Here is a situation we see constantly. A US or international company needs to send equipment to Canada. It might be laptops on long-term loan to a client’s staff, demo units, or tools that stay the company’s property and are never sold. With no sale and no money changing hands, it feels simple. Then the shipment sits in customs for a week or more, and the company finds out the hard way that the goods still triggered Canada’s CARM requirements, and nobody was registered to clear them.
This guide explains why loaned and no-sale equipment can still fall inside Canada’s commercial import framework, how CARM registration and Release Prior to Payment apply, what changed to importer liability on 1 January 2026, and how a properly authorised third party offering importer of record (IOR) services may let you ship into Canada without registering for CARM yourself.
The Short Answer, at a Glance
- No sale does not mean no CARM. Goods imported for business or commercial use are commercial goods, even when they are loaned, not sold, and remain your property.
- CARM is fully in force. Since 20 May 2025, an importer that wants goods released before duties are paid must post its own financial security in CARM. A broker’s security no longer covers it.
- The named importer carries real exposure. Since 1 January 2026, section 17(3) of the Customs Act makes the importer of record jointly liable with the owner and importer for duties, including reassessed amounts.
- You may not have to be that party. A third party authorised to act as importer of record can hold the CARM registration, business number and security, though you still supply accurate information, valuation, permits and records.
- The return leg is covered too. If loaned equipment later leaves Canada, an exporter of record can handle the outbound movement.
Why Loaned and No-Sale Equipment Still Triggers CARM
The most common and most costly assumption is that CARM only applies when goods are sold. It does not. The test is not whether money changes hands. The test is whether the goods are commercial.
Under Canadian customs rules, commercial goods are goods imported for sale or for any business, industrial, commercial or occupational use. A laptop shipped to a client’s employee for work is a commercial good, even though it is on loan, was never sold and remains the shipper’s property throughout. Such goods generally enter through the commercial import framework, subject to any temporary importation or other special procedure that applies.
This is exactly where companies get caught. They treat a no-sale shipment as a formality, ship it under their own name, and only then discover that being the importer means a CARM Client Portal account, a business number and financial security before release. Until that is in place, the shipment waits. In our operational experience, loaned equipment can be held for a week or more when the importer and release structure are not arranged before dispatch. Our guide on how late is too late to appoint an importer of record covers the timing.
What Changed Under CARM, and Why It Matters More Now
For years, importing into Canada was something your customs broker quietly handled. You shipped the goods, the broker cleared them under its own business number and bond, and you paid the invoice. That era has ended, in three stages worth knowing.
- 21 October 2024, registration. CARM launched as the CBSA’s official accounting system, and commercial importers had to register in the CARM Client Portal.
- 20 May 2025, security. The transition period for financial security ended. Importers using Release Prior to Payment must now post their own security in CARM, as a deposit or through a bond with a security provider.
- 1 January 2026, liability. Section 17(3) of the Customs Act came into force, making the importer of record jointly liable for duties.
Brokers can still account for goods and act for an importer where authorised. What changed in May 2025 is that the security obligation now sits with the importer, not the broker.
The January 2026 change is the bigger one for liability. Under section 17(3), the person identified as importer on the customs accounting declaration is jointly liable with the owner and the importer for all duties, including amounts reassessed later. The CBSA’s memorandum D17-2-5 says it can pursue the parties jointly or individually if the importer of record defaults.
In plain terms, if your company is named as the importer, it carries that exposure, and the exposure follows the entry if the CBSA reassesses it. It applies equally to Canadian residents and non-resident importers, so being based outside Canada does not reduce it. Our guide to the 2026 CARM liability changes for the importer of record goes further, and the importer of record versus customs broker guide explains why the role cannot simply be handed to a broker.
The Non-Resident Importer Route, and Why Many Companies Avoid It
Canada does allow a foreign company to import in its own name as a non-resident importer. A non-Canadian business can obtain a business number, register in the CARM Client Portal, post financial security and act as its own importer of record. For a company with steady, high-volume Canadian imports, that can make sense.
