Importing commercial goods from China into Canada now involves much more than preparing a commercial invoice and asking a customs broker to clear the shipment.
Canada’s CBSA Assessment and Revenue Management system, known as CARM, has fundamentally changed how commercial importers register with the Canada Border Services Agency, account for imported goods, pay duties and taxes, authorize customs brokers and obtain release of cargo before payment.
Since October 21, 2024, CARM has been the official system of record for commercial imports into Canada. For Canadian companies regularly importing goods from China, understanding CARM is now an important part of planning reliable customs clearance.
There was another important change on January 1, 2026: amendments to Canada’s Customs Act concerning the Importer of Record came into force, strengthening responsibility for duties and taxes declared on imported goods.
For importers shipping from China to Vancouver, Toronto, Montreal, Calgary, Edmonton or other Canadian destinations, these changes mean customs planning should begin before the vessel departs China, not after the container reaches Canada.
This guide explains the Canadian customs clearance process, CARM registration, BN/RM accounts, Release Prior to Payment, financial security, customs duties, GST, Importer of Record responsibility and the documents required to clear commercial cargo from China.
What Is CARM in Canada?
CARM stands for:
CBSA Assessment and Revenue Management
It is the Canada Border Services Agency’s digital system for managing the accounting and payment of duties and taxes on commercial imports.
CARM became Canada’s official system of record for commercial import accounting on October 21, 2024.
The associated online platform is the:
CARM Client Portal — CCP
Commercial importers use CARM for functions such as:
- Registering their business with CBSA
- Enrolling in CBSA import programs
- Managing importer accounts
- Delegating authority to customs brokers
- Viewing customs transactions
- Filing or managing Commercial Accounting Declarations
- Viewing Statements of Account
- Paying duties and taxes
- Enrolling in Release Prior to Payment
- Posting financial security
CARM is therefore not simply a new Canadian customs website.
It has changed the relationship between:
Importer → Customs Broker → CBSA
Latest CARM Requirements for Canadian Importers in 2026
As of 2026, several transition periods that applied when CARM was first introduced have already ended.
For regular commercial imports, importers should therefore operate according to the permanent CARM structure rather than relying on older transition rules.
Important CARM Timeline
| Date | CARM Development |
|---|---|
| October 21, 2024 | CARM became the official system of record for commercial import accounting |
| May 20, 2025 | General RPP transition period ended |
| December 31, 2025 | Several temporary broker-BN transition measures ended |
| January 1, 2026 | New Importer of Record liability provisions came into force |
| January 31, 2026 | General transition relief from late-payment penalties and interest ended |
| 2026 onward | Importers operate under the permanent CARM framework |
The CBSA confirmed that, by January 30, 2026, more than 219,000 businesses had enrolled in CARM, with RPP enrolment covering more than 99% of historical release volumes.
CARM Registration Is Now a Core Part of Canada Customs Clearance
Businesses importing commercial goods into Canada need to establish the correct importer account structure.
A Canadian commercial importer will generally need:
BN9 → RM Program Account → BN15
The BN9 identifies the legal business.
The RM account identifies the business’s CBSA program account.
Together they form what is commonly referred to as the:
BN15
Example format:
123456789RM0001
Commercial imports should use the correct importer or importer/exporter RM account.
CBSA has specifically warned against using an exporter-only BN15 to obtain release or account for imported commercial goods.
What Is the CARM Client Portal?
The CARM Client Portal, often abbreviated as CCP, is the centralized portal through which importers manage their relationship with CBSA.
A company importing goods from China can use the portal to manage:
Business Registration
Register or link the company’s CBSA business information.
Import Program Account
Establish the appropriate RM program account.
Customs Broker Delegation
Authorize a customs broker to transact with CBSA on behalf of the importer.
Release Prior to Payment
Apply for the RPP privilege.
Financial Security
Post or manage the financial security required for RPP.
Customs Accounting
Review Commercial Accounting Declarations and transaction information.
Statements and Payments
Review customs balances and make payments to CBSA.
This is one of the most important differences between the old Canadian customs system and CARM.
Can a Canadian Importer Still Use a Customs Broker?
Yes.
CARM does not eliminate customs brokers.
Canadian importers can still authorize licensed customs brokers to handle customs-related activities.
However, the importer normally needs to register appropriately in CARM and delegate authority to the broker.
CBSA states that customs brokers can continue transacting with CBSA for their clients once the importer has registered and granted the appropriate authority.
This means:
Using a customs broker does not mean the importer can ignore CARM.
