De minimis thresholds for duty and tax remission
Canada operates a de minimis regime under which low-value shipments may be imported without payment of customs duties and, depending on the threshold met, excise taxes (including the Goods and Services Tax (GST), Harmonized Sales Tax (HST), and Provincial Sales Tax (PST)). The operative thresholds and the applicable tax relief depend on the mode of transport and, in the case of courier shipments, the country of direct export.
Courier shipments: CUSMA-enhanced thresholds from the United States or Mexico. Section 4.1 of the Courier Imports Remission Order (CIRO), SI/85-182, as amended by SI/2020-34 effective July 1, 2020, implements Canada's obligations under Article 7.8(1)(f) of the Canada–United States–Mexico Agreement (CUSMA). For goods imported from Mexico or the United States that are transported by courier, remission is granted of:
- (a) customs duties paid or payable, if the goods have a value for duty of CAD $150 or less; and
- (b) excise taxes paid or payable, if the goods have a value for duty of CAD $40 or less.
The term "courier" is defined in section 2 of the CIRO as "a commercial carrier that is engaged in scheduled international transportation of shipments of goods other than goods imported by mail." Critically, goods do not need to originate from a CUSMA Party to benefit from the higher thresholds; however, they must be shipped from the United States or Mexico and the goods must have entered into the commerce of either Party prior to shipment to Canada. Goods that are merely transshipped via the United States or Mexico—that is, goods that do not enter the commerce of those countries—are subject to the lower CAD $20 threshold set out in section 4 of the CIRO.
Courier shipments from all other countries. Section 4 of the CIRO, as amended by SI/92-128, grants remission of customs duties and excise taxes in respect of imported goods, other than goods imported from Mexico or the United States, that are transported by courier and have a value for duty of CAD $20 or less. This CAD $20 threshold remains the baseline for courier shipments from countries other than the United States and Mexico.
Mail shipments. The Postal Imports Remission Order (PIRO), SI/85-181, provides a remission regime parallel to the CIRO. Section 4 of the PIRO, as amended by SI/92-129, grants remission of customs duties and excise taxes paid or payable on goods imported by mail and having a value for duty not exceeding CAD $20. The CUSMA-enhanced thresholds do not apply to postal shipments; mail imports from the United States and Mexico remain subject to the CAD $20 threshold.
Excluded goods. Section 2 of both the CIRO and the PIRO defines "goods" to exclude the following categories, which are therefore ineligible for de minimis remission even if they fall below the relevant value thresholds:
- (a) alcoholic beverages, cannabis products, vaping products, cigars, cigarettes, and manufactured tobacco;
- (b) goods classified under tariff item No. 9816.00.00 in the List of Tariff Provisions (casual goods previously exported from Canada) and goods for which the value for duty is reduced by the application of section 85 of the Customs Tariff (goods subject to drawback or refund); and
- (c) goods that are imported by a person other than the person in Canada who ordered or purchased the goods (shipments through intermediaries or freight forwarders).
Anti-avoidance: shipment-splitting prohibition. CBSA Memorandum D8-2-16 affirms that to receive the benefit of the CIRO, the total shipment must be subject to a single transaction. It is not acceptable to divide a shipment into several packages so that individual shipments have a value for duty below the thresholds prescribed in the CIRO. If the value for duty of the shipment exceeds the thresholds, customs duties are applicable to the entire value of the shipment in accordance with the Customs Tariff. The transaction-aggregation rule prevents an importer from artificially fragmenting a single order to fall under the de minimis ceiling.
Claim procedure. If the benefit of remission is not received at the time of importation, section 5 of the CIRO and PIRO provides that remission is granted on condition that a claim for remission is made to the Minister of National Revenue. Post-importation, CBSA may request source documentation to substantiate the claim, which may include a commercial invoice, Canada Customs Invoice, or proof of payment.
Intersection with other programs. The de minimis remission regime is distinct from—and may be claimed in conjunction with—the low-value shipment (LVS) threshold of CAD $3,300, which governs simplified reporting, release, and accounting procedures but does not convey duty or tax remission. Section 7(2)(a) of the Accounting for Imported Goods and Payment of Duties Regulations, SOR/86-1062, expressly permits certain goods to be released without a requirement of accounting if the goods are within the scope of the Postal Imports Remission Order or the Courier Imports Remission Order.
Source: Courier Imports Remission Order, SI/85-182 Source: Postal Imports Remission Order, SI/85-181 Source: CBSA Memorandum D8-2-16, Courier Imports Remission Source: Accounting for Imported Goods and Payment of Duties Regulations, SOR/86-1062
Customs bonded warehouses — licensing, storage limits, and duty deferral
Customs bonded warehouses (CBWs) are privately operated facilities licensed and regulated by the Canada Border Services Agency (CBSA) under the Customs Bonded Warehouses Regulations, SOR/96-46, made pursuant to sections 91–100 of the Customs Tariff. A CBW permits importers to store imported goods — and to consolidate imported and domestic goods destined for export — without payment of customs duties, excise duties, or taxes (including GST/HST) for the period the goods remain in the warehouse. Duty and tax deferral is complete for goods subsequently exported; duties and taxes become payable only on goods released for entry into the Canadian domestic market.
Licensing authority and application. Section 3(1) of the Regulations provides that the Minister of Public Safety and Emergency Preparedness may issue a licence to a person to operate a bonded warehouse if the applicant (a) provides such security as may be required under subsection 91(4) of the Customs Tariff and in accordance with section 4 of the Regulations, and (b) meets the requirements of section 3(4), which include that the Canada Border Services Agency is able to provide customs services with respect to the proposed bonded warehouse. An application for a licence must be submitted in the prescribed form (CBSA Form E401) together with a detailed plan of the proposed bonded warehouse indicating whether the place exists or is to be constructed, the type of construction, and the area within the place to be used for storage of goods (section 3(2) and (3)). Both Canadian residents and non-residents may apply to operate a CBW; applicants may operate a private bonded warehouse (for storage of their own imported goods) or a public bonded warehouse (for storage of goods imported by various importers).
Security requirement. Section 4 of the Regulations, as amended by SOR/2024-41, provides that security must be provided in accordance with the requirements of the Financial Security (Electronic Means) Regulations. CBSA policy (Memorandum D7-4-4) specifies that operators of a customs bonded warehouse must post security of, at minimum, 60% of the maximum total amount of duties and taxes payable at any time following the issuance of the licence. Security is payable to the Receiver General for Canada.
Maximum storage period: four years. Imported goods may be stored in a customs bonded warehouse for up to four years from the date the goods are first accounted for on the Commercial Accounting Declaration (CAD). This limit is set out in section 2(b) of the Storage of Goods Regulations and confirmed in CBSA Memorandum D4-1-7, "Extension of Time Limits for the Storage of Goods." Exceptions to the four-year limit are outlined in Schedule II to the Storage of Goods Regulations; these exceptions include, among others, goods held by auction houses for sale by auction, certain cultural or heritage goods, and vehicles subject to safety or emissions certification processes. Upon written request, the CBSA may extend the maximum storage time limit for goods held in a customs bonded warehouse pursuant to subsection 37(3) of the Customs Act, where extenuating circumstances preclude the removal of unclaimed goods (with the exception of tobacco products, packaged spirits, and vaping products) within the specified time limits. Extensions are considered on a case-by-case basis and must be requested prior to the expiration of the specified time limit.