For a company sending a handful of loaned or no-sale shipments a year, it is usually more than it wants to take on. It means getting a business number from the Canada Revenue Agency, enrolling in the CARM Client Portal, posting and maintaining security that scales with import value, and managing monthly statements of account.
Records add another layer. Under memorandum D17-1-21, importers keep records for six years at a place of business in Canada. A non-resident can instead name an agent in Canada, or ask to keep records in the United States or Mexico, but either way it needs a signed BSF900 agreement with the CBSA.
That is a lot of standing compliance infrastructure for occasional shipments of equipment you are not even selling. This is where a third-party importer of record becomes the practical answer.
How a Third-Party Importer of Record Lets You Skip CARM Registration
The CBSA’s memorandum D17-2-5 confirms that authorised agents, customs brokers included, can take on the importer of record role under the direction of the importer or owner. The party identified as importer of record has to be properly authorised and accept the CARM, duty, tax, recordkeeping and reassessment obligations that come with it.
In practice, the third-party importer holds the business number and the CARM Client Portal account, posts and maintains the financial security, is named on the accounting declaration, and carries the section 17(3) exposure for the entry. You ship the goods and it clears them. You do not register with the Canada Revenue Agency, build a CARM account or post security yourself.
Be precise about what this does and does not do. It removes the registration burden that caused the delay. It does not remove your own responsibilities. The goods still need correct classification, a defensible value and any permits that apply, and the owner and importer keep obligations of their own. What changes is that an authorised party handles the entry and stands behind it, rather than your shipment waiting at the border while you scramble to register.
One practical check before you appoint anyone is to ask for the provider’s Canadian structure and which party will actually appear on the accounting declaration. Not every company marketing IOR services can take that role for every shipment. Our Canada IOR compliance guide for IT imports lists more of the questions to ask.
Shipping loaned or no-sale equipment to Canada and want to avoid registering for CARM yourself? Carra Globe can act as your importer of record in Canada, so the CARM registration, security and importer liability sit with an authorised party rather than with you. Talk to us about your Canada shipment
Valuing No-Sale Goods for Customs
One question always comes up with loaned equipment. If there is no sale, what value goes on the customs paperwork? A value is still required, because duties, taxes and the declaration are all based on it.
For no-sale goods, the customs value still has to be set under the applicable Canadian valuation method. With no sale for export to Canada, the transaction value method often does not apply. The value may instead rest on identical or similar goods, deductive or computed value, depreciation, purchase records or lease terms, depending on the facts. A fair market or resale estimate can support the analysis, but it is not automatically the right value.
The key point is that a no-sale shipment is not a zero-value shipment. Declaring zero invites problems, so a capable importer of record will help set and document a defensible value under the right method. Classification matters as much, and our HS code finder is a quick first check.
For goods that will not stay in Canada, there is another route to ask about. Where equipment will be re-exported, check whether tariff item 9993.00.00, an ATA Carnet or another temporary importation procedure applies. The CBSA sets out tariff item 9993.00.00 in memorandum D8-1-1 and carnets in memorandum D8-1-7.
Eligibility depends on the goods, their use, the importer, security, identification, a time limit and proof of re-export, so long-term loans do not always qualify. Temporary admission can reduce or remove duty, but it does not automatically remove every accounting, permit, tax or CARM obligation. Our comparison of an ATA Carnet, a temporary import bond and an importer of record sets out the trade-offs.
For permanent imports, our guide on how to reduce import duty into Canada covers the levers that do apply. Because temporary importation can change the cost of a loaned equipment shipment materially, raise it with your importer of record early.
Getting the Equipment Back Out, the Return Leg
Loaned equipment has a feature sold goods do not. It usually has to come back. When a device on long-term loan is replaced or returned, the old unit has to leave Canada, and that outbound movement has its own requirements.
