For US Importers Expanding to Canada: CARM Registration, Canada HS Codes, the CUSMA Bridge

Every year, the United States and Canada move goods across their shared border worth hundreds of billions of dollars. For a US importer weighing expansion, that scale, combined with tariff preferences and a customs system built to handle high volume, makes Canada one of the more straightforward markets to enter next.

The bilateral trade footprint

U.S. goods trade with Canada (exports plus imports) totaled an estimated $719.5 billion in 2025, with U.S. goods exports to Canada at $336.5 billion and U.S. goods imports from Canada at $383.0 billion that year. Canada was the top destination for U.S. exports in 2024, and Canada exported over three-quarters of its goods to the United States while importing almost half of its goods from the United States.

CUSMA preferential rates as a starting advantage

The Canada-United States-Mexico Agreement (CUSMA, the successor to NAFTA) gives most US-origin goods a real head start. CUSMA provides preferential, duty-free treatment on over 98% of tariff lines and more than 99.9% of bilateral trade between Canada and the United States. However, you still need to confirm your product qualifies as originating and complete the certification paperwork, covered later in this piece, but the baseline duty exposure for most US goods entering Canada is low compared to non-preferential trading partners.

Common goods that flow easily across both borders

Certain categories move with particular ease given the depth of cross-border supply chains: 

• vehicles and auto parts, 

• machinery, 

• agricultural products, 

• and energy goods 

These all have long-established classification precedent and CUSMA rules of origin. For most consumer and industrial goods manufactured or substantially transformed in the US, the path to preferential treatment is well-trodden, which is part of why Canada tends to be a lower-friction second market than importers expect.

Non-Resident Importer (NRI) Status

What NRI means in Canadian customs law

A Non-Resident Importer (NRI) is a business based outside Canada, most commonly a US company, that acts as the importer of record for goods entering the Canadian market. Rather than routing sales through a Canadian distributor, an NRI ships directly to Canadian customers and takes on the customs and tax obligations that come with that role. This status doesn't require a Canadian office or employees, but it does require formal registration with Canadian authorities, which the next section covers in detail.

When a US business needs NRI status

You need NRI status once your business, not a Canadian buyer, is the party responsible for clearing goods at the border. This typically applies to companies selling direct-to-consumer or direct-to-business into Canada under Delivered Duty Paid (DDP) terms, where you're quoting a landed price and handling customs on the buyer's behalf. If your Canadian customers already act as the importer of record on your invoices, you may not need NRI status, but many US sellers choose it anyway because it gives them control over classification, duty treatment, and delivery timing rather than leaving that in a customer's hands.

NRI vs. setting up a Canadian subsidiary

NRI status and incorporating a Canadian subsidiary solve different problems. 

NRI status lets you sell and ship directly into Canada under your existing US entity, with a lighter setup but ongoing exposure to Canadian customs and tax compliance under your own name. 

A subsidiary creates a separate Canadian legal entity, which can simplify banking, payroll, and long-term tax planning, but adds incorporation costs and its own compliance obligations. 

Most US importers start as an NRI and only consider a subsidiary once Canadian revenue is large enough to justify the overhead.

Mandatory CARM Registration for US Sellers

The CBSA Assessment and Revenue Management (CARM) system is Canada's official system of record for the collection of duties and taxes for commercial goods imported into Canada, and it now applies fully to non-resident importers.

Registration mechanic for non-resident importers

To register, you first need a 9-digit Business Number (BN9). Non-resident businesses must contact the Canada Revenue Agency (CRA) directly to request a non-resident BN9 before attempting to log into CARM, unlike resident businesses, which can often generate one during portal registration. Once you have your BN9, you register your business in the CARM Client Portal, and the first person to complete that registration automatically becomes the Business Account Manager, the person responsible for approving employee and broker access going forward.

Posting financial security as an NRI

As of January 1, 2026, legislative amendments to the Customs Act took effect making the importer of record directly liable for duties, taxes, and post-accounting adjustments, rather than the customs broker, and a broker's business number can no longer be used to release or account for commercial goods on an importer's behalf. In practice, this means you must post your own financial security (a surety bond or cash deposit) to qualify for Release Prior to Payment (RPP), the program that lets goods clear before duties are formally paid.

