Importer of Record in Canada
Canada’s import framework changed fundamentally on two dates that every foreign shipper must now account for. On 21 October 2024, the CARM system became the permanent platform for customs accounting, retiring the legacy B3 form entirely. On 1 January 2026, amendments to Section 17 of the Customs Act took effect, making the entity named as importer of record on the Commercial Accounting Declaration jointly and severally liable for all duties, taxes, and reassessed amounts. Without CARM Client Portal registration and posted RPP financial security, goods cannot be released prior to payment. Compounding this, Canada’s 25% retaliatory surtaxes on US-origin steel, aluminium, vehicles, and nearly 1,800 additional HS codes remain in force, adding a layer of landed cost exposure that must be confirmed per HS code before quoting.
Carra Globe acts as your Importer of Record in Canada, holding the Business Number and RM import account, managing CARM Client Portal registration and RPP security, filing Commercial Accounting Declarations, handling CUSMA and CPTPP preference claims, coordinating GST/HST registration and recovery, and managing OGD permits so your cargo clears on first submission.
Importer of Record in Canada
An Importer of Record in Canada is the legally accountable entity identified on the Commercial Accounting Declaration (CAD) at the time goods are accounted for with the Canada Border Services Agency (CBSA). Since January 1, 2026, the entity named as IOR on the CAD is jointly and severally liable alongside the importer and owner for all duties, taxes, and reassessed amounts arising from CBSA verifications.
The structural requirement for foreign companies is a Canadian Business Number (BN) with an RM import account and active registration in the CARM Client Portal (CCP). CARM became the permanent framework from 21 October 2024, with all transition measures ending December 31, 2025. Without CCP registration and posted financial security, goods cannot be released prior to payment. Carra Globe removes this barrier, holding the BN and RM account, managing CCP registration and RPP security, and standing as the accountable importer on every CAD so your company can ship DDP into Canada without a local entity.
Why Companies Use Carra Globe as Their Importer of Record in Canada
Canada’s compliance framework combines a newly permanent customs accounting system, joint liability for the named IOR, an active trade dispute with the United States, and multi-agency regulatory requirements that must all be resolved before cargo arrives. CARM registration and RPP financial security are prerequisites for release prior to payment. The Section 17 liability amendments mean the named IOR carries real financial exposure on every declaration. Canada-US surtaxes at 25% on steel, aluminium, vehicles, and nearly 1,800 additional HS codes require per-code confirmation before quoting landed cost.
Beyond customs, products regulated by Health Canada, CFIA, ECCC, or Global Affairs Canada require OGD permits that CBSA will enforce at the border. ACI eManifest filing is mandatory across all transport modes with mode-specific advance deadlines. GST at 5% applies on all commercial imports and must be registered and recovered through the CRA. Carra Globe manages all of these before cargo departs.
When You Need IOR Services in Canada
Working with an Importer of Record in Canada becomes necessary when no Canadian entity exists and your company cannot or does not wish to register as a Non-Resident Importer directly, when your Canadian recipient lacks a BN, CCP registration, or RPP security, when DDP obligations require a single party accountable for all entry costs, when goods are regulated by Health Canada, CFIA, Transport Canada, or Global Affairs Canada, when claiming CUSMA or CPTPP preferences with origin documentation ready for CBSA audit, or when importing goods subject to Canadian surtaxes or SIMA anti-dumping measures requiring classification before departure.
Common Hold in Canada & How Carra Globe Prevents Them
The most frequent causes of holds at Canadian ports follow a consistent pattern: importer not registered in the CARM Client Portal, no BN15 RM import account, RPP financial security not posted, incorrect 10–digit HS code triggering wrong duty rates or missed SIMA measures, CUSMA preference claimed without valid certification of origin, US-origin surtax not identified, ACI eManifest not accepted before loading or departure, OGD permit absent for regulated products, customs value understated, and SIMA duties not declared on CAD. Every one of these results in a hold, penalty, or duty reassessment that cannot be resolved quickly at the border.
Carra Globe prevents these by verifying compliance before cargo moves, covering CARM registration and RPP security, BN15 confirmation, HS classification with SIMA and surtax checks, CUSMA origin documentation, ACI coordination, OGD permit verification, customs valuation review, and CAD filing accuracy.
Canada Trade & Compliance Framework (2026)
CBSA, CARM & the Commercial Accounting Declaration
The Canada Border Services Agency (CBSA) administers customs, border security, and import compliance. CARM is Canada’s permanent platform for customs accounting and duty payment, fully in force since 21 October 2024 with all transition measures concluded December 31, 2025. All commercial accounting is now via the Commercial Accounting Declaration (CAD), the legacy B3 and B2 forms having been retired. The CAD is submitted electronically via EDI/API or through the CARM Client Portal, with a paper exception (BSF946) available only when electronic submission is genuinely unavailable.