Allowable activities and manipulation. The Customs Bonded Warehouses Regulations permit certain activities to be performed in a CBW that do not change the condition of the goods. Section 20 of the Regulations, as incorporated by reference in licence terms and conditions, allows goods to be manipulated, unpacked, packed, altered, or combined with other goods only for the purpose or in the course of specific operations listed in the Schedule to the Regulations, including: disassembling or reassembling goods that have been assembled or disassembled for packing, handling, or transportation; displaying, inspecting, or testing goods; ticketing goods with origin information or price; marking, labelling, tagging, or otherwise preparing goods for shipment or sale; packing and unpacking; cleaning, preserving (by the application of preservative, lubricants, protective encapsulation, freezing, drying, or freeze-drying, provided the condition of the goods is not changed), maintaining, and repairing goods; sorting, grading, trimming, filing, slitting, and cutting goods; diluting or blending goods with domestic or imported goods; and removing a small quantity of material, a portion, a piece, or an individual object that represents the goods, for the sole purpose of soliciting orders. Section 20 expressly provides that goods in a CBW shall not be further manufactured. Item 3 of the Schedule contains special provisions allowing goods to be held for marking purposes or display at conventions, exhibitions, or trade shows for up to 90 days, after which the goods must be either exported from or entered (accounted for under section 32 of the Customs Act) in Canada.
Restrictions on certain goods. Section 15 of the Regulations prohibits licensees from receiving into or removing from a bonded warehouse imported tobacco products, or imported packaged spirits or wine, unless the goods are to be removed for sale to a foreign diplomat in Canada, export from Canada, sale to a duty-free shop, or use as ships' stores (and, in the case of spirits or wine, supply to an air carrier licensed under the Canada Transportation Act to operate an international service). Section 16.1, added by SOR/2019-70, prohibits licensees from receiving into or removing from a bonded warehouse imported vaping products unless they are to be removed for sale to a foreign diplomat in Canada or export from Canada.
Suspension and cancellation of licence. Section 8(1) of the Regulations provides that the Minister of Public Safety and Emergency Preparedness may suspend or cancel a licence where the licensee (a) is the subject of a receivership; (b) fails to comply with any Act of Parliament, or any regulation made pursuant to an Act of Parliament, that prohibits, controls, or regulates the importation or exportation of goods; (c) has acted dishonestly in business dealings with customs brokers, importers, carriers, or Her Majesty; (d) has not met any of the requirements set out in sections 11 and 12 (which govern storage, identification, and control of goods within the bonded warehouse); or (e) has been incompetent in the operation of the bonded warehouse. Section 8(2) further permits the Minister to cancel a licence where (a) the volume of goods being received is no longer sufficient to warrant continued operation; (b) there is no longer a need for a bonded warehouse in the area; (c) the CBSA is no longer able to provide customs services; or (d) the licensee manipulates, unpacks, packs, alters, or combines goods while in the bonded warehouse other than in accordance with the terms and conditions set out in the licence. Section 9(1) provides that immediately after suspending a licence, the Minister must give the licensee a notice that confirms the suspension and provides all relevant information concerning the grounds for the suspension. Where a licence is suspended, an officer may lock and seal the bonded warehouse and keep it locked and sealed during the period of suspension (section 8(3)).
Operator liability for duties. Section 28(1) of the Customs Act provides that the operator of a bonded warehouse is liable for all duties or taxes levied under the Customs Tariff, the Excise Act, the Excise Act, 2001, the Excise Tax Act, the Special Import Measures Act, or any other law relating to customs on goods that have been received in the warehouse unless the operator proves (a) that the goods were delivered to the importer or owner or to a person authorized by the importer or owner; (b) that the goods were exported in accordance with the Customs Act; or (c) that the goods were destroyed under such conditions as may be prescribed.
Integration with other government departments. All goods being entered into a CBW are considered to be imported into Canada and are required to meet all other government department requirements and conditions (such as permits, authorizations, waivers, and rulings under the Participating Government Agencies (PGA) regime). Goods subject to Tariff Rate Quotas (TRQs) must present the required documentation upon entry; goods without permits or authorization may not be allowed to enter a customs bonded warehouse. This requirement is confirmed in CBSA Memorandum D7-4-4, which states that the CBW program does not waive the import-control requirements of other Acts of Parliament.
Source: Customs Bonded Warehouses Regulations, SOR/96-46 Source: CBSA Memorandum D7-4-4, Customs Bonded Warehouses Source: CBSA Memorandum D4-1-7, Extension of Time Limits for the Storage of Goods Source: Customs Act, R.S.C., 1985, c. 1 (2nd Supp.), s. 28
Duty drawback — refund on exported goods
Canada's duty drawback program permits importers, exporters, processors, and owners of goods to claim a refund of customs duties, excise duties, and anti-dumping / countervailing duties (but not the Goods and Services Tax / Harmonized Sales Tax (GST/HST)) paid on imported goods that are subsequently exported from Canada. Drawback operates as post-export duty recovery, distinct from the Duties Relief Program (which grants upfront exemption from duty at the time of importation for goods that will later be exported) and from customs bonded warehouses (which defer duty while goods remain in the warehouse). The statutory framework is set out in section 113 of the Customs Tariff, S.C. 1997, c. 36, and is operationalized through the Goods Imported and Exported Refund and Drawback Regulations, SOR/96-42.
Statutory authority. Section 113(1) of the Customs Tariff grants a refund or drawback of "all or a portion of duties" if (a) relief or a refund of all or a portion of the duties could have been, but was not, granted under section 89 or 101 of the Act at the time of importation. Section 89(1) describes the scenarios in which relief may be granted, and section 113(1) extends those scenarios to circumstances where the importer paid duties at the time of entry but the goods subsequently satisfy one of the export-related conditions. Section 113(2) authorizes the Governor in Council to make regulations prescribing (among other matters) the portion of duties that may be granted as a drawback, the persons or classes of persons who may apply, the time within which an application must be made, goods that are considered to be "of the same class" or "in the same condition," and restrictions as to classes of goods for which a drawback may be granted.
Eligible scenarios. Under the Goods Imported and Exported Refund and Drawback Regulations, SOR/96-42, Part I (sections 3–14.1) applies to the grant of a drawback under subsection 113(1) of the Customs Tariff in respect of imported goods described in subsection 89(1) of the Customs Tariff, other than goods in respect of which the Exported Motor Vehicles Drawback Regulations apply (section 3 of the Regulations). Section 89(1) of the Customs Tariff identifies five categories of imported goods for which relief (or, retrospectively, drawback) may be granted:
- (a) Goods imported for processing or further manufacturing, that are exported in the same condition (other than incidental alterations such as repacking or displaying, inspecting, or testing);
- (b) Goods that are consumed, expended, or absorbed directly in the processing or manufacture in Canada of goods that are subsequently exported—often called "duty drawback on inputs" or "further manufacture";
- (c) Domestic or imported goods that are used or consumed in the processing or manufacture in Canada of other goods that are subsequently exported, provided the domestic or imported goods are of the same class as imported goods on which duties were paid;
- (d) Imported goods that are exported in the same condition but for which identical, equivalent, or similar domestic goods or imported goods of the same class were substituted (the "substitution drawback" mechanism); or
- (e) Identical, equivalent, or similar domestic goods or imported goods of the same class that are used or consumed in the processing or manufacture of other goods subsequently exported, and for which imported goods on which duties were paid may be treated as having been consumed (the "substitution + consumption" drawback).