The customs broker handles customs operations.
The importer remains responsible for establishing the appropriate account and authorization structure.
The Biggest CARM Change: Importers Need Their Own RPP Security
One of the most important changes for Canadian importers is the Release Prior to Payment program, commonly called:
RPP
RPP allows qualifying importers to receive the release of their imported goods before duties and taxes are actually paid.
Before CARM, many importers effectively relied on a customs broker’s security.
That system has changed.
The general CARM RPP transition ended on May 20, 2025.
Importers that want normal Release Prior to Payment privileges now generally need to:
- Register in CARM
- Enrol in RPP
- Provide their own financial security
There are limited CBSA contingency or specialized exceptions for certain situations, but a normal FCL or LCL importer should not build its customs strategy around these exceptions.
What Happens If an Importer Does Not Have RPP?
An importer can still import goods without RPP.
However, the operational difference is important.
Without RPP privileges, the importer generally needs to account for the shipment using the appropriate C-Type Commercial Accounting Declaration and pay the applicable duties and taxes before the cargo can be released.
CBSA confirmed this requirement when the RPP transition period ended.
For regular container importers, this can make RPP commercially important.
Consider a Canadian company importing:
1 × 40HQ from Qingdao to Vancouver
with a substantial customs value.
If the company wants the container released immediately while customs duties and taxes are settled through its normal monthly account cycle, RPP becomes especially relevant.
How Much CARM Financial Security Is Required?
The amount depends on the importer’s customs account history.
CBSA generally calculates the RPP requirement based on the importer account’s highest monthly accounts receivable balance during the previous 12 months.
For a written financial security agreement, such as an approved security arrangement, the required security is generally:
50% of the calculated requirement
with a minimum written security amount of:
CAD 5,000 per RM account
For a cash deposit, the importer generally needs to post:
100% of the calculated requirement
There is no minimum cash-deposit amount.
The maximum security requirement is generally:
CAD 10 million per RM account.
For a new importer without sufficient customs history, the financial security requirement may initially be based on projected import activity.
Example of CARM RPP Financial Security
Suppose a Canadian importer had a highest monthly customs account balance of:
CAD 40,000
during the previous 12 months.
An illustrative written-security requirement could therefore be approximately:
CAD 20,000
because written financial security generally covers 50% of the requirement.
If the same importer chose to provide a cash security deposit instead, the requirement could be:
CAD 40,000
because cash security generally covers 100%.
The actual requirement shown in CARM should always be used.
What Changed on January 1, 2026? Importer of Record Rules
A major Canadian customs change took effect on January 1, 2026.
Amendments to section 17 of the Canadian Customs Act clarified and expanded liability involving the:
Importer of Record — IOR
The entity identified as the importer of record on CBSA accounting documents can be jointly liable with the importer and owner for duties owing, including certain reassessments after final accounting.
This is extremely important for:
- Canadian importers
- Non-resident importers
- Customs brokers
- DDP sellers
- Overseas suppliers
- Logistics providers
The customs declaration is no longer something that should be treated simply as paperwork completed by the broker.
The BN used for customs accounting and the identity of the Importer of Record matter.
Why the 2026 Importer of Record Rule Matters for DDP Shipping
Many companies in China advertise:
DDP shipping to Canada
But DDP is a commercial delivery term.
It does not remove Canadian customs obligations.
Someone still needs to legally assume the appropriate importer/customs responsibilities.
For a properly structured DDP shipment, the logistics provider needs to determine before shipping:
- Who is the Importer of Record?
- Which BN15 will be used?
- Is the importer registered in CARM?
- Does the customs broker have delegated authority?
- Who is responsible for duties and GST?
- Is RPP required?
- Has financial security been posted?
- Who will receive any customs reassessment?
This has become even more important since January 1, 2026.
A cheap quotation labelled “Canada DDP” without a clear Importer of Record structure can create customs risk later.
Customs Broker BN15 vs Importer’s Own BN15
Under the permanent CARM model, regular commercial importers should generally expect to use the true importer’s own importer BN15 for their commercial importations.
The previous transitional practice that allowed customs brokers to use their own BN15 in certain situations was temporary.
From the CBSA’s perspective, the correct identification of the importer has become increasingly important.
A customs broker can act for the importer.
That is different from automatically becoming the importer.
For routine China-to-Canada commercial freight, importers should therefore establish their CARM account before the shipment reaches Canada.
Commercial Accounting Declaration — CAD
CARM also changed Canada’s customs accounting documentation.