This is where an exporter of record matters. Just as an importer of record is accountable for goods entering a country, an exporter of record provider can coordinate the outbound customs and export control responsibilities for goods leaving it. The exact filings depend on the origin, destination, goods and export rules, so having one partner run both legs keeps the paperwork consistent. If you swap a new device in and ship an old one back, plan the return at the same time as the inbound. Our guide to IOR and EOR for returned goods and reverse logistics covers this in more depth.
What to Do Before You Ship to Canada
- Do not assume no sale means no CARM. Goods for business or commercial use generally enter through the commercial import framework, subject to any temporary importation or other special procedure. Confirm the route before the shipment moves.
- Decide who the importer of record will be. Either register as a non-resident importer yourself, with everything that involves, or appoint a third-party importer of record that is already set up.
- Set a defensible customs value. Use the applicable Canadian valuation method and document the basis. Zero is not acceptable just because no sale occurred.
- Plan the return leg up front. If loaned equipment will come back out, arrange the exporter of record role at the same time.
- Check temporary import relief before choosing a permanent import. Tariff item 9993.00.00 or an ATA Carnet may reduce or remove duty for goods that will be re-exported.
- Confirm any permits or restrictions. Some equipment needs extra clearances whoever imports it. Check before shipping.
How Carra Globe Helps
Carra Globe acts as your Canadian importer of record for loaned, no-sale and company-owned equipment, so you can ship without registering for CARM yourself. You continue to provide accurate product, valuation, permit and record information. For equipment that has to return, we can also act as exporter of record for the outbound leg.
Carra Globe works through importer-side registrations and local importing structures appropriate to the goods and destinations it accepts, its own in some markets and established local structures in others. Approvals falling outside the available structure are flagged before a delivery date is agreed. Our focus is high-value IT and technology hardware, including the loaned device, no-sale and demo unit cases that trip companies up at the Canadian border. Reach us at info@carraglobe.com.
Frequently Asked Questions
Does CARM apply if I am not selling the goods?
Yes. CARM applies to commercial goods, which include goods imported for business use, not only goods that are sold. Loaned, demo and company-owned equipment for business use still triggers it.
Can I import into Canada without registering for CARM myself?
Yes, by appointing a third party authorised to act as importer of record. It holds the CARM account and security, though you still supply accurate information, valuation, permits and records.
Do I need a Canadian business number to ship loaned equipment to Canada?
Only if you act as your own importer of record. A non-resident importer gets its business number from the Canada Revenue Agency. If a third-party importer clears the goods, it uses its own.
Why did my no-sale shipment get held at Canadian customs?
Often because no importer was set up in CARM to release it. Since 20 May 2025, release before payment needs the importer’s own financial security posted in CARM.
What value do I declare for goods that are not being sold?
A value is still required. With no sale for export, the transaction value method may not apply, so the value is set under another Canadian valuation method. Zero is not acceptable.
Who is liable if something is wrong with the customs declaration?
Under section 17(3) of the Customs Act, the importer of record is jointly liable with the owner and importer for duties, including reassessed amounts. The CBSA can pursue them jointly or individually.
Sources and verification
- CARM launch and security. CBSA, financial security transition period ending 20 May 2025, which also records the 21 October 2024 launch.
- Importer of record liability. CBSA memorandum D17-2-5, Duty Liability of Importer of Record, on section 17(3) from 1 January 2026.
- Records. CBSA memorandum D17-1-21, Maintenance of Records in Canada by Importers.
- Temporary importation. CBSA memorandum D8-1-1 on tariff item 9993.00.00 and memorandum D8-1-7 on ATA Carnets.
Disclaimer. This guide is educational and does not constitute legal or customs advice. CARM requirements and the rules on commercial goods, valuation and importer liability change over time and depend on your circumstances. The position described is as at 13 October 2026. Confirm your obligations with a qualified trade compliance partner or the Canada Border Services Agency.