Guidelines
This D-Memo provides the Canada Border Services Agency’s (CBSA) policy for two expressions that are found in Chapter 89 of the Customs Tariff: “open vessel” and “Lifeboats and inflatable rafts imported by societies dedicated to the saving of lives.”
Open vessels
1. For tariff classification purposes, the CBSA considers an “open vessel” to be a vessel for use on the surface of the water, that has no deck. A deck consists of a horizontal surface (e.g. plank, metal plate) above the bottom of the vessel where:
- It may provide a working or leisure surface or flooring;
- It may provide a protective covering over the vessel to prevent the entrance of water to the lower portions of the vessel; or
- It may be mainly structural providing support for various elements and/or more buoyancy for the vessel.
2. Vessels that have a deck are not to be classified under tariff items 8901.90.10, 8906.90.11, or 8906.90.19, regardless of the reason for the presence of a deck and of the number of decks in a vessel (upper deck, lower deck, etc.).
3. In applying this interpretation to a vessel, primary consideration should be given to the construction of the vessel:
- Vessels that have a narrow deck along the gunwale for a footpath may be considered to be open for purposes of the tariff items at issue.
- Vessels such as barges that may have a flat surface for carrying goods are not considered to be open vessels.
Lifeboats and inflatable rafts imported by societies dedicated to the saving of lives
4. Societies dedicated to saving lives are organizations that are incorporated under either a federal or provincial charter for the express purpose of saving the lives of persons who are victims of water mishaps and conducting related life-saving training.
Example: The Royal Life Saving Society Canada
5. Only societies that are incorporated under either a federal or provincial charter for the express purpose of saving the lives of persons are entitled to import lifeboats under tariff item 8906.90.11 and inflatable rafts under tariff item 8907.10.10. This position was supported by the Canadian International Trade Tribunal (CITT) decision in AP-91-006 Mil Davie Inc.
6. Any importer that does not satisfy this requirement is excluded from using the provisions of these tariff items. This includes: commercial companies and corporations, government departments and agencies, and municipal bodies such as fire and police departments.
Other open vessels considered a lifeboat imported by societies dedicated to the saving of lives
7. Lifeboats that are considered to be “open vessels” are to be classified under tariff item 8906.90.11 when imported by a society dedicated to the saving of lives. In this case, the vessel must meet both requirements as interpretated in this D-Memo.
Additional Information
8. Procedures to obtain an advance ruling for tariff classification of goods are outlined in Memorandum D11-11-3: Advance Rulings for Tariff Classification.
References
Consult these resources for further information.
Applicable legislation
Related D memoranda
Superseded D memorandum
- D10-13-3 dated
- D10-14-48 dated
Issuing office
Tariff Classification, Origin and Valuation Division
Trade Programs and Operations Directorate
Commercial and Trade Branch
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