The Commercial Accounting Declaration, or CAD, replaced the former:
B3 Canada Customs Coding Form
and the adjustment process that previously used:
B2 Adjustment Requests.
CBSA now uses the CAD as the digital accounting declaration for commercial imports in CARM.
For importers, the CAD contains important customs accounting information such as:
- Importer BN15
- Broker information
- Tariff classification
- Country of origin
- Value for duty
- Customs duty
- GST
- Other applicable taxes or assessments
Accurate CAD information therefore matters for both immediate clearance and later customs verification.
Canada Customs Clearance Process from China
For a typical commercial shipment from China, the customs process can be understood in several stages.
Step 1 — Confirm the Canadian Importer
Determine who will legally import the cargo.
For example:
Canadian buyer
or an appropriately established:
Non-Resident Importer
depending on the commercial arrangement.
Step 2 — Check CARM and BN15 Status
Before departure, confirm that the importer has the appropriate:
CARM account + BN/RM importer account
Do not wait until the container arrives in Vancouver or Montreal to discover that the importer account cannot be used.
Step 3 — Delegate the Customs Broker
If a customs broker will clear the shipment, the importer should provide the necessary CARM authorization.
This allows the broker to work on behalf of the importer.
Step 4 — Determine RPP Requirements
If the importer wants the goods released before duties and taxes are paid, verify that the importer:
is enrolled in RPP
and has:
sufficient financial security.
Step 5 — Prepare Customs Documents
The required documentation will depend on the cargo, but commercial shipments commonly require:
- Commercial Invoice
- Packing List
- Bill of Lading or Air Waybill
- Product description
- HS classification information
- Country of origin
- Value information
- Importer BN15
- Consignee information
- Permits or certificates where required
Additional requirements can apply to regulated products.
CBSA notes that some products require permits, certificates or inspections from other Canadian government departments before release.
Step 6 — Determine the Correct HS Code
Canada customs duties are determined partly by the product’s tariff classification.
This is why an accurate product description is essential.
For example, descriptions such as:
plastic fence with aluminum posts
are much more useful than simply writing:
fence
Likewise:
aluminum fence panel
is different from:
steel fence panel
or:
WPC composite fence
Tariff classification can change:
- Duty rate
- Permit requirements
- Trade-remedy exposure
- Statistical reporting
- Customs risk
Step 7 — Determine the Value for Duty
Canadian customs duty is generally calculated using the legally determined:
Value for Duty — VFD
The customs value does not always equal the simple factory invoice amount.
Commercial terms, assists, commissions, royalties, transportation treatment and other valuation elements can affect the declared value.
For normal transactions, accurate commercial documentation should be maintained.
Step 8 — Determine Country of Origin
Customs treatment also depends on origin.
Goods manufactured in China will normally be declared with China as the country of origin unless applicable origin rules establish otherwise.
Origin becomes particularly important where:
- Preferential tariffs apply
- Surtaxes apply
- Anti-dumping measures apply
- Countervailing duties apply
- Quotas or special measures apply
Importers should therefore not assume that changing the shipping port or transshipping through another country changes the country of origin.
Step 9 — Customs Release
The customs broker or importer submits the required release information.
CBSA can then:
release the cargo
or select it for:
- Document review
- Customs examination
- Additional information
- Other government agency review
A customs examination does not automatically mean there is a problem with the shipment.
CBSA has the authority to examine imported cargo.
Step 10 — Final Accounting and Payment
The transaction is accounted for through the Commercial Accounting Declaration.
Duties, GST and other applicable customs charges are then reflected in the importer’s CARM account.
Importers with RPP can operate according to the applicable deferred-payment structure.
Importers without RPP generally need to settle duties and taxes before release.
Canada Import Duty on Goods from China
There is no single Canada import duty rate for Chinese goods.
The duty depends primarily on:
- HS classification
- Country of origin
- Customs value
- Applicable tariff treatment
- Special trade measures
A product may have:
0% duty
while another product may have:
6.5%, 8%, 10% or another tariff rate.
Some products can also be subject to:
- Anti-dumping duty
- Countervailing duty
- Surtax
- Excise duty
- Excise tax
- Tariff-rate quota measures
Therefore, a logistics provider should not promise a universal:
“Canada duty is 6.5%.”
For example, the plastic fencing shipment previously handled by BRF may have been assessed at approximately 6.5% under its particular customs classification, but that rate should not automatically be applied to every fence shipment.
How Much GST Is Charged on Imports into Canada?
Most commercial goods imported into Canada are subject to the federal:
5% Goods and Services Tax — GST
at importation.
