CARM is Mandatory: A Registration Guide for Non-Resident Importers (NRIs)

Key Takeaways:

• Mandatory Shift: CARM is not optional; it is the new digital standard for importing into Canada.
• Importer Liability: The legal responsibility for duties and taxes now sits directly with the importer, not the customs broker.
• Financial Security: Importers must post their own economic security (RPP) to clear goods before payment.
• Digital Authority: You must digitally delegate authority to your broker in the CARM portal; a paper Power of Attorney is no longer sufficient.

For decades, importing goods into Canada was primarily handled by customs brokers. You shipped the goods, the broker dealt with the paperwork, and you paid the invoice. In 2025, that era has officially ended, and as of January 1, 2026, new legislative amendments to the Customs Act have come into force, clarifying the shared liability for duties and taxes for the Importer of Record.

The Canada Border Services Agency (CBSA) has fully implemented CARM (CBSA Assessment Revenue Management), a digital initiative that fundamentally changes how duties and taxes are collected. The most critical change is that liability and registration now sit directly with the importer, not the broker.

If you are a US, UK, or European brand shipping DDP (Delivered Duty Paid) to Canada, you are likely classified as a Non-Resident Importer (NRI). If you have not registered your business in the CARM Client Portal, your goods risk being turned away at the Canadian border - which can halt cross-border delivery entirely.

This guide will walk you through the CARM registration guide steps and explain why immediate action is required to keep your supply chain moving.

What is CARM?

CBSA Assessment Revenue Management (CARM) is the digital system that modernizes how the Canadian government collects duties and taxes on commercial goods. It replaces the old paper-based methods with a fully digital interface.

The goal of CARM is to streamline import processes, but for non-resident importers into Canada, it adds an administrative burden. You can no longer rely solely on your customs broker to use their business number for your imports. Every importer must have their own account and their own financial security (bond) posted - so customs clearance services now depend on the importer being properly registered in CARM.

Step 1: Get Your BN9 Registration

Before you can even log in to the CARM Client Portal, you need a Business Number (BN).

If you are a foreign entity, you must obtain a BN9 registration (a 9-digit Business Number) from the Canada Revenue Agency (CRA). This number identifies your business to the Canadian government for tax and customs purposes. Without a BN9, you cannot act as the Importer of Record, meaning you cannot legally bring commercial goods into Canada under your own name.

For merchants expanding into this market, as detailed in our guide on shipping from the UK to Canada, obtaining your BN9 is the absolute first step in your cross-border journey.

Step 2: Register in the CARM Client Portal (CCP)

Once you have your BN9, you must register the business in the CARM Client Portal. This is the online hub where you will view your Statement of Account, pay duties, and authorize your broker.

The registration process requires a "Business Account Manager" (BAM) to be designated. This must be an employee of your company (usually an owner, CFO, or logistics director), not a third-party agent. The BAM must create the account using a "Sign-In Partner" (like a bank login) or a "GCKey" (government ID credential).

Step 3: Delegate Authority

This is where many businesses get stuck. Once your account is active, you must formally "delegate authority" to your customs broker or logistics provider within the portal.

In the past, a paper Power of Attorney was enough. Under CARM, the relationship must be digital. If you do not log in and click to accept your broker's request for access, they will not be able to clear shipments on your behalf. Your broker can no longer "front" the duties for you without this digital handshake.

Step 4: Post Financial Security (RPP)

Perhaps the most significant financial shift is the requirement for Release Before Payment (RPP) security.

Previously, NRIs often used their broker's bond to clear goods. Now, importers are encouraged to post their own financial security directly through the portal to benefit from RPP privileges (which allow your goods to be released from the border before duties are paid). Failing to post security or secure a bond can result in your shipments being held until full payment is made at the port of entry.

Why This Matters for 2026?

The Canadian market continues to expand, supported by major infrastructure projects like the 2025 opening of the Gordie Howe International Bridge, a vital link for cross-border e-commerce trade. As shown in our facts and figures on cross-border Canada e-commerce, Canadian consumers are eager for international goods. However, CARM is a gatekeeper.

If you ignore these steps, the consequences are severe:

• Border Delays: Trucks turned around because the importer's account does not exist.
• Cash Flow Hits: Having to pay duties instantly at the border because no RPP bond is in place.
• Compliance Penalties: Fines for inaccurate data or late accounting.

Summary

CARM is mandatory, and all transition measures have officially concluded following the issuance of Customs Notice 25-32, marking the full enforcement of the new system. For the Non-Resident Importer to Canada, this means you must become an active participant in your customs compliance.

Do not wait for your first shipment to get stuck. Get your BN9 registration, log in to the CARM Client Portal, and delegate authority to your logistics partner today. If you need assistance navigating this transition, Landmark Global is here to guide you through every click of the process.

Sources:

• Government of Canada (2025): https://www.cbsa-asfc.gc.ca/agency-agence/reports-rapports/rpp/2025-2026/full-plan-plan-complet-eng.html
• International Trade Administration U.S. Department of Commerce (2023): https://www.trade.gov/country-commercial-guides/canada-ecommerce
• Government of Canada (2025): https://www.cbsa-asfc.gc.ca/services/carm-gcra/start-passer-eng.html
• Government of Canada (2025): https://www.cbsa-asfc.gc.ca/services/carm-gcra/menu-eng.html