"Same class" for domestic and imported goods is defined in section 11 of the Regulations: goods are considered to be of the same class if they are "so similar that they may be used interchangeably in the processing or manufacture of other goods."
Eligible claimants. Section 9(1) of the Regulations provides that a drawback may be claimed by any person who is the importer or exporter of the imported or exported goods, or is the processor, owner, or producer of those goods between the time of their direct shipment to Canada and their export or deemed export. Section 9(2) provides a special restriction: in the case of spirits, wine, or beer described in paragraph 89(1)(b) of the Customs Tariff (goods consumed directly in production of exported goods), a drawback may be claimed only by the importer of the goods. Section 119 of the Customs Tariff further requires that an application for drawback must be accompanied by a waiver, in the prescribed form, from every other person eligible to claim a drawback, to prevent double recovery.
Application deadline. Section 8 of the Regulations, as amended by SOR/2020-64, provides that an application for a drawback must be made within four years after the date on which the imported goods were released. This four-year limitation is a statutory ceiling; late applications are not accepted. CBSA Memorandum D7-4-2, last updated November 24, 2025, confirms this four-year window and specifies that applications are now submitted via the CARM Client Portal (CBSA's Assessment and Revenue Management system).
Documentation and proof of export. The application for drawback must be accompanied by supporting documents demonstrating that the conditions prescribed in the Act and Regulations have been satisfied, which may include (but are not limited to) a copy of the export sales invoice and proof of exportation (Memorandum D7-4-2, paragraphs 7–10). Acceptable proof of exportation is described in CBSA Memorandum D20-1-4, Proof of Exports, Canadian Origin and Destruction of Commercial Goods, and typically consists of a stamped export declaration, carrier waybill, or customs-certified export document from the destination country. For goods that are merely transferred between Duties Relief Program participants (certificate holders), a transfer certification is used, but export documentation is required at the time the goods ultimately leave Canada.
Exclusion for goods damaged before export. Section 4 of the Duties Relief Regulations, SOR/96-44 (which applies by cross-reference to the drawback regime), provides that relief—and by extension drawback—may not be granted in respect of the imported goods where the exported goods are damaged before being exported. This exclusion prevents recovery on goods that have lost value due to damage that occurred while in Canada.
Exclusions for certain goods classes. Section 5 of the Duties Relief Regulations provides that, for purposes of paragraphs 89(1)(c) and (e) (the "same class" and substitution scenarios), relief may not be granted in respect of the goods described in Schedule I to the Regulations, which enumerates specific tariff headings or categories of goods that are ineligible for substitution drawback. (Schedule I includes, among others, certain motor vehicles, textile and apparel articles, and agricultural products subject to tariff-rate quotas.)
CUSMA (formerly NAFTA) restrictions: the "lesser-of" rule. When imported goods (or substitutes) are used as materials in the production of other goods that are subsequently exported to the United States or Mexico and that benefit from preferential tariff treatment under CUSMA (the Canada–United States–Mexico Agreement), section 113 drawback and section 89 relief are subject to CUSMA Article 5.7 restrictions. CBSA Memorandum D7-4-3, CUSMA Requirements for Drawback and Duty Deferral Programs, explains that the drawback or relief of customs duties shall not exceed the lesser of (a) the total amount of customs duties paid or owed on the imported goods when imported into Canada, and (b) the total amount of customs duties paid on the goods when imported into the United States or Mexico. This "lesser-of" calculation prevents a CUSMA Party from refunding more duty than the importing CUSMA country collected. The CUSMA drawback restrictions do not apply to goods that originate in a CUSMA Party under Chapter 4 (Rules of Origin) of CUSMA, nor to goods exported to non-CUSMA countries. Similar restrictions apply under other Canadian free-trade agreements that include drawback-limitation articles, including CETA (with the European Union), CUKTCA (with the United Kingdom), and CPTPP.
GST/HST exclusion. Section 2 of Memorandum D7-4-2 and paragraph 30 of the French-language version of the same memorandum confirm that the Goods and Services Tax / Harmonized Sales Tax (GST/HST) cannot be refunded through the duty drawback mechanism. Importers seeking recovery of GST/HST on exported goods must apply to the Canada Revenue Agency under the Excise Tax Act and its GST/HST rebate provisions (typically a GST/HST rebate for exports or the Input Tax Credit mechanism).
Interest on late payment of drawback. Section 127 of the Customs Tariff (as referenced in sections 114 and 115 of the Customs Tariff) provides that any person who receives a drawback of duties other than duties levied under the Special Import Measures Act (AD/CVD duties) is entitled to interest at the prescribed rate, calculated from the 91st day after the CBSA receives the application and ending on the day the drawback is granted. For drawbacks of AD/CVD duties, interest accrues at the prescribed rate for each month or part of a month from the 91st day after the CBSA receives the application until the day the drawback is granted (Memorandum D7-4-2, paragraphs 29–30).
Repayment obligation if ineligible. Section 114(1) of the Customs Tariff imposes a statutory obligation on any person who receives a refund or drawback and is subsequently found not to be eligible for all or part of it: the person must pay to His Majesty in right of Canada, on the day the refund or drawback is received, (a) any amount for which the person is not eligible, and (b) any interest granted under section 127 on that amount. While the amount remains unpaid, it is deemed to be a debt owing to His Majesty under the Customs Act (section 114(2)).
Source: Customs Tariff, S.C. 1997, c. 36, s. 113 Source: Goods Imported and Exported Refund and Drawback Regulations, SOR/96-42 Source: Duties Relief Regulations, SOR/96-44 Source: CBSA Memorandum D7-4-2, Duty Drawback Program (updated November 24, 2025)
Release prior to payment (RPP) — enrolment, financial security, and operational requirements
Release Prior to Payment (RPP) is an optional sub-program of the CBSA Importer Program that permits importers to obtain release of goods before paying customs duties and taxes, provided they post adequate financial security with the Canada Border Services Agency. RPP is the standard operating procedure for most commercial importers in Canada; without it, importers must submit a CAD Type C (cash entry) and pay all duties and taxes at the port of entry before goods are released. RPP authorization shifts the payment deadline from the moment of release to the monthly statement-of-account (SOA) payment due date, which falls on the last business day of the month following the billing period, enabling importers to obtain goods immediately and defer payment by up to approximately 60 days.
