If your US business sells to Canadian customers and ships goods across the border under your own name, you are a Non-Resident Importer — and as of January 1, 2026, you are legally responsible for your own customs compliance in Canada. The era when your Canadian customs broker quietly handled everything on your behalf, under their business number and their bond, is over.
The Canada Border Services Agency (CBSA) fully implemented its CBSA Assessment and Revenue Management (CARM) system, and the Customs Act was amended to make the importer of record, not the broker, directly liable for duties, taxes, and penalties. For US companies, this is not a paperwork update. It is a fundamental shift in who carries the legal and financial risk of importing into Canada.
This guide explains exactly what a US business selling to Canada must do to comply with CARM as a Non-Resident Importer: how to register, what financial security you must post, how to recover the GST you pay at the border, and how to delegate authority to your customs broker correctly. Follow it in order, and your shipments keep moving. Skip a step and your goods get held at the border.
What Is a Non-Resident Importer, and Are You One?
A Non-Resident Importer (NRI) is a business based outside Canada that imports goods into Canada under its own name, without a physical presence in the country. By registering as an NRI, your US company becomes the Importer of Record (IOR) into Canada — the legal entity responsible for the shipment at the border.
If you sell to Canadian customers on a Delivered Duty Paid (DDP) basis — meaning you handle the duties, taxes, and customs clearance so your Canadian buyer receives the goods without any surprise charges at the door — you are almost certainly operating, or should be operating, as a Non-Resident Importer.
| Why the NRI model is good for your business |
| As the Importer of Record, you can roll all shipping and customs costs into a single price for your Canadian customer. The transaction looks and feels like a domestic purchase no unexpected duty bills, no goods held at customs waiting for the customer to pay. |
| This removes the single biggest friction point in cross-border e-commerce: the ‘duties at the door’ surprise that drives cart abandonment and refund requests. The NRI model makes buying from a US company as easy for a Canadian as buying from a Canadian company. |
You are likely a Non-Resident Importer if any of the following describe your business:
- You ship products from a US warehouse directly to Canadian consumers under your brand.
- You sell DDP to Canadian customers and absorb the duties and taxes.
- You import goods into Canada to hold in a Canadian fulfilment centre or 3PL before sale.
- You are the named importer on the customs paperwork for goods entering Canada, even though your business has no Canadian office.
What Changed Under CARM — and Why It Matters More for US Businesses
Before CARM, most US businesses selling to Canada relied entirely on their Canadian customs broker. The broker’s bond covered the Release Prior to Payment (RPP) privilege, the broker’s business number appeared on the accounting, and the US company had no direct relationship with the CBSA. That model is gone.
Three changes affect every Non-Resident Importer:
| The three CARM changes US businesses cannot ignore |
| 1. January 1, 2026 — Customs Act liability shift. Legislative amendments to Section 17 of the Customs Act came into force. The importer of record is now directly and jointly liable for all duties and taxes. Your broker can no longer carry that liability for you using their own business number. |
| 2. May 20, 2025 — Financial security enforcement. A customs broker’s RPP financial security no longer covers commercial importers. As a Non-Resident Importer, you must post your own financial security — a surety bond or cash deposit — directly in the CARM Client Portal, or your goods cannot be released before payment. |
| 3. Mandatory portal registration. Every Non-Resident Importer must have their own CARM Client Portal account. Without it, your goods cannot be cleared, and your broker cannot file on your behalf. |
For a US business, the practical effect is that you can no longer outsource Canadian customs compliance entirely. You must register, you must post security, and you must actively delegate authority to your broker through the portal. Your broker remains essential — but they now act under your registration, not in place of it.
How a US Business Registers as a Non-Resident Importer Under CARM
The Non-Resident Importer registration path has one critical difference from the resident path: you cannot generate your Business Number inside the CARM portal. You must obtain it from the Canada Revenue Agency first. Follow these steps in order.
Step 1: Obtain a 9-digit Business Number (BN9) from the CRA
Every importer needs a 9-digit Business Number (BN9) issued by the Canada Revenue Agency (CRA). Resident Canadian businesses can generate one inside the CARM portal during registration. As a non-resident, you cannot — you must obtain your BN9 from the CRA before you attempt CARM registration.
Attempting to register in the CARM portal without a CRA-issued BN9 will produce a registration error and require you to contact the CARM Client Support Helpdesk to resolve. To obtain your BN9 as a non-resident, register through the CRA’s non-resident business registration process. You will need your legal entity name, business address, and a description of your Canadian commercial activity.
| Important for US businesses |
| The legal entity name and address you provide to the CRA must exactly match the details you later enter in the CARM Client Portal. Any mismatch — including abbreviations, punctuation, or formatting differences — triggers manual CBSA review and can delay your registration by up to 30 days. Use your exact registered business name as it appears on your incorporation documents. |
Step 2: Register your RM import-export program account
Once you have your BN9, you need an import-export program account, known as an RM account. This appends a program identifier to your BN9, creating a 15-character BN15 (for example, 123456789RM0001). The RM account is what the CBSA uses to track your import activity, assess your duties, and manage your financial security.
