Canada's CARM Regime: Which Account Carries Duty Before Release

Under Canada's assessment rules the account that carries duty before goods move is the importer's own portal account, and from 20 May 2025 that account must already hold financial security posted by the importer. No forwarding ledger substitutes for it, and no China-side paperwork lends a registration number to an entry. For a seller shipping delivered duty paid freight out of Guangdong the deciding question is administrative, not physical: whose business number sits on the entry, and does that name have posting behind it.

Key facts

• Two dates, two gates. From 21 October 2024 a new importer holding a nine-digit Canada Revenue Agency business number, the BN9, can open an import-export programme account with the RM suffix inside the CARM Client Portal. From 20 May 2025, release before duty and taxes are settled also needs financial security posted there.
• Posting follows the registration. The ledger is keyed to the importing number, not to whoever transmits the declaration, so an agent's security cannot cover your cartons.
• Security is not a service fee. It answers for possible arrears on one account; the figure required is the agency's own calculation, so no amount appears here.
• Our boundary is documentary. Weights, counts, marks and invoice data come off our floor; the registration, the posting and the release decision belong to the importer of record and their broker.

What the two CARM dates switched on

Assessment and Revenue Management put an importer's registration, delegated authority and ledger into one client portal. Two published dates shape how a new importing name enters it. From 21 October 2024 a new importer or exporter already holding a Canada Revenue Agency business number can register an import-export programme account with the RM suffix straight in the portal, without a separate offline step, as the guidance on canada.ca sets out. From 20 May 2025 an importer requiring release prior to payment of duty and taxes must have posted their own financial security there, the condition published in Customs Notice 24-27 on cbsa-asfc.gc.ca. Neither date touched liability itself: classification, origin and the sum owed behave as before. What changed is the money standing behind an account.

Why an agent cannot lend you its ledger

A broker may hold delegated authority to transmit declarations and act inside a portal account. Authority answers who may file; it does not answer whose account absorbs the risk. The registration number on the entry decides which ledger is debited when duty falls due, which posting supports early release, and whose name shows arrears. An experienced agent is no replacement for your own posting: file under another number and a hold taken while that posting lapses lands on a record you cannot read from Shenzhen.

Two systems sellers routinely collapse into one

Our FAQ answers the United States question first, about who posts a bond on an American entry. That is a different instrument in a different country, and nothing above transfers to it. Canada asks an importing name to register itself and hold security in a portal, which is the comparison below.

Whose registration sits behind a delivered duty paid line

Delivered duty paid is a statement about cost, not about whose registration files. On a Canadian movement some name is recorded as importer: yours, a trading intermediary, or the party that arranged the freight. Ask before the first despatch, because that answer tells you whose posting your release depends on and who receives an agency request afterwards. Where you want the account to be your own, the order of work is fixed: a business number from the revenue agency, an RM programme account opened in the portal as permitted since 21 October 2024, delegated authority granted to whoever files, then security posted before the 20 May 2025 condition allows cargo out ahead of payment. Our DDP sea and air page covers what our side includes; it names no importing identity, because that identity is a term to agree.

What our floor produces, and what it never will

Goods-in weights and dimensions, carton counts reconciled to your manifest, shipping marks, the invoice as your supplier issued it and the despatch reference tying an entry to one pallet are ours to hand over, and they are what a broker needs to file cleanly. What we do not do is register with a foreign agency, hold a portal account, lodge security, or answer for duty owed at a Canadian border; nor can we tell you the figure your posting should reach. A hold placed at a port is lifted by the importer's own action. Four checks close the subject: which registration files the entry, whether its posting is current, who holds delegated authority and what happens if it lapses mid-transit, and which documents travel with the cartons.

Do you hold a CARM account or post security on my behalf?

No, and we would not take the role. Our work is origin-side: receipt, storage, picking, packing, despatch from China and the freight arrangement to a Canadian port. The portal account, the business number behind it and any security posted inside belong to the importing entity, so release behaviour follows that account, not our paperwork. A provider who offers to carry the Canadian posting for you is offering to file under their own registration, which puts your clearance history in a ledger you cannot inspect.

My terms include duty, so does that settle whose account pays?

It settles who bears the cost commercially, not whose registration answers to the agency. Duty and taxes can sit inside a delivered duty paid price while the entry files under a third party's programme account, and if that account holds no current posting after 20 May 2025 the early release route closes even though your invoice says everything is settled. Put one line in the booking record: the BN9 and RM account filing the entry, and confirmation its posting is live on arrival. A provider who cannot write that sentence has defined a price, not an arrangement.

I have no BN9 yet. Can my goods still reach a Canadian customer?

They can be entered, but not on the assumption that release ahead of payment is open to them. The posting condition bites where an importer requires goods released prior to payment of duty and taxes; where the amount is settled before release, that gate is not the one your cargo meets. Registration is the slower half: a business number from the Canada Revenue Agency must exist before the portal opens an RM import-export programme account, and both before delegated authority can be granted. Sellers expecting recurring Canadian volume start that before booking a first pallet.

Reviewed 2026-11-03. The BN9 and RM points come from the CARM registration guidance and the account registration and modification page on canada.ca, the posting condition from Customs Notice 24-27 on cbsa-asfc.gc.ca, all read on that date. Further customs answers, including the United States bond entry, sit on our FAQ page. This note comes from the desk trading as FulfillDock by SBT, registered under Shenzhen Shibotong International Logistics Co., Ltd., which holds no Canadian portal account and files no entry there. No amounts appear in it, and the dates quoted are published conditions rather than a clearance promise.