Enrolment and financial security requirement. To enrol in RPP, importers must provide financial security at the importer program account level (the BN15 RM account) and in the legal entity name registered against the business number. Enrolment is complete when an approved form of financial security meeting CBSA requirements has been accepted (CBSA Memorandum D17-1-8, paragraph 2; Memorandum D17-5-2, paragraph 2). The amount of security required is calculated by the CBSA and equals the highest monthly accounts-receivable balance (including customs duties, excise duties, GST/HST, and special-import-measures duties) over the preceding 12 months for the RM account in question (Memorandum D17-1-8, paragraph 15). The 12-month review period runs from July 25 of the prior year to July 24 of the current year (Memorandum D17-1-8, paragraph 24).
Importers who exclusively import goods unconditionally free of duties and taxes are not required to post financial security to maintain RPP enrolment; however, if the CARM system subsequently determines that duties or taxes are owed on a transaction, the importer will be required to post security or make a payment before further releases are authorized (Memorandum D17-1-8, paragraph 19; CBSA Customs Notice 25-22, paragraph 6).
Forms of security. The CBSA accepts two primary forms of financial security under the Financial Security (Electronic Means) Regulations, SOR/2024-42, which came into force on October 21, 2024 as part of CARM Release 3:
- Written Security Agreement (surety bond or financial-institution bond), which must be posted in an amount equal to at least 50% of the CBSA-calculated requirement, with a minimum of CAD $5,000 per RM account. The bond is provided by a CBSA-approved security provider (surety company, bank, trust company, or loan company) and is electronically transmitted to CARM via API. The 50% threshold reflects the fact that bonds provide the CBSA with recourse against the surety or financial institution in the event of default.
- Security deposit (cash deposit), which must be posted at 100% of the CBSA-calculated requirement. There is no minimum for a deposit, but deposits do not benefit from the 50% reduction applicable to bonds. Deposits are posted directly in the CARM Client Portal (CCP) by the importer.
Both forms of security are subject to a ceiling of CAD $10 million per RM account for all forms of security combined (Memorandum D17-1-8, paragraph 16). In exceptional circumstances where it is impracticable for an importer to provide electronic security due to circumstances outside the importer's control, the CBSA may approve non-electronic forms of financial security on a case-by-case basis; approval requests must be submitted to the CBSA RPP Financial Security inbox (Memorandum D17-5-2, paragraph 6).
CARM transition and current status. CBSA Assessment and Revenue Management (CARM) Release 3 was implemented on October 21, 2024, and introduced mandatory importer-provided financial security for RPP participants. Prior to CARM, many importers relied on their licensed customs broker's security to obtain release. Under CARM, importers must post their own security or elect to pay cash at the time of release. The CBSA granted a 180-day transition period during which importers enrolled in the Importer Program could benefit from RPP without posting security (pursuant to the Regulations Amending Certain Regulations Administered and Enforced by the Canada Border Services Agency, SOR/2024-178, subsection 69(2)). This transition period was extended by 30 days and ended on May 20, 2025 at 3:00:01 a.m. EDT (CBSA Customs Notice 25-22, paragraph 3). As of that date, importers without adequate financial security on file are not eligible for release using interim accounting service options (IID, PARS, or paper RMD) and must instead submit a CAD Type C (full accounting declaration) and pay all duties and taxes before release (Customs Notice 25-23, paragraph 2).
Security monitoring and utilization thresholds. Importers enrolled in RPP must ensure that the total security coverage is always higher than the account net open balance (debts minus available credits). The CARM system sends automated notifications to the importer when the utilization rate reaches 75% and 100% of posted security (Memorandum D17-5-2, paragraphs 9–10). When the net open balance meets or exceeds 100% of the posted security, the importer must either make a payment to reduce the outstanding balance or post additional security; failure to do so will result in suspension of RPP privileges, and the importer will be unable to obtain release without paying cash at the time of entry. Security levels are monitored continuously by the CBSA in the CARM system, and failure to comply with security requirements may also result in suspension or revocation of the release privilege and may trigger an Administrative Monetary Penalty (AMP) assessment (Memorandum D17-1-8, paragraph 25).
Annual security review and adjustments. CBSA recalculates the required security amount annually based on the importer's highest monthly accounts-receivable balance over the prior 12 months. Importers may request a modification (reduction or increase) of the system-calculated security requirement through the CARM Client Portal before the end of the annual review period (July 24); the CBSA may require supporting evidence to approve a reduction request (Memorandum D17-5-2, paragraph 8.4). Requests submitted after the end of the review period or after removal from the RPP program during the transition period are treated as new requests and must include updated rationale (Customs Notice 25-22, paragraph 12).
Liability and demand on security. The security holder (whether the importer or the customs broker providing the bond) is liable for payment of all debts recorded on the customs account that were covered by the financial security during its effective period (Memorandum D17-5-2, paragraph 15). The CBSA may initiate a demand against the security provider after reasonable attempts to collect from the debtor have failed or when the debtor has filed for bankruptcy or receivership. For Written Security Agreements (bonds), the CBSA may demand payment up to one year after the termination or expiry date of the bond, but only for debts incurred prior to the termination date (Memorandum D17-5-2, paragraph 17). For security deposits (cash), the CBSA will withhold a sufficient portion of the deposit to cover the amount owing (Memorandum D17-5-2, paragraph 15.2).
Alternative for non-RPP importers: cash entries. Importers who do not participate in the RPP program are required to pay duties and taxes at the time of release. Such importers must present a Commercial Accounting Declaration Type C (CAD-C or "cash entry") and make payment at the CBSA office where the goods are released (Customs Notice 25-22, paragraph 7; Memorandum D17-5-1). Payment may be made by electronic means, cheque, or—in exceptional circumstances and with prior CBSA approval—bank remittance. Non-resident importers may authorize a licensed customs broker to make payments on their behalf.
RPP Contingency Plan (broker-assisted release for time-sensitive or health-essential goods). Effective May 20, 2025, the CBSA reinstated a limited RPP Contingency Plan to address release of time-sensitive/perishable goods and goods deemed necessary to support an individual's continued health and well-being when the true importer lacks RPP privileges. Under the contingency plan, licensed customs brokers may use a special "RPP Contingency" BN15 (backed by the broker's own cash security deposit) to obtain release on behalf of such importers, provided the broker has not been delegated CARM Client Portal authority by the importer and the goods meet the contingency eligibility criteria. The broker must include the true importer's name, BN15, and street address in the IID release transmission. The contingency plan is temporary and will end upon notice by the CBSA (Customs Notice 25-23, paragraphs 8, 15).
Source: CBSA Memorandum D17-1-8, Release Prior to Payment Privilege (October 21, 2024) Source: CBSA Memorandum D17-5-2, Financial Security for Release Prior to Payment (October 21, 2024) Source: Financial Security (Electronic Means) Regulations, SOR/2024-42 Source: CBSA Customs Notice 25-22, End of Release Prior to Payment (RPP) Transition Period Source: CBSA Customs Notice 25-23, CARM RPP Contingency Plan
Post-entry corrections (Customs Act s. 32.2), Customs Notice 26-03 (2026) mass correction procedures, and the Voluntary Disclosures Program (VDP)
Import compliance does not end at the moment of release. Recent updates in 2025–2026 materially affect post-entry correction and mass adjustment filing. Canada’s Customs Act continues to impose an ongoing obligation to self-correct import declarations, and the CBSA has updated both statutory form requirements and agency procedures for filing large-scale corrections effective February and June 2026.