Every commercial importer must hold a Business Number (BN) from the Canada Revenue Agency and an RM import/export sub-account (BN15) from CBSA. Release Prior to Payment (RPP) requires enrolment via the CCP with posted financial security, either a surety bond or cash deposit equal to at least 50% of the highest monthly duty liability. Importers without RPP must pay all duties before release.
Section 17 Customs Act liability (in force 1 January 2026): the entity named as IOR on the CAD is jointly and severally liable for all duties and taxes including reassessed amounts. This applies equally to Canadian-resident importers and Non-Resident Importers. The IOR remains legally responsible for declaration accuracy even when a licensed customs broker files on their behalf. CBSA records must be retained for six years.
Canadian Customs Tariff & Free Trade Agreements
Canada applies a 10-digit HS classification under the Canadian Customs Tariff. The correct code determines the MFN duty rate, applicable preferential treatment, and any OGD permit requirements. CUSMA provides 0% duty on qualifying goods from the US and Mexico. No specific certificate of origin form is required; a certification statement with nine required data elements on an invoice or accompanying document is sufficient. CUSMA is scheduled for mandatory joint review with a target date of July 1, 2026, politically significant given the 2025 Canada-US trade dispute.
Canada-US trade dispute (2025–2026): Canada imposed 25% retaliatory surtaxes on a broad range of US-origin goods from early 2025. As of early 2026, surtaxes remain on steel, aluminium, vehicles, and nearly 1,800 HS codes, applied in addition to MFN or CUSMA rates. Surtaxes are based on where goods were produced, not purchased. Goods made in a third country but purchased through a US intermediary are not subject to the surtax if origin is demonstrated.
CPTPP provides preferential rates on imports from Japan, Australia, New Zealand, Singapore, Vietnam, Chile, Peru, Brunei, Malaysia, and the UK (accession December 2024). Canada also holds FTAs with the EU (CETA), South Korea, Ukraine, Honduras, Panama, Colombia, Jordan, Israel, and others. Anti-dumping and countervailing duties under the Special Import Measures Act (SIMA) apply on specific goods where CBSA or the Canadian International Trade Tribunal has made a finding. Steel, solar panels, and certain agricultural and chemical products are commercially significant. SIMA duties must be confirmed per HS code and origin before importation.
GST/HST & Canadian Sales Tax
GST is levied at 5% on the duty-paid value of all commercial imports, collected by CBSA at the border regardless of destination province. In HST provinces, the combined rate applies at domestic sale, not at import. Ontario applies 13%, Nova Scotia, New Brunswick, PEI, and Newfoundland & Labrador apply 15%.
GST paid at import is recoverable as an Input Tax Credit (ITC) on the importer’s GST/HST return using the CAD as proof. Without a valid CAD, the CRA may deny the claim. GST/HST registration threshold is CAD $30,000 of taxable supplies in any four consecutive quarters. Non-resident businesses supplying digital services or goods in Canada are often required to register regardless under the simplified regime. Non-Resident Importers can register for a GST/HST number to charge, collect, and claim ITCs.
De minimis thresholds: goods from US or Mexico via courier, CAD $150 for duties, CAD $40 for taxes. All other origins, CAD $20. Commercial consignments assessed per shipment.
Advance Commercial Information (ACI) & eManifest
ACI eManifest is a mandatory CBSA pre-arrival reporting requirement for all modes. Carriers must transmit data electronically before arrival: highway at least 1 hour before border crossing, air at least 4 hours before arrival (or at departure for shorter flights), marine 24 to 96 hours before arrival depending on cargo type and voyage duration, rail equivalent pre-arrival requirements.
ACI data must be accepted by CBSA before highway carriers load freight for Canada. Late, incomplete, or inaccurate filings result in AMPS penalties and may trigger physical examination on arrival.
Other Government Departments (OGD) — Regulated Goods
Health Canada regulates drugs, medical devices, natural health products, food additives, cosmetics, and controlled substances, requiring pre-market authorisation or import notification. CFIA requires phytosanitary or veterinary health certificates and import permits for plants, animals, and food. ECCC requires permits for chemicals, hazardous substances, and ozone-depleting substances under CEPA. Global Affairs Canada (GAC) governs controlled goods and dual-use technology under the Export and Import Permits Act (EIPA). Transport Canada enforces TDG requirements for dangerous goods across all modes. OGD holds can last days to weeks. Permit status must be confirmed before departure.
Duty Rates & Tax Structure
Electronics and IT hardware: most at 0% MFN under ITA commitments, accessories 0 to 8%. Machinery and industrial equipment: 0 to 8%, many at 0%. Textiles and apparel: 17 to 18% MFN from non-CUSMA origins, 0% under CUSMA for qualifying goods. Vehicles and automotive parts: variable, CUSMA provides significant benefits. Food and agricultural products: variable, supply-managed categories (dairy, poultry, eggs) subject to high over-quota rates. Steel and aluminium (US-origin): 25% surtax in addition to MFN. GST: 5% on duty-paid value. Excise duties on alcohol, tobacco, and cannabis under Excise Act 2001. Under DDP, the seller settles duties, GST, and clearance costs. Under DAP, the consignee handles all entry charges.