New importers with a BN9 can register their RM account directly in the CARM Client Portal. As a non-resident, you will be prompted during this step to provide the address where your business records are kept (covered in Step 3).
Step 3: File Form BSF900 if your records are kept outside Canada
As a Non-Resident Importer, the CARM portal will ask where your books and records are maintained. If your records are kept outside Canada — which is the case for virtually every US business — you must obtain permission from the CBSA to do so.
You provide this permission by completing Form BSF900: Agreement to Maintain Records Elsewhere than the Place of Business in Canada, and submitting it through the CARM Client Portal when prompted. One firm rule applies: your books and records may be kept in the United States, but they cannot be kept outside North America. If your records are held in Europe or Asia, you must arrange North American record-keeping before registration.
Step 4: Designate your Business Account Managers (BAMs)
The Business Account Manager (BAM) is the highest-level administrator on your CARM account. The first person who links their user profile to your business account automatically becomes the BAM. This person can manage business information, delegate authority to your customs broker, and handle penalty notices.
| Assign at least two BAMs |
| If your only BAM leaves the company or loses access to their login or multi-factor authentication, your business can be locked out of its own CARM account with no self-service recovery. For a US business managing Canadian imports remotely, this risk is higher — the person with portal access may be in a different office or may change roles. Assign a primary and a secondary BAM before completing registration. |
Step 5: Enrol in Release Prior to Payment and post financial security
Release Prior Payment (RPP) is the privilege that lets your goods be released by the CBSA before you pay the duties and taxes. Without RPP, you must pay in advance for every shipment through the CARM portal before your goods are released — a serious cash-flow and operational burden for any business shipping regularly into Canada.
As of May 20, 2025, your customs broker’s bond no longer covers you. To enrol in RPP, you must post your own financial security directly. You have two options:
| Security type | Amount required | Best for |
| Cash deposit (posted in CARM portal) | 100% of your highest monthly accounts payable to the CBSA over the prior 12 months | US businesses with high cash reserves and low, infrequent import volumes |
| Surety bond (Written Security Agreement) | 50% of your highest monthly accounts payable to the CBSA, subject to a CAD $25,000 minimum and CAD $10 million maximum | Most US businesses. Lower cash outlay; arranged through a surety provider or your customs broker; renews annually |
The financial security you post secures all amounts owing to the CBSA — duties, GST, interest, adjustments, ascertained forfeitures, SIMA fees, and any penalties. If you do not have 12 months of import history, you provide an estimate of your expected monthly duties and taxes; if your estimate is too low, the CARM system will notify you.
| Rule of thumb for US businesses |
| A surety bond is almost always more cost-efficient than a cash deposit, because you post only 50% of the required amount as a bond rather than 100% as cash. For a business with monthly Canadian duty and tax obligations up to CAD $50,000, a surety bond keeps your capital free while satisfying the RPP requirement. |
| Clearit Canada can arrange your RPP surety bond through an approved security provider as part of your NRI setup. |
Step 6: Delegate authority to your customs broker — digitally
Your customs broker cannot register your business for you, and they cannot file on your behalf until you grant them delegation of authority through the CARM Client Portal. This is the step US businesses most often overlook, because under the old system, a paper Power of Attorney was sufficient.
Under CARM, digital delegation is a separate, additional requirement. The General Agency Agreement (GAA) or Power of Attorney your broker holds does not replace portal delegation, and portal delegation does not replace the paper agreement. You need both. To delegate: log into the CARM Client Portal, navigate to Manage My Business Relationships, review the pending request from your broker, approve it, and select the appropriate role and visibility.
Once delegation is complete, your broker can file your Commercial Accounting Declarations, manage your entries, and act on your behalf — under your registration, with your financial security backing the transactions.
How to Recover the GST You Pay at the Border
Here is the part most US businesses miss, and it directly affects your margins: as a Non-Resident Importer, you pay Goods and Services Tax (GST) at the border when your goods enter Canada — but you may be able to recover it.
If your business is registered for GST/HST with the CRA, you can claim the GST you paid at importation as an Input Tax Credit (ITC) on your GST/HST return. This effectively makes the import GST recoverable rather than a permanent cost. For a US business importing regularly into Canada, this recovery can represent a meaningful portion of your landed cost.
| The CAD is your proof of GST payment — keep it |
| Under CARM, the Commercial Accounting Declaration (CAD) replaced the old B3 customs coding form. The CAD is now the official proof that you paid GST at import. You need a valid CAD to support your Input Tax Credit claim on your GST/HST return. |
| Without a valid CAD, the CRA may deny you the right to recover GST. Download and retain your CAD documents, along with commercial invoices and supporting documentation, for at least 6 years. |
Note the registration threshold: generally, if your worldwide taxable supplies exceed CAD $30,000 in 12 months, you are required to register for a GST/HST account with the CRA. Many US businesses selling into Canada will exceed this threshold and must register. GST/HST registration is separate from your import BN9 registration, though both use your CRA business number. Consult a Canadian tax advisor to confirm your specific registration obligations.