A simplified example:
Value for duty:
CAD 100,000
Customs duty:
6.5% = CAD 6,500
Simplified value for GST:
CAD 106,500
GST:
CAD 5,325
Total simplified customs duty + GST:
CAD 11,825
This is only an illustration.
Actual customs calculations can also be affected by surtaxes, anti-dumping duties, excise amounts or other assessments.
Can Canadian Companies Recover Import GST?
Potentially, yes.
A GST/HST-registered business that is legally entitled to claim an Input Tax Credit — ITC may be able to recover eligible GST paid on commercial imports, provided the relevant requirements are satisfied.
The CRA confirms that an importer registered for GST/HST may claim an input tax credit for eligible tax paid on imports where the importer meets the required conditions.
This is one reason why correct Importer of Record documentation is important.
The company that wants to recover import GST should ensure the customs and tax structure has been properly established.
CARM Statement of Account and Customs Payments
CARM also centralizes customs account information.
The Statement of Account — SOA is available through CARM and shows the amount owed to CBSA.
CBSA currently makes the monthly SOA available on the 25th of each month.
The agency publishes specific payment due dates for each accounting period.
This is important because another CARM transition measure has now ended.
From January 31, 2026, overdue CARM balances can again be subject to late-payment penalties and interest.
Unpaid amounts may ultimately be transferred for collection action.
Canadian importers therefore need to monitor their CARM account even when a broker is handling daily customs operations.
Non-Resident Importers and CARM
A foreign company can sometimes operate as a:
Non-Resident Importer — NRI
in Canada.
However, a foreign company cannot simply write its Chinese company name on the customs paperwork and assume Canadian importer requirements have been solved.
For a non-resident company needing a Canadian business number, the BN process differs from that of a resident Canadian business.
CBSA guidance indicates that non-resident businesses generally need to obtain the required business number through the appropriate CRA process before completing their CBSA program enrolment through CARM.
This becomes particularly relevant for:
DDP shipping from China to Canada
because the importer structure needs to be established before promising a complete DDP solution.
CARM and DDP Shipping from China to Canada
CARM has made professionally structured DDP shipping more important.
For a typical shipment:
Chinese Factory
↓
China Pickup
↓
Export Customs
↓
Ocean Freight
↓
Vancouver / Montreal / Other Gateway
↓
Canada Customs Clearance
↓
Duties & GST
↓
Canada Inland Transportation
↓
Final Door Delivery
the Canadian import structure should be confirmed before departure.
BRF SHIPPING recommends reviewing at least:
Importer identity
BN15
CARM registration
Broker delegation
RPP status
Financial security
HS classification
Customs value
Estimated duty
Estimated GST
Destination delivery
before providing a complete customs-and-delivery plan.
Customs Clearance Through Vancouver
Vancouver is one of Canada’s principal gateways for containerized imports from Asia.
For shipments from:
- Qingdao
- Shanghai
- Ningbo
- Shenzhen
- Yantian
- Xiamen
Vancouver can serve not only customers in British Columbia but also inland destinations.
For example:
Qingdao → Vancouver → Toronto
or:
Shanghai → Vancouver → Calgary
After customs release, containers can continue inland by suitable rail and trucking arrangements.
This is why Vancouver customs clearance should often be planned together with Canadian inland transportation.
Customs Clearance for Toronto Shipments
Toronto is an inland commercial destination rather than a Pacific container gateway.
China-to-Toronto freight may therefore enter Canada through a gateway such as Vancouver before moving inland, or use another suitable Canadian routing depending on the shipment.
For Toronto-bound containers, BRF SHIPPING recommends evaluating:
Port of entry + customs clearance + inland freight + Toronto final delivery
as one transportation chain.
Looking only at the ocean freight rate can hide a significant portion of the total landed cost.
Common Reasons Canada Customs Clearance Is Delayed
Most customs problems are easier to solve before departure than after arrival.
Common causes can include:
Incorrect Importer Account
The BN/RM structure is not ready or the wrong importer account is used.
No Broker Delegation
The customs broker does not have proper access to act for the importer.
RPP Problem
The importer expects immediate release but does not have valid RPP privileges or sufficient security.
Vague Product Description
Invoice descriptions such as:
parts
accessories
material
or:
fence
may not provide enough information.
Incorrect HS Classification
The selected tariff classification does not accurately match the product.
Customs Value Problems
The invoice value and customs valuation information do not align.
Missing Permit
The goods require authorization from another Canadian government department.