Canada Import Documents Checklist
- Commercial Invoice (10-digit HS code, transaction value, full description, country of origin, Incoterms)
- Canada Customs Invoice (CCI), required for shipments over CAD $3,300
- Packing List
- Bill of Lading, Air Waybill, or CMR consignment note
- Certification of Origin (CUSMA, CPTPP, or other FTA preference claims)
- ACI eManifest, filed by carrier or freight forwarder before arrival
- Commercial Accounting Declaration (CAD), filed via CARM Client Portal
- Health Canada Drug Establishment Licence or Medical Device Licence
- CFIA import permit or phytosanitary/veterinary health certificate
- ECCC permit or CEPA notification (chemicals, hazardous substances)
- EIPA import permit from Global Affairs Canada (controlled goods, strategic technology)
- TDG documentation (safety data sheet, UN number, packing group, ERG reference)
- CITES permit (endangered species and derived products)
- Excise documentation (alcohol, tobacco, cannabis)
- SIMA declaration on CAD where applicable
Product Categories Requiring Special Attention in Canada
Carra Globe’s IOR services are tailored to industries that rely on precision, speed, and reliability.
Canada Customs Clearance Lead Times
- Standard commercial cargo with CCP registration: 1 to 3 business days
- CBSA examination or intensive inspection: 3 to 7 additional business days
- CFIA inspection for regulated products: 1 to 5 additional business days
- Health Canada OGD hold for unlicensed products: days to weeks, pre-authorisation essential
- CARM Client Portal registration and RPP security posting: allow 1 to 2 weeks for first-time registrations
- CUSMA post-entry verification by CBSA: up to 4 years post-importation, origin records must be retained
Lead times depend on CBSA examination decisions, OGD resolution, documentation completeness, and CCP registration status. CARM registration, RPP security, and HS classification must be confirmed before departure.
Carra Globe already holds every licence, certification, and approval listed above so your cargo moves without any delay.
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Carra Globe services in Canada
Carra Globe provides Importer of Record in Canada (IOR), Exporter of Record (EOR), DDP shipping coordination, BN/RM import account registration, CARM Client Portal setup and management, RPP financial security posting, Commercial Accounting Declaration filing, Canadian Customs Tariff classification, CUSMA and CPTPP preference management, GST/HST registration and input tax credit recovery, ACI eManifest coordination, OGD permit and licence support (Health Canada, CFIA, GAC, ECCC), SIMA anti-dumping compliance, Non-Resident Importer programme structuring, freight forwarding (air, sea, highway, rail), and last-mile delivery coordination across Canada.
Frequently Asked Questions — Canada IOR & DDP Shipping
Can I ship to Canada on DDP terms without a Canadian entity?
Yes, through Canada’s Non-Resident Importer (NRI) programme. A non-Canadian business can register a BN and RM account, enrol in CCP, and act as IOR. Carra Globe can structure and manage NRI registration on your behalf or act as the IOR directly, depending on volume and operational preference.
What is CARM and what changed on January 1, 2026?
CARM is the permanent system for customs accounting, replacing legacy B3 and B2 forms with the CAD. All transition measures expired December 31, 2025. From January 1, 2026, all importers must be registered in CCP with RPP financial security for release prior to payment, and Section 17 places joint and several liability on the named IOR for all duties and reassessments.
What is Release Prior to Payment (RPP)?
RPP allows goods to be released before duties are paid. Without RPP enrolment and posted security (surety bond or cash deposit of at least 50% of highest monthly duty liability), all duties must be paid before release. A customs broker’s bond cannot be used for RPP since May 2025.
How does CUSMA preference work?
CUSMA provides 0% duty on qualifying US and Mexican goods. No specific certificate form is required; a certification statement with nine data elements on the invoice or a separate document is sufficient. Must be held at declaration and retained six years. CBSA verifies up to four years post-importation. CUSMA origin also determines surtax exposure for US-origin goods.
What surtaxes apply to US-origin goods in 2026?
A 25% surtax applies to US-origin steel, aluminium, vehicles, and goods across nearly 1,800 HS codes, in addition to standard rates. Based on where goods were produced, not purchased. Third-country goods purchased through a US intermediary are not subject if origin is demonstrated.
What are OGD requirements?
Health Canada, CFIA, ECCC, and GAC each regulate specific product categories. CBSA holds goods flagged as OGD-regulated until the importer presents required authorisation. Holds can last days to weeks. Permit status must be confirmed before departure.
Can Carra Globe handle IT and data centre imports into Canada?
Yes. HS classification, CUSMA preference confirmation, CAD filing via CARM, GST/HST registration and ITC recovery, ACI coordination, ISED type approval for telecoms, and GAC EIPA verification for encryption-capable or dual-use technology.
