CARM Registration Guide for Non-Resident Importers

If your brand is based outside Canada and you want to import inventory directly into a Canadian warehouse, one acronym comes up almost immediately: CARM. It's the system the Canada Border Services Agency (CBSA) uses to assess and collect duties and taxes on commercial imports — and if you're the importer, you have to be registered in it.

For Canadian businesses, registration is fairly straightforward. For non-resident importers — US brands, European brands, or anyone selling to Canadian customers from abroad — there are a few extra steps, and doing them in the wrong order is one of the most common reasons registration stalls. This guide walks through what you need, the registration steps in order, and how CARM fits with your customs broker, GST/HST and your Canadian 3PL.

A note before we start: Redwolf 3PL is a fulfillment company, not a customs broker or tax advisor. Everything below comes from CBSA and Canada Revenue Agency (CRA) guidance linked throughout; confirm the details for your business with those agencies or a licensed broker.

What Is CARM?

CARM stands for CBSA Assessment and Revenue Management. According to the CBSA, it is the official system of record for the collection of duties and taxes for commercial goods imported into Canada. Importers, brokers and other "trade chain partners" use it through the CARM Client Portal.

In practice, the portal is where an importer creates its import program account, delegates authority to a customs broker, enrols in Release Prior to Payment, and submits declarations and payments. The CBSA's guide to setting up your business to import covers each of these. Since October 21, 2024, new importers and exporters with a business number can register for their import-export program account directly in the portal.

The Three Numbers Every Importer Needs

The CBSA says all importers of commercial goods need:

A CARM Client Portal account — the user profile and business account you sign in to.
A 9-digit business number (BN9) issued by the CRA.
A 6-character import program (RM) account, for example RM0001. Combined with your BN9, it forms the 15-character business number account identifier (BN15) that identifies you as the importer.

The key difference for non-residents is the BN9. A Canadian resident business can usually get its business number during portal registration. A non-resident business can't.

Step 1: Get Your Business Number From the CRA First

The CBSA is explicit here: non-resident businesses must request their BN9 from the CRA before attempting to register their business in the portal. If you skip this step, the registration will error out and you'll need to contact the CARM Client Support Helpdesk to fix it.

The CRA's page on getting a nine-digit business number for importing and exporting explains how. Non-resident businesses register for a BN either through the CRA's online "Register as a non-resident doing business in Canada" service or by calling the CRA's non-resident registration and security line.

One detail that saves headaches later: before you register, make a list of every business name that may appear on your customs documents and commercial invoices, and include all of them. The CRA notes that the information the CBSA has on file must match your customs release documents, and mismatches can delay your goods at the border.

Step 2: Create Your User Profile and Register Your Business in the Portal

With your BN9 in hand, the person who will manage your account signs in to the CARM Client Portal. The CBSA offers two sign-in options — a GCKey username and password, or an Interac Sign-in Partner (online Canadian banking credentials) — and you must use the same option every time after that. Most non-residents won't have Canadian online banking, so GCKey is the usual route.

On the "First time setup" screen, choose Register my business. A few rules from the CBSA are worth knowing up front:

The first user to register becomes the business account manager (BAM). The BAM approves colleagues' access and delegates authority to outside parties.
Add a second BAM. The CBSA recommends at least two users with the BAM role so you don't lose access to account management if one person leaves.
You must register yourself. The CBSA states that importers need to register their business in the CARM portal themselves, and customs brokers cannot register their client's business on their behalf.

Step 3: Enrol in the Importer Program to Get Your BN15

Once the business is registered, enrol in the importer program. This creates your RM account and gives you the BN15 that goes on your customs declarations. The CBSA's instructions for non-resident importers are short: get your BN9 from the CRA, register in the CARM Client Portal, and enrol in the importer program to receive your importer BN15.

The CBSA also advises registering for the RM account well ahead of your first import deadline to avoid delays in the release of your goods. Build it into the timeline for your first container or large order.

Step 4: Delegate Authority to Your Customs Broker

You can file your own release and accounting documents with the CBSA, but most brands importing into Canada use a licensed customs broker. If you do, the CBSA's steps are:

Find a broker on the CBSA's list of licensed customs brokers
Sign a general agency agreement with that broker
Delegate authority to the broker in the CARM Client Portal
Enrol in Release Prior to Payment (recommended) and post the financial security

Delegation only works after your business is registered, so the broker can't start acting for you in CARM until you've completed Steps 1 to 3. The CBSA also notes that it doesn't regulate brokerage fees, so discuss them before hiring.