Your Ongoing CARM Obligations After Registration
Registration is the beginning, not the end. As a Non-Resident Importer and importer of record, you carry ongoing responsibilities that the CBSA now holds you — not your broker — accountable for.
- Monitor your Statement of Account. The CARM portal issues a monthly Statement of Account on the 25th of each month, consolidating all your import duties and taxes. Payment is due by the last business day of the month. Late payments now accrue penalties and interest — the transition grace period ended January 31, 2026.
- Keep your financial security adequate. If your import volume grows, your required security increases. The CBSA does not automatically prompt you to top it up. Underposted security can cost you your RPP privileges without warning. Review your posted security against your highest monthly accounts payable each quarter.
- Maintain your books and records for six years. Keep all CADs, commercial invoices, and supporting documentation. The CBSA can verify your entries for up to four years, and the CRA requires six-year retention for GST/ITC purposes.
- Classify your goods accurately. As importer of record, you are liable for the accuracy of the tariff classification, valuation, and origin declared on every Commercial Accounting Declaration — even when your broker files it. Misclassification carries penalty exposure under the Administrative Monetary Penalty System (AMPS).
Common Mistakes US Businesses Make With CARM
These are the errors that most frequently stop US businesses at the Canadian border:
- Assuming the broker handles registration. Your broker cannot register your business or post your security. You must do both. This is the single most common and costly misunderstanding.
- Trying to get a BN9 through the CARM portal. Non-residents cannot. You must obtain your BN9 from the CRA first, or registration fails.
- Completing paper POA but skipping digital delegation. Both are required. A valid paper agreement without portal delegation means your broker still cannot file for you.
- Forgetting to post financial security before the first shipment. Without RPP security, every shipment requires advance cash payment before release.
- Keeping records outside North America. Books and records can be in the US but not in Europe or Asia. File BSF900 to authorise US record-keeping.
- Not registering for GST/HST and losing ITC recovery. Without GST registration and valid CADs, you pay import GST with no path to recover it.
Frequently Asked Questions
Is CARM registration mandatory for US businesses selling to Canada?
Yes. If your US business is the importer of record for goods entering Canada, CARM Client Portal registration is mandatory. As of January 1, 2026, your customs broker’s business number can no longer be used to clear goods on your behalf. Without your own CARM registration, your goods cannot be released at the Canadian border.
Can my Canadian customs broker register my business for me?
No. Your broker cannot register your business or post your financial security on your behalf. You must complete the initial CARM registration yourself, obtain your BN9 from the CRA, post your own RPP security, and then delegate authority to your broker through the portal. Your broker can guide you through each step, but the registration and security obligations are legally yours.
Do I need a Canadian bank account as a Non-Resident Importer?
Not strictly. Non-Resident Importers do not require a Canadian bank account, but you do need a valid electronic method to pay duties and taxes through the CARM portal. The portal accepts various electronic payment methods. The essential requirements are your BN9, your portal access, and your posted financial security.
How much financial security do I need to post?
For a surety bond, you must post security equal to 50% of your highest monthly accounts payable to the CBSA over the most recent 12-month period, subject to a CAD $25,000 minimum and a CAD $10 million maximum. For a cash deposit, you post 100% of that amount. If you have no import history yet, you provide an estimate, and the CARM system will notify you if it is too low.
Can I recover the GST I pay at the Canadian border?
If your business is registered for GST/HST with the CRA, yes. You claim the import GST as an Input Tax Credit on your GST/HST return. The Commercial Accounting Declaration (CAD) is your official proof of payment and is required to support the claim. Without GST registration and a valid CAD, the import GST is not recoverable. Generally, you must register for GST/HST if your worldwide taxable supplies exceed CAD $30,000 over 12 months.
Where can my US business keep its import records?
Your books and records may be kept in the United States, but not outside North America. To maintain records outside Canada, you must file Form BSF900 (Agreement to Maintain Records Elsewhere than the Place of Business in Canada) through the CARM Client Portal. Records held in Europe or Asia must be relocated to North America before registration.
Set Up Your Non-Resident Importer Account With Clearit Canada
CARM registration as a Non-Resident Importer involves CRA registration, portal setup, financial security, BSF900 filing, and digital delegation, and every step has a way to go wrong that holds your goods at the border. Clearit Canada is a fully digital, self-serve customs brokerage built to get US businesses importing into Canada quickly and correctly.
We guide you through your BN9 registration, help you arrange your RPP surety bond, and handle your Commercial Accounting Declarations once your delegation is in place. Get started with Clearit Canada and clear your next Canadian shipment without the compliance guesswork.