Canada's model differs from what US importers are used to with CBP: CARM requires a deposit equal to roughly 50% of your highest monthly duties and taxes if using a bond, which is often higher than the 10% baseline used in the US.

Broker delegation when you have no Canadian operations

Registering yourself doesn't eliminate the need for a broker, it changes the relationship. You must digitally delegate authority to your broker inside the CARM Client Portal; a paper Power of Attorney is no longer sufficient. Your broker continues to file entries and manage day-to-day clearance, but now acts under your registration and your posted security rather than their own, which is why the sequencing matters: register and post security first, then delegate.

Translating Your US HTS to Canadian HS

The 1-6 digit overlap and the 7-10 digit divergence

The Harmonized System (HS) is an international standard maintained by the World Customs Organization, and the first six digits of a classification code are identical whether you're filing in the US or Canada. 

Where the US Harmonized Tariff Schedule (HTS) and the Canadian Customs Tariff diverge is at the 7th digit onward, where each country adds its own subdivisions for statistical and duty-rate purposes. 

A product with a shared 6-digit HS heading can still land on a different 10-digit Canadian tariff item than its US counterpart, which means a US classification is a strong starting point but not a substitute for Canadian-specific classification.

Mapping your SKU catalog to dual classifications

For a catalog of any size, mapping each stock-keeping unit (SKU) to both its US HTS code and its Canadian tariff classification is the practical way to avoid surprises at the border. Doing this product by product, by hand, is slow and error-prone once you're past a few dozen SKUs, particularly for products with ambiguous material composition or multiple potential uses. This is one of the areas where a classification tool built to work across both schedules can save meaningful time, since it can flag where the US and Canadian codes diverge in duty treatment rather than just confirming a 6-digit match.

CBSA advance rulings for major SKU families

For product families where classification is genuinely unclear, or where the duty difference between two plausible codes is significant, you can request an advance ruling from the CBSA before you start shipping. An advance ruling gives you a binding classification determination in writing, which removes the risk of a post-entry reassessment on a whole product line. 

This is worth doing selectively, for your highest-volume or highest-risk SKU families, rather than for every product in your catalog.

CUSMA Preferential Origin for US-Origin Goods

Qualifying as US-origin under CUSMA

To claim CUSMA's preferential rate, your good has to meet the applicable rule of origin, not just be shipped from the US. The product-specific rules of origin generally rely on either a tariff shift, where imported materials must be classified in a sufficiently different HS code than the finished good, or regional value content (RVC), where a set percentage of the good's value must originate in Canada, the US, or Mexico. Which test applies depends on the product's HS classification, so this is a determination made good by good, not company-wide.

Certification mechanics (you'll likely be the certifier)

A CUSMA certification of origin can be completed by the exporter, producer, or importer of the good, and as a US company shipping into Canada, you'll often be filling this role yourself as exporter. The certification isn't a special government form, it can appear on a commercial invoice or standalone document, but it must include specific data elements: the certifier's role and contact information, a description of the good, its 6-digit HS classification, the applicable origin criterion, and a signed statement that the information is accurate. A single certification can also cover multiple shipments of identical goods over a period of up to 12 months, which reduces the paperwork burden for recurring orders.

Substantial transformation if you assemble in the US from imported components

If your product isn't wholly made in the US, if it includes imported parts or materials, you'll need to work through whether US assembly counts as enough transformation to qualify. This is where the tariff shift and RVC tests actually get used: if your imported components are classified under a different heading than your finished product, or if enough of the product's value was added domestically, it can still qualify as originating even with non-US content inside it. 

Getting this wrong in either direction, claiming origin you haven't earned or failing to claim origin you have, carries real cost, so it's worth documenting the calculation rather than estimating it.