There's an accountability point here too. The importer of record — the importer listed at the time of accounting — is responsible for duties, taxes, record keeping and corrections. If your broker's business number is used on the declaration instead of yours, the broker is jointly responsible with you.

Step 5: Decide on Release Prior to Payment and Financial Security

Release Prior to Payment (RPP) is optional, but the CBSA describes it as the most common release method for commercial importers. It lets your goods be released before you pay duties and taxes, with payment due by the end of the billing period. Without RPP, you account for and pay at the time of release.

To use RPP you have to post financial security. Based on the CBSA's page on getting ready to enrol in RPP:

CARM calculates your required security from your highest monthly accounts receivable with the CBSA (including GST, duties and surtax) over the previous 12 months.
With a written security agreement from a financial security provider (a surety bond), you post at least 50% of that calculated amount, with a minimum of $5,000 and a maximum of $10 million per importer program account.
With a security deposit, you post 100% of the calculated amount yourself.
The requirement is recalculated every year. Importers are notified on October 20, and if the amount goes up, the security must be increased by January 15 to keep RPP.

The most important change for brands that used to lean on their broker: since October 21, 2024, importers who enrol in RPP must obtain their own security agreement or post their own deposit. Customs brokers can't post a security deposit for their clients, and importers can't use their broker's security.

Don't Forget GST/HST — It's a Separate Question

CARM covers customs duties and the taxes collected at the border. Whether you also need to register for the GST/HST with the CRA is a separate question. The CRA's guide RC4027, Doing Business in Canada – GST/HST Information for Non-Residents, covers the rules in detail. A few points from it that matter to ecommerce brands:

Non-residents who carry on business in Canada and make taxable supplies there must register under the normal GST/HST regime unless they're small suppliers (generally, $30,000 or less in worldwide taxable supplies over four consecutive calendar quarters, including associated persons).
Non-residents who don't carry on business in Canada may still have to register under the simplified GST/HST regime for certain supplies made into Canada.
A GST/HST registrant that is the importer of record generally pays the GST (or federal part of the HST) at importation and can claim it back as an input tax credit to the extent the goods are used in its commercial activities.

Because CARM and your GST/HST account both tie back to the same BN9, it usually makes sense to sort them out together, with advice specific to your setup.

Where a Canadian 3PL Fits In

CARM registration is what lets you import into Canada in your own name. It's also what makes the setup we describe in our article on paying tariffs and freight twice possible: shipping straight from your manufacturer or country of origin into Canada instead of routing Canadian inventory through the US first.

Once your goods clear customs, they need somewhere to land. Redwolf 3PL receives imports directly from manufacturers and countries of origin at our Toronto facility near Pearson (YYZ), handles prep, kitting and assembly, and ships to Canadian customers through DTC and Shopify fulfillment, B2B orders, or Amazon FBA prep for Amazon.ca. We're not a customs broker, but we regularly help brands get CARM and GST/HST in place — including on tight timelines — by connecting them with the right people. You can read more about how that works on our sell in Canada fulfillment page.

Frequently asked questions

Can a non-resident business register for CARM?

Yes. Non-resident importers can register in the CARM Client Portal and enrol in the importer program. The difference is that they must first get a 9-digit business number from the Canada Revenue Agency; unlike most Canadian resident businesses, they can't obtain it during portal registration.

Can my customs broker register my business in CARM for me?

No. The CBSA says importers must register their business in the CARM Client Portal themselves and customs brokers cannot do it on their behalf. Once you're registered, you delegate authority to your broker in the portal so they can act for you.

What is the difference between a BN9 and a BN15?

The BN9 is the 9-digit business number issued by the CRA. The BN15 adds your 6-character import program (RM) account, such as RM0001, to the BN9 and is the identifier the CBSA uses for you as an importer.

Do I have to enrol in Release Prior to Payment?

No, RPP is optional, but the CBSA describes it as the most common release method for commercial importers. It lets goods be released before duties and taxes are paid, and it requires you to post your own financial security, either a written security agreement for at least 50% of the calculated amount or a security deposit for 100%.

Does CARM registration also register me for GST/HST?

No. CARM covers customs accounting with the CBSA. GST/HST registration is handled by the CRA, and whether a non-resident has to register depends on factors such as whether it carries on business in Canada and whether it is a small supplier. The CRA's guide RC4027 explains the rules for non-residents.

Sources

Importing into Canada for the first time, or untangling a setup that routes Canadian inventory through the US? Tell us what you sell and where it ships from, and we'll walk you through how receiving and fulfillment from Toronto would work.

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CARM Registration for Non-Resident Importers: A Step-by-Step Guide for Brands Selling Into Canada