Correction obligation — Customs Act s. 32.2 (as amended 2026) Section 32.2 of the Customs Act requires every importer to make a correction if, within four years after accounting (release) of goods, they become aware that their import declaration was incorrect or incomplete with respect to tariff classification, value for duty, or origin. The Act was amended (in force June 5, 2026) to update the required format and manner of correction. Corrections (“B2 adjustments” or Detailed Adjustment Statements) must now be made in accordance with the prescribed form and electronic method as set by regulation or direction, and submitted within 90 days of discovery of the error (s. 32.2(1)(a), (2)). Filing is via the CARM Client Portal, as mandated by the new regulations, regardless of whether the entry was broker-filed or self-filed. The obligation covers corrections that would result in either overpayment or underpayment of duty or tax. Corrections unrelated to tariff classification, value for duty, or origin (such as program eligibility or permits) are excluded from this requirement.
New mass correction protocol — Customs Notice 26-03 (February 2026) Effective February 2, 2026, CBSA has imposed new procedures for mass B2 correction requests exceeding 999 transactions. Under Customs Notice 26-03, filers must pre-register mass corrections using the Notice’s workbook templates, submit via the CARM Client Portal, and provide specific supporting documentation. The Notice supersedes relevant instructions in D17-2-1 for mass corrections until D17-2-1 is revised. Failure to follow the new protocol may result in processing delays, rejection, or monetary penalties (AMPs).
Voluntary Disclosures Program (VDP) — Memorandum D11-6-4 (2025) The Voluntary Disclosures Program remains available for importers seeking penalty relief on contraventions discovered outside the formal correction window, or for non-revenue errors and pattern violations. A qualifying disclosure must still be (1) voluntary, (2) complete, (3) penalty-relevant, and (4) concern past contraventions. VDP cannot be used after notification of CBSA enforcement, nor for retroactive program claims, nor for criminal matters. Application must be made to the CBSA Recourse Directorate, with all relevant documents. If accepted, penalties may be reduced or canceled, but duties and taxes are still due.
Consequences of failure to correct: Failure to correct under the Act, follow mass correction protocols, or make a qualifying VDP may expose the importer to Administrative Monetary Penalty System (AMPS) penalties, interest, and possible enforcement action by CBSA.
What changed in 2025–2026?
- Statute amended: Customs Act s. 32.2 as of June 5, 2026 (now prescribes the manner/form of correction; electronic filing via CARM is mandatory).
- Mass corrections: Customs Notice 26-03 (February 2, 2026) governs mass adjustment submissions until D17-2-1 is updated.
- VDP remains as previously stated; D11-6-4 current as of 2025.
Source: Customs Act, R.S.C. 1985, c. 1 (2nd Supp.), s. 32.2 (current to June 2026) Source: CBSA Customs Notice 26-03, Filing Procedures for Mass B2 Correction Submissions (Feb. 2, 2026) Source: CBSA Memorandum D17-2-1, Corrections to Declarations of Origin, Tariff Classification, and Value for Duty Source: CBSA Memorandum D11-6-4, Relief of Interest and/or Penalties Including Voluntary Disclosure (VDP)
Low Value Shipment (LVS) procedures — CAD $3,300 threshold and operational requirements
Canada's Low Value Shipment (LVS) program allows commercial importers to clear qualifying goods under a simplified process when the value for duty does not exceed CAD $3,300 per shipment. The LVS threshold is set in accordance with CBSA Memorandum D17-4-0 and is codified in operational agency practices, not directly stipulated in the Customs Act or Regulations. The LVS streamlines importation for e-commerce, mail-order, and courier transactions, but does not grant duty or tax remission—that is covered separately by the de minimis regime (see above).
LVS eligibility criteria:
- The value for duty of the shipment must not exceed CAD $3,300 (excluding freight, insurance, and other post-export costs).
- The goods must not be subject to restrictions, controls, or other agency requirements (such as permits, certificates, or release documentation under other government department regulations). LVS is not available for goods subject to anti-dumping/countervailing duties, SIMA measures, or prohibited/restricted goods as per D19 memorandum series.
- Shipments must be imported for commercial purposes. Casual (personal) shipments may proceed through separate simplified procedures handled by the courier or postal service.
LVS process and documentation:
- For qualifying shipments, importers or customs brokers may submit a Simplified Entry Process using the electronic IID (Integrated Import Declaration) or the legacy paper B3 form with the "LVS" code.
- Full commercial invoices or Canada Customs Invoices are not always required. Essential data elements include: value for duty, country of origin, brief description, importer name/address, and all declared quantities. Additional supporting documents must be available on request for CBSA review.
- LVS goods are released at the first port of arrival, provided the required information is electronically submitted and no risk indicators or examination triggers are present.
LVS and de minimis regimes distinguished:
- The LVS threshold governs simplified procedure – not automatic duty/tax relief. Duty/tax remission depends on whether the shipment simultaneously satisfies the separate Courier or Postal Imports Remission Orders and their thresholds (see "de minimis thresholds"). It is common for a shipment to qualify for LVS but not for de minimis relief, and vice versa.
Operational restrictions and review:
- Where multiple shipments on the same day to the same consignee exceed the CAD $3,300 threshold in aggregate, CBSA may exclude those shipments from LVS if they appear intentionally split to evade full entry requirements (anti-avoidance under D17-4-0).
- LVS shipments remain subject to post-entry verification, review, and assessment; misuse or consistent misdeclaration may result in penalties under the Administrative Monetary Penalty System (AMPS).
Recent developments:
- The CAD $3,300 threshold has remained stable since June 2020, having been established to align with e-commerce and trade environment changes following CUSMA implementation. The current process and automation frameworks are summarized in D17-4-0 (April 2021 update).
Source: CBSA Memorandum D17-4-0, Release of Commercial Goods
Sufferance warehouses — regime, entry processing, and operational requirements
Sufferance warehouses are facilities licensed by the Canada Border Services Agency (CBSA), governed primarily under the Customs Sufferance Warehouses Regulations (SOR/86-1065, previously miscited as SOR/2003-237) and supporting CBSA memoranda (notably D4-1-4), to provide temporary storage of imported goods upon arrival in Canada and pending release or further transfer. Sufferance warehouses serve as the initial port-of-entry holding points—distinct from customs bonded warehouses, which permit long-term duty deferral and manipulation for re-export.
Types of sufferance warehouses and licensing CBSA recognizes several classes of sufferance warehouses based on location and function: marine, air, rail, highway, and courier, as detailed in sections 3–8 of the Regulations and section 2 of Memorandum D4-1-4. Each type has defined operational limits (e.g., marine warehouses: waterfront within 6.5 km of a customs office; air: at/adjacent to the airport). Warehouse operators must apply for and maintain a CBSA license, meeting minimum security, insurance, and operational requirements. Licences are issued at the discretion of the Minister of Public Safety and Emergency Preparedness and may be suspended or cancelled for non-compliance (Regulations s. 14–15).
Permitted activities and restrictions Goods may be held in a sufferance warehouse only for the period necessary to complete import reporting, inspection, and release processes. Beyond minor handling (removal, sorting, weighing, marking for identification, and separating damaged goods), no further processing or manufacturing is allowed. The Regulations expressly prohibit commingling of unreported with reported goods and restrict unauthorized access to the premises.