GST/HST Registration Threshold

The CAD $30,000 worldwide-supplies threshold

A business is no longer considered a "small supplier," and must register for GST/HST, once the total value of its worldwide taxable supplies exceeds CAD $30,000 in a single calendar quarter or over four consecutive calendar quarters. This threshold is measured on worldwide revenue, not just Canadian sales, which surprises some US sellers who assume it only counts Canadian-sourced revenue. For most active importers selling into Canada at any meaningful volume, this threshold is crossed quickly, so it's rarely a question of if, only when.

Voluntary registration and ITC recovery

You can register for GST/HST voluntarily even before hitting the threshold, and there's a real reason to: registration lets you recover the GST/HST you pay on Canadian business expenses through Input Tax Credits (ITCs). If you're paying GST on freight, warehousing, or brokerage fees inside Canada before you've technically crossed the $30,000 mark, voluntary registration can mean recovering that tax rather than treating it as a sunk cost.

Provincial PST vs. HST considerations

Canada's sales tax layer isn't uniform across provinces. Some provinces have harmonized their provincial sales tax with the federal GST into a single Harmonized Sales Tax (HST), while others, including British Columbia, Saskatchewan, and Manitoba, apply a separate Provincial Sales Tax (PST) on top of GST with their own registration rules and rates. Before you set final Canadian pricing, it's worth confirming which regime applies in each province you're shipping to, since the combined tax burden can differ meaningfully by destination.

Canadian Surtaxes That Apply to US Sellers Sourcing From China

If your products, or their components, are made in China, sourcing decisions can carry a Canadian duty cost separate from anything CUSMA covers. These surtaxes generally exempt US-origin goods, but they matter directly if you're a US company importing Chinese-made goods, or Chinese components, into Canada.

The 25% steel/aluminum surtax on Chinese-origin goods

Effective July 31, 2025, steel goods containing steel melted and poured in China, and aluminum goods containing aluminum smelted and cast in China, are subject to a surtax of 25% of the value for duty, under Canada's Steel Goods and Aluminum Goods Surtax Order. Goods eligible to be marked as Made in the United States are exempt, but the burden of proof sits with the importer: if you can't provide a certificate demonstrating the country of melt and pour or smelt and cast, the goods are deemed to contain Chinese steel or aluminum by default.

 As of September 22, 2025, a commercial invoice alone is no longer sufficient proof; a specific certificate is required.

The SGAGS Order for Chinese steel exported through third countries

The Steel Goods and Aluminum Goods Surtax Order (sometimes referred to as the SGAGS Order) is deliberately designed to catch transshipment. The surtax follows the country where the steel was melted and poured or the aluminum was smelted and cast, not the country the shipment was exported from, so routing Chinese-melted steel through a third country before it reaches Canada doesn't avoid the surtax. This is a documentation issue as much as a sourcing one: if your supply chain runs through intermediaries, you'll need melt-and-pour or smelt-and-cast certification from further up the chain than just your immediate supplier.

The 100% Chinese EV surtax (with the 49,000-vehicle quota)

This one has changed recently, and it's worth being precise about the current state. Canada applied a 100% surtax on Chinese-origin electric vehicles starting in October 2024. As of March 1, 2026, that 100% surtax was repealed and replaced with a quota system: eligible Chinese EVs can now enter under a permit at the standard 6.1% most-favoured-nation tariff rate, with the initial annual quota set at 49,000 vehicles, growing 6.5% per year. The first six months of the initial quota year made 24,500 vehicles available on a first-come, first-served basis, with permits issued by Global Affairs Canada rather than the CBSA. If you're importing Chinese-made EVs or EV components into Canada, the operative constraint today is the permit and quota system, not a 100% surtax.

Choosing a Canadian Customs Broker

Selection criteria (CARM-API integrated, NRI experience, industry fit)

Not every Canadian broker is set up to work well with a US-based NRI. Look for a broker whose systems integrate directly with the CARM Client Portal rather than relying on manual re-entry, since that reduces the chance of delegation or accounting errors. Broker experience specifically with non-resident importers matters too, since NRI accounts carry different security and liability arrangements than resident importer accounts, and a broker unfamiliar with those distinctions is more likely to make process mistakes that cost you time at the border.