SIMA / Trade Remedy Issues
Certain goods may be subject to anti-dumping or countervailing duties.
Document Differences
Quantities, weights, product descriptions or values differ across the invoice, packing list and shipping documents.
CARM Checklist Before Shipping from China
Before loading a commercial container bound for Canada, importers should ideally confirm:
- CARM account is active
- Correct importer BN15 is available
- Customs broker is authorized
- RPP status is confirmed if required
- Financial security is sufficient
- Product description is accurate
- HS classification has been reviewed
- Country of origin is correct
- Commercial value is supported
- Duty rate has been checked
- GST exposure is understood
- Required permits are available
- Commercial invoice is complete
- Packing list matches the shipment
- Bill of Lading instructions are correct
- Canadian delivery address is confirmed
A five-minute customs check before departure can prevent several days of delay after arrival.
CARM Before and After: What Changed?
| Before CARM | Current CARM Environment |
|---|---|
| Broker security commonly supported release | Importer generally needs its own RPP security |
| B3 customs accounting | Commercial Accounting Declaration |
| B2 adjustment | CAD adjustment |
| Customs information spread across older systems | Centralized CARM account management |
| Broker often controlled much of the import account process | Importer has greater direct account responsibility |
| Less direct importer account visibility | Online CARM transaction and SOA access |
| Older IOR liability framework | Expanded Importer of Record liability effective Jan. 1, 2026 |
This shift is one reason Canadian importers need to become more actively involved in their customs setup.
Frequently Asked Questions About CARM and Canada Customs
Is CARM mandatory for Canadian commercial importers?
CARM is now CBSA’s official commercial import accounting and revenue-management system. Businesses importing commercial goods into Canada should establish the appropriate CARM and importer account structure.
Can my customs broker register everything for me?
A broker can assist with customs activities, but the importer is responsible for its own business/account setup and generally needs to authorize the broker through CARM.
Can I still use my broker’s customs bond?
For ordinary commercial RPP use, importers should generally expect to provide their own financial security. The broad RPP transition ended on May 20, 2025.
Do I need RPP to import into Canada?
Not necessarily.
But without RPP, applicable duties and taxes generally need to be paid before release under the applicable customs process.
What is a BN15?
It combines the Canadian business number with the relevant RM program account and identifies the import account used for CBSA transactions.
What is CAD?
CAD means Commercial Accounting Declaration. It replaced the former B3 customs accounting form and B2 adjustment process under CARM.
What is the Canadian import GST rate?
Most imported commercial goods are subject to 5% GST at importation, subject to exemptions and the specific tax treatment of the goods.
Is customs duty from China always 6.5%?
No.
The applicable rate depends on the HS classification, origin, customs value and applicable tariff or trade measures.
Can a Chinese company act as the importer in Canada?
A non-resident company can potentially establish an appropriate Canadian importer structure, but it needs to meet Canadian registration and customs requirements. This should be established before shipping.
Does DDP automatically solve CARM?
No.
DDP describes the commercial delivery responsibility between seller and buyer. Canadian customs still requires a compliant importer, customs-accounting and payment structure.
BRF SHIPPING Canada Customs Clearance Support
BRF SHIPPING coordinates international transportation between Chinese suppliers and Canadian importers.
For China-to-Canada shipments, our logistics planning can include:
China factory pickup
Warehouse consolidation
Export customs declaration
FCL and LCL ocean freight
Air freight
Shipping documentation coordination
Canada customs-clearance coordination
CARM information review
Import duty and GST planning
Vancouver container arrival
Canada inland rail/truck coordination
Toronto delivery
Door-to-door shipping
Where an importer already has its Canadian CARM and customs structure established, BRF can coordinate transportation with the destination customs process to reduce communication gaps between the Chinese factory, shipping line, customs broker and Canadian delivery provider.
Planning a Shipment from China to Canada?
If you are importing:
- Aluminum fencing
- Plastic fencing
- WPC products
- Aluminum gates
- Building materials
- Machinery
- Fitness equipment
- Furniture
- Industrial products
- Commercial equipment
- Wholesale goods
send BRF SHIPPING:
Product name
Material
HS code if available
Commercial value
Chinese pickup location
Packages
CBM
Gross weight
Container type
Canadian destination/postal code
Importer CARM status
We can then evaluate the logistics route and identify customs information that should be prepared before shipment.
For Canada, reliable door-to-door logistics begins with understanding the importer structure before the cargo leaves China.
BRF SHIPPING — China to Canada Freight, Customs Coordination and Door Delivery.