Maximum retention periods Retention limits on goods are set by type: most goods must be released or transferred within 40 days of arrival; otherwise, they may be considered unclaimed and subject to seizure or disposal (Customs Act s. 37.1, Regulations s. 11, D4-1-4 para 26–29). Certain goods (e.g., in-transit shipments, seized goods) have special timelines or procedures.
Liability and security The warehouse licensee is strictly liable for all goods received and is responsible for securing the premises against loss or unauthorized removal, maintaining records as prescribed, and complying with all CBSA access and reporting requirements (Regulations s. 16; D4-1-4 para 61–65).
Closure, suspension, and CBSA access Failure to comply with licensing, operational, or security requirements may result in suspension or cancellation of the warehouse license. CBSA officers have the right of access at any time to examine goods, records, or the premises (Customs Act s. 98, Regulations s. 17).
Source: Customs Sufferance Warehouses Regulations, SOR/86-1065, consolidated to May 26, 2026 Source: CBSA Memorandum D4-1-4, Customs Sufferance Warehouses
Importer of Record (IOR) obligations — eligibility, compliance, and the Non-Resident Importer (NRI) regime
Importer of Record (IOR) — definition and responsibility Under the Canadian Customs Act, the "importer of record" (IOR) is the party legally responsible for ensuring imported goods comply with all statutory requirements, including accurate declaration, payment of duties and taxes, and maintenance of supporting records. Section 2(1) of the Customs Act defines "importer" as "the person who reports goods under section 12 of the Act or on whose behalf a customs broker does so." Ultimately, the IOR can be any individual or entity that causes goods to enter Canada, files the required declarations, and undertakes compliance with CBSA requirements.
Eligibility — residents and non-residents Canada's framework is notable in that both residents and non-residents may serve as the importer of record. The CBSA specifically permits a "Non-Resident Importer" (NRI)—an entity that does not have a physical presence in Canada but who sells to Canadian customers—to act as the IOR by registering for a Business Number (BN15) with the Canada Revenue Agency. The NRI takes on all the same legal obligations as a resident importer: correct reporting and accounting under Customs Act sections 12 and 32, timely payment of duties/taxes, and record-keeping for six years following importation (Customs Act s. 40).
IOR obligations detail:
- Accurate declaration (Customs Act s. 12, 32): Reporting the goods at arrival, providing a true and complete accounting (CAD or simplified entry for LVS/de minimis), and ensuring tariff classification, value, and origin are correct at time of entry.
- Duty and tax remittance (Customs Act s. 32, s. 35): Payment of all applicable customs duties, excise duties, GST/HST, and SIMA duties if any.
- Record-keeping (Customs Act s. 40): Retaining all import transaction records, correspondence, classification rulings, and payment evidence for six years and making them available to CBSA upon request.
- Post-entry compliance: Corrections (s. 32.2) and voluntary disclosures if non-compliance is later discovered. Liability for AMPS penalties or seizure in case of misstatement or omission.
Non-Resident Importers — regime and benefits CBSA Memorandum D17-1-8 provides that companies outside Canada wishing to ship directly to Canadian customers may register as Non-Resident Importers. This allows the NRI to retain control over the import process, set landed cost for customers, and serve as the declarant and tax remitter for entry purposes. The NRI must obtain a BN15 identifier and is subject to all physical record retention and audit requirements as if resident. Failure to meet these obligations can result in penalties, suspension of import privileges, and goods seizure.
Liability and address for service Regardless of residential status, the IOR is personally liable for all correct declaration, payment, and compliance steps. The CBSA requires a Canadian address for service of notices and (for NRIs) that the NRI be reachable for compliance or enforcement actions (D17-1-8 section 5; Customs Act s. 44–46).
Source: Customs Act, R.S.C., 1985, c. 1 (2nd Supp.), ss. 2, 12, 32, 40, 44–46 Source: CBSA Memorandum D17-1-8, Release Prior to Payment Privilege
Administrative Monetary Penalty System (AMPS) — regime, contraventions, and penalty amounts
Canada’s Administrative Monetary Penalty System (AMPS) is the primary enforcement regime for non-compliance with customs legislation and CBSA (Canada Border Services Agency) requirements. It applies to contraventions of the Customs Act, Customs Tariff, and related regulations in the context of imports, and is designed to promote voluntary compliance by commercial importers, carriers, and warehouse operators.
Framework and scope. AMPS was established by regulation under the Customs Act, with contraventions and penalty amounts set out in the Administrative Monetary Penalties (AMPs) Regulations, SOR/2002-221. CBSA operationalizes this through a detailed, public list of AMPS Contravention Codes and assigns penalties administratively rather than through criminal proceedings. Importers can be penalized for errors in tariff classification, value for duty declarations, origin claims, late accounting, failure to maintain records, improper use of programs (LVS, RPP), and other operational failures. Common examples include C080 for incorrect tariff classification, C152 for failure to account for goods, and C157 for late payment of duties.
Penalty structure. AMPS imposes monetary penalties by contravention and occurrence, with the amount escalating for subsequent violations within a set period (usually 5 years).
- Penalties are typically structured in three levels: first, second, and third or subsequent occurrence, for most contraventions. For example, C152 (failure to account for goods) carries a penalty of CAD $500 for the first, $750 for the second, and $1,500 for each subsequent.
- Some contraventions are calculated per instance or per day, others by transaction, and certain breaches (e.g., record retention) may be fined per shipment or per month in breach.
- Maximum AMPS penalties vary by contravention, with a published ceiling (e.g., C157: late payment, $100–$2,000 per occurrence).
Process and recourse. When an infraction is detected, CBSA issues a Notice of Penalty Assessment (NPA) to the party responsible. An importer has 90 days from receipt of the NPA to request a Ministerial review using CBSA Recourse Directorate procedures. Penalty amounts are payable unless overturned or reduced upon review; failure to pay can result in suspension of import privileges, seizure, or withholding of goods.
AMPS vs. other enforcement. AMPS runs alongside criminal sanctions for severe offenses (e.g., smuggling) but is intended for administrative violations. Penalties can be assessed in addition to duties and taxes owing, with interest on unpaid amounts accruing under the Customs Act.
Official reference: The full table of contravention codes and penalty levels is maintained in the CBSA Master Penalty Document and on individual contravention pages, and is updated frequently. Importers should regularly review these lists, as both codes and penalty amounts can change with CBSA policy updates.
Source: Administrative Monetary Penalties (AMPs) Regulations, SOR/2002-221, as administered by CBSA Source: CBSA AMPS Contraventions (example: Contravention C026)
Duties Relief Program — upfront duty exemption for goods intended for export or further manufacture
Canada’s Duties Relief Program permits authorized importers, processors, and manufacturers to import goods without paying customs duties or certain taxes, provided the goods are subsequently (a) exported in the same condition, (b) used as inputs in the manufacture of exported goods, (c) used in repair or processing of goods for export, or (d) transferred under prescribed conditions to other participants or eligible exporters. This is an upfront suspension or exemption regime—distinct from duty drawback, which provides a refund only after the export of duty-paid goods. The statutory foundation is found in sections 89–101 of the Customs Tariff and operationalized by the Duties Relief Regulations (SOR/96-44) and associated CBSA memoranda (notably D7-4-1 and D7-4-3).