Delegation scope decisions

When you delegate authority in the CARM portal, you choose how much control the broker has: filing entries only, managing your Statement of Account, or acting on your behalf for a broader set of programs. Broader delegation reduces your day-to-day workload but also means more of your compliance posture depends on someone outside your company. 

Most US importers start with a narrower delegation scope and expand it once they've built confidence in the relationship.

Service level expectations

Set clear expectations upfront on response times, especially around held shipments and Statement of Account reviews, since CARM's monthly billing cycle means errors can compound if they aren't caught quickly. Ask how the broker handles CBSA verification requests and documentation demands, given the stricter proof-of-origin requirements now in place for surtax-affected goods.

Six-Month Launch Plan for US Importers Going to Canada

Month 1: NRI status + CARM registration

Obtain your non-resident Business Number from the CRA, then register your business in the CARM Client Portal and designate a Business Account Manager. This step has to happen before anything else, since brokers can't register on your behalf.

Month 2: Classification + CUSMA certification setup

Map your SKU catalog to Canadian HS classifications, confirm which products qualify for CUSMA preferential treatment, and build a template for your certification of origin. For SKU families with unclear classification or meaningful duty exposure, submit advance ruling requests to the CBSA now, since they take time to process.

Month 3: Broker selection + delegation

Select a Canadian broker with CARM-API integration and NRI experience, then complete delegation of authority in the portal, with scope matched to how much control you want to retain. Confirm your posted financial security is adequate for your expected shipment volume before your first commercial entry.

Month 4: First shipments and process validation

Run your first shipments and treat them as a test of the whole system, not just the goods. Check that classifications clear as expected, that CUSMA claims are accepted, and that any surtax exemption documentation (for Made-in-USA goods, for instance) is being recognized correctly.

Month 5: GST/HST registration if threshold reached

Review your cumulative Canadian and worldwide revenue against the CAD $30,000 small supplier threshold. If you've crossed it, or are clearly going to within the next quarter, register for GST/HST now rather than waiting for a forced registration deadline, and confirm the correct PST or HST treatment for each province you're shipping to.

Month 6: First-period account review

Review your first full Statement of Account cycle end to end: duties assessed, surtaxes applied (or correctly exempted), GST/HST charged, and your financial security position against actual monthly volume. This is also the point to reassess broker delegation scope now that you have a working history together.

Frequently Asked Questions

Do I need a Canadian business address? 

No. Non-Resident Importer status doesn't require a Canadian office, employees, or bank account. Some businesses choose to incorporate a Canadian subsidiary later for other reasons, but it isn't a requirement to start importing.

Can I use my US HTS codes when shipping to Canada? 

Only partially. The first six digits of your US HTS code will typically match the Canadian HS heading, since both follow the international Harmonized System, but the additional digits that determine the specific Canadian tariff item and duty rate are assigned separately. Treat your US classification as a starting reference, not a final answer, for Canadian entries.

What's the smallest shipment that triggers all this? 

There's no minimum shipment size that exempts you from CARM registration or importer-of-record liability if you're acting as the NRI. GST/HST registration is driven by your revenue threshold (CAD $30,000), not by any single shipment, and most of the surtax rules apply per shipment based on value for duty, with some carrying a de minimis exemption around CAD $5,000. In practice, if you're planning recurring commercial shipments rather than a one-off, it's worth setting up compliance properly from the first order.

How do I price the layered Canadian tax stack? 

Build your landed cost model to separately account for CUSMA-qualified duty (often zero for originating US goods), any applicable surtax if sourcing includes Chinese-origin content, and GST/HST plus provincial PST where applicable. Because these layers depend on classification, origin, and destination province, a single flat markup rarely holds up across your full catalog, which is part of why scenario modeling by SKU tends to be more reliable than a blanket estimate.

Can I run my Canadian sales through my US entity entirely? 

Yes, that's essentially what Non-Resident Importer status is designed for. You keep your existing US legal entity, register it directly with Canadian customs and tax authorities, and act as the importer of record on your own shipments. The tradeoff is that your US entity carries the compliance and liability exposure directly, which is why some businesses eventually weigh a Canadian subsidiary once volume grows.