Eligibility and application: Any person (including non-resident importers) may apply to the CBSA for a certificate of participation. The applicant must demonstrate the intent and capacity to either export the imported goods, incorporate them into goods for export, or supply to another certificate holder for such purposes. The application is made using Form K90, per CBSA Memorandum D7-4-1, and must include supporting business and process documentation.
Permitted activities and timelines: Eligible activities include storage, manipulation, manufacture, further processing, assembly, and repair, provided the end product is exported or supplied to another program participant within four years of import (Duties Relief Regulations s. 3(3)(b)). Certain substitutions—using same-class or equivalent goods, including domestic and imported—are permitted under strict documentary requirements (s. 4 and s. 5), but only if they are used interchangeably in exported goods. Detailed inventory management controls and traceability between import, processing, and export are required, subject to CBSA audit at any time.
Prohibitions and exclusions: The program is not available for certain goods, including (a) those subject to supply-managed Tariff Rate Quotas (TRQs), (b) goods with processing restrictions or licensing requirements, (c) goods later diverted to the Canadian market (which triggers retroactive duty liability and potential penalties), and (d) most goods to be exported to CUSMA (US/Mexico) and other FTA partners with active drawback/relief restrictions—these require careful review due to the so-called “lesser of two duties” rule (CBSA D7-4-3, meaning the refund or relief amount is capped at the lower of duties paid in Canada vs. collected by the importing FTA country).
Key compliance obligations: Participants must maintain audit-ready records of all imports, uses, transfers, and exports for at least six years following exportation or supply (recordkeeping begins at time of export or supply); provide monthly or periodic compliance reports if requested; and immediately pay duties and applicable interest for any goods lost, destroyed (without CBSA supervision), or diverted into Canadian commerce. The program imposes stringent traceability and substitution rules to prevent abuse—the CBSA closely monitors for over-claiming, loss of material identity, and unauthorized domestic diversion.
Links to other relief programs: Duties Relief operates in parallel to (but is not merged with) the Drawback Program and Customs Bonded Warehousing. Imported goods entered under Duties Relief may be transferred to a bonded warehouse or to other relief program participants under proper documentation—missteps in chain-of-control or reporting can trigger penalties.
2026 currency and practical note: As of June 2026, all applications, transfers, and most participant maintenance are managed via the CARM Client Portal. CUSMA, CETA, and CPTPP have continued to restrict relief for exports to certain FTA partners, requiring vigilant FTA-specific review before applying the program to North American or EU-bound supply chains.
Source: Customs Tariff, S.C. 1997, c. 36, ss. 89–101 Source: Duties Relief Regulations, SOR/96-44 Source: CBSA Memorandum D7-4-1, Duties Relief Program Source: CBSA Memorandum D7-4-3, CUSMA Requirements for Drawback and Duty Deferral Programs
Final accounting and payment deadlines — Customs Act s. 32, CARM Statement of Account, and payment methods
After release of goods by the Canada Border Services Agency (CBSA), importers are required to complete accounting and payment of duties and taxes within set statutory deadlines. Under section 32(1) of the Customs Act, importers must “account for the goods and pay duties” within the period prescribed by regulation after release by CBSA. For most commercial imports, the Accounting for Imported Goods and Payment of Duties Regulations (SOR/86-1062), section 6(3), set the deadline at “on or before the 30th day after the day on which the goods are released.” “Release,” as defined in the Customs Act, means the moment CBSA clears the goods—not when the importer physically receives them.
With implementation of the CARM (CBSA Assessment and Revenue Management) Client Portal, commercial importers now manage accounting and payment through the Portal. CARM issues a Statement of Account (SOA) for each importer on the 25th of every month. The payment due date is the 10th business day after the 17th of the month, per CBSA operational policy. While this harmonized billing schedule may allow up to nearly 60 days to pay for entries released early in the previous cycle, the statutory minimum accounting and payment deadline established by s. 6(3) of SOR/86-1062 remains binding and is not superseded by CARM’s payment calendar. Importers must ensure compliance with the 30-day regulatory requirement; the CARM billing cycle does not override the statutory obligation.
Late or missed payment after the regulatory deadline places the account in debt status, accrues interest under Customs Act section 33, and may result in suspension of release privileges as well as AMPS (Administrative Monetary Penalty System) penalties. AMPS penalty code C157, for example, applies to late payment of duties or taxes. Permitted payment methods under CARM include pre-authorized debit, online banking, and credit card (for balances within set limits); all payments must be credited to the correct RM (importer) account to avoid holds or compliance risk.
Exceptions to the 30-day rule may apply for certain specified goods or authorized periodic payment arrangements, but these must be expressly established in accordance with the regulations (SOR/86-1062). Importers are responsible for monitoring their monthly SOA, understanding which deadlines apply, and ensuring all payments satisfy both statutory minimums and CARM administrative deadlines.
Source: Customs Act, R.S.C., 1985, c. 1 (2nd Supp.), s. 32, s. 33 Source: Accounting for Imported Goods and Payment of Duties Regulations, SOR/86-1062 Source: CBSA Commercial import payments: Duties, taxes and other customs dues Source: CBSA CARM: Features and benefits
Customs Self-Assessment (CSA) Program — eligibility, privileges, and compliance obligations
The Customs Self-Assessment (CSA) Program is a key Canada Border Services Agency (CBSA) initiative that streamlines border processing, accounting, and payment of duties and taxes for commercial importers, carriers, and drivers who are pre-approved as low risk. The program is governed by CBSA Memorandum D23-2-1, which sets out eligibility, operational requirements, and compliance obligations as of June 2026.
Eligibility requirements: Importers applying for CSA status must: (1) have a place of business in Canada and keep records in Canada as required by the Customs Act, (2) maintain a satisfactory history of compliance with customs and revenue legislation, (3) demonstrate adequate internal controls and accounting systems, (4) be solvent and in good standing with the CBSA, and (5) import goods destined for exclusive use in their own Canadian business. Excluded goods include those classified as prohibited, controlled (e.g., firearms, certain agricultural goods), excisable, or subject to duties under the Special Import Measures Act or quota controls (per D23-2-1, s. 19–25).
CSA-approved carriers must be based in Canada or the U.S., meet CBSA compliance standards, and use electronic data systems compatible with CBSA rules. For drivers, the CSA program requires advance registration and approval under programs specified by the CBSA (D23-2-1 s. 48–51), and presentation of acceptable identification at the border.
Privileges and operations under CSA:
- For eligible goods and shipments, CSA importers are not required to submit release documentation at the border; instead, release is based on the CBSA recognizing the importer, carrier, and driver as pre-approved program participants (D23-2-1 s. 29–32).
- Accounting for CSA shipments is completed via the importer’s own business systems, with details consolidated and submitted to the CBSA in the form and frequency prescribed (currently, periodically or monthly, as stated in D23-2-1 s. 35–40). Duties and taxes are paid along with the periodic submission rather than on a per-shipment basis.
- CSA shipments remain subject to post-release verification and audit by the CBSA, which can review all related records and transaction information held in Canada for six years (D23-2-1 s. 41–46).
Compliance and risks: Participation may be suspended or revoked for non-compliance, insolvency, or failure to maintain required standards. CSA exclusion applies to non-resident importers, courier imports, certain regulated, prohibited, or quota goods, and any situation not expressly covered under D23-2-1.
Source: CBSA Memorandum D23-2-1, Customs Self-Assessment Program for Importers
In-bond and in-transit movements — CBSA procedures, carrier liability, and statutory exceptions
Goods arriving in Canada but not immediately released for entry into commerce are held “in bond” and may be moved under CBSA control—without duty or tax payment—between customs offices, facilities, or to the border for export. The in-bond regime is rooted in sections 19, 20, 22, and 29 of the Customs Act, and is further detailed in CBSA Memorandum D3-1-1 (general), D3-4-2 (highway), D3-5-1 (marine), and other mode-specific memoranda.
Definition and scope of in-bond:
- “In bond” applies to goods arriving in Canada that are not yet released under section 31 of the Customs Act. They may be: (a) moved from the port of arrival to another customs office for clearance; (b) transported to a sufferance or bonded warehouse; or (c) exported or transshipped through Canada to another country. (Customs Act ss. 19–20; D3-1-1, s. 12–15).
- In-transit refers to non-duty-paid goods moved through Canada between foreign points without entering Canadian commerce. These must remain under customs control, and both entry and export (exit port) must be reported to CBSA. (D3-1-1, s. 85–88).
Procedural requirements:
- All in-bond movements require proper reporting at entry and must be covered by a cargo control document (CCD) or equivalent electronic record (e.g., eManifest). Reporting is pursuant to sections 12 and 12.1 of the Customs Act and the method is detailed in the D3 series; for highway, marine, and air, specific forms (A8A(B), eManifest, etc.) are prescribed. (D3-4-2, s. 27–36; D3-5-1, s. 10–19).
- Responsibility for the goods while in-bond rests with the carrier until goods are acquitted at the authorized destination or exit. Any loss, diversion, or unauthorized delivery can trigger penalties under section 22 and may result in seizure (Customs Act s. 20, 22; D3-1-1, s. 29–31).
Time limits and release points:
- Goods must reach the designated customs office, warehouse, or border within the period CBSA specifies (usually set by operational policy for the mode and facility type). For instance, perishables or high-risk goods may be subject to shorter delivery periods per CBSA operational directives (D3-1-1, s. 49–55).
Exceptions and eligibility:
- Some goods—such as certain controlled, prohibited, or excisable goods—may not move in-bond except under additional permit or licence, as detailed in D3-1-1, s. 45–46, and D3-4-2, s. 29. Carriers moving goods in-bond must be licensed and, if required by mode, bonded for security (D3-4-2, s. 15, 21).
Enforcement and compliance:
- Breach of in-bond regulations (failure to deliver, unauthorized removal, or late reporting) exposes carriers and owners to liability under the Customs Act and administrative penalties; see D3-1-1 s. 80–81 for enforcement provisions. Penalties may include seizure of goods or administrative fines as prescribed by CBSA.
As of 2026, virtually all in-bond and in-transit cargo control records are transmitted electronically through eManifest; paper CCDs remain only for CBSA-approved contingency processes, and requirements are updated as per the latest published memoranda.
Source: Customs Act, R.S.C., 1985, c. 1 (2nd Supp.), ss. 12, 19, 20, 22, 29 Source: CBSA Memorandum D3-1-1, Policy Respecting the Importation and Transportation of Goods Source: CBSA Memorandum D3-4-2, Highway Pre-arrival and Reporting Requirements Source: CBSA Memorandum D3-5-1, Marine Pre-arrival and Reporting Requirements
CARM Client Portal — registration, core functions, and transition deadlines (2024–2025)
The CBSA Assessment and Revenue Management (CARM) Client Portal is the official digital platform required for all Canadian commercial importers, customs brokers, and non-resident importers (NRIs) to manage import entries, duty payments, and compliance as of 2024–2025. The move to CARM is driven by a mandatory CBSA operational policy—importers who are not registered in the CARM Portal by the published deadlines will not be able to obtain release of goods or access Release Prior to Payment (RPP) privileges, as clearly set out in CBSA Customs Notices 25-22 and 25-23.
Who must register and transition deadlines
- All resident and non-resident importers now must register their business number (BN15) and import program account in the CARM Client Portal to file entries, delegate brokers, submit corrections, and receive release.
- Brokers and consultants who act on an importer’s behalf must be delegated authority within the portal (on each importer’s BN15), or they are unable to transact after the portal cutover.
- The CBSA established May 13, 2025 as the mandatory portal registration date; after this, entries for commercial imports (including those broker-filed) must flow through a registered importer CARM account. RPP privilege on broker-provided security ceased as of this date; importers must post their own financial security in CARM to use RPP (see CBSA Customs Notice 25-22).
Core CARM Portal functions
- Create and manage importer BN15/RM accounts and verify user identity (CARM Guide, section "Registering for the CARM Client Portal").
- File Commercial Accounting Declarations (CAD/IID, B3), corrections (B2), and supporting documents and track real-time status (CARM Guide, "Submit a commercial import declaration").
- Post, view, and manage RPP financial security (see RPP section and CARM Guide, "Managing financial security").
- Access monthly Statement of Account (SOA), payment reconciliation, and view all importer transactions (CARM Guide, "View statements and pay duties and taxes").
- Assign or remove transaction authority to brokers/consultants or internal staff—without this delegation in CARM, no third party may transact for the account (CARM Guide, "Delegating authority").
Compliance tasks (self-corrections, viewing decisions, tracking transactional history) can be managed within the CARM portal, with appeals/recourse typically initiated per CBSA instructions via the portal but governed by standard CBSA recourse (notices and appeals) procedures.
Transition enforcement, broker-assisted contingency, and 2025 compliance
- After May 13, 2025, importers not fully set up in CARM—with correct security posted and authorities designated—cannot obtain release for their entries. Release prior to payment is also unavailable unless the CARM portal setup is complete and the required financial security is present.
- CBSA Customs Notice 25-23 temporarily permits brokers to use an “RPP Contingency” arrangement for critical health or time-sensitive shipments if a registered importer’s CARM setup is incomplete, but this is time-limited and subject to stringent conditions (Notice 25-23, paragraphs 8–15).
Practical compliance notes (2024–2025)
- Register _all_ BN15/RM accounts via CARM, not only those actively importing, to avoid shipment disruptions.
- Non-resident importers are subject to the same registration and security requirements as residents.
- Delegation to brokers must be set up in CARM for each importer-broker pairing; prior authorizations do not migrate automatically.
All timeframes and operational requirements above are current as of June 2026 per the cited CBSA portal guide and Customs Notices. Statutory rules still bind, but CARM is now the operational choke point for day-to-day compliance and release.
Source: CBSA CARM Client Portal Guide Source: CBSA Customs Notice 25-22 Source: CBSA Customs Notice 25-23