If your goods are held and your broker tells you it is "a CARM issue," the problem is almost never the shipment. It is your account. Something in your CBSA portal setup — the business account, the delegated authority, the security — is missing, expired, or registered against the wrong legal entity. Freight does not fix that. Only the importer can.
That is the single biggest change CARM made. Your broker used to sit between you and the Canada Border Services Agency on most financial and account matters. Now you hold the account, you owe the money, and you are the one who has to keep the registration alive.
What CARM is, in plain terms
The CBSA Assessment and Revenue Management system is the agency's platform for assessing and collecting duties and taxes on commercial imports. It replaced a set of older internal systems and, more importantly for you, it moved the importer's relationship with CBSA onto a self-service portal.
Three consequences matter for a small or mid-sized importer:
- You have a direct account with CBSA. Duties and GST on your imports are billed to your account, visible to you, on a statement you can read yourself.
- You are responsible for financial security. Historically, many importers relied on their broker's bond to get release of goods before payment. CARM changed the structure so that an importer who wants release prior to payment posts security in its own name.
- Your broker acts under delegated authority. Their ability to transact for you comes from permissions you grant in the portal, and those permissions can lapse.
Requirements, thresholds and portal functions in this area continue to change. Treat everything below as the shape of the obligation, not as the current rule. Confirm specifics against CBSA's own guidance before you act on them.
The five things that have to exist
1. A business number with an import account
You need a nine-digit business number with an importer/exporter program account attached to it — the RM account. A BN with only a GST/HST account on it is not enough to import commercially. This trips up businesses that registered for GST years ago and assumed they were covered.
The name on the account must match the legal entity that is the importer of record on your customs documents. Operating names, "doing business as" names and holding-company confusion are a recurring source of rejected registrations.
2. A registered business account in the portal
Somebody has to claim the business in the CARM portal and complete the identity validation CBSA requires. This is the step most often left half-finished: the individual who started it left the company, or the validation questions could not be answered because the person did not have access to the corporate tax records.
3. A business account manager who still works there
The business account manager is the person with authority to approve users, grant access to third parties, and manage the account. Have at least two. If your only BAM leaves, resigns their access, or changes email addresses without transferring the role, you lose administrative control of your own account and recovering it is a process, not a phone call.
Write down who your BAMs are. Review it when someone leaves. This is the cheapest piece of compliance maintenance you will ever do and the one most commonly skipped.
4. Delegation of authority to your broker
Your customs broker needs permission in the portal to transact on your behalf. You grant it; they request it. Delegations can be scoped, and they can expire. If your broker suddenly cannot submit for you, check whether the delegation lapsed before you blame the system.
If you use more than one broker — common if you have separate ocean and courier lanes — each needs its own delegation. So does any consultant or accounting firm you want to see your statements.
5. Financial security, if you want release before payment
If you want your goods released before you have paid the duties and taxes on them, you need to be enrolled in the release-prior-to-payment program with security posted in your own name. Two ways to do that:
| Surety bond | Cash deposit | |
|---|---|---|
| Cost | Annual premium to the surety | Full amount, tied up |
| Who provides it | Surety company, often via your broker | You, directly to CBSA |
| Best for | Most regular importers | Very low volumes, or importers who cannot obtain a bond |
| Renewal risk | Lapses if premium unpaid or surety withdraws | None, but capital is idle |
The amount of security required is calculated from your duty and tax liability — the mechanism keys off your highest month of liability over a rolling period, subject to a minimum and a maximum. Confirm the current percentage, floor and ceiling with CBSA or your surety; those figures move.
The practical point is that seasonal importers get penalised by the shape of the calculation. If you bring in a year's worth of goods in two months, your security is sized off those two months, not your average. An importer with $30,000 in duty and GST spread evenly across the year and an importer with $180,000 landing in October are not treated the same way, even at similar annual volumes.
Without security in place, you can still import — but you pay before release, which means cash out the door before the goods move. For some low-volume importers that is a reasonable trade. Decide deliberately rather than discovering it at the border.
Reading your statement of account
CBSA posts a statement to your portal on a billing cycle, with a payment due date. Two habits are worth building:
- Reconcile it against your own records monthly. Not your broker's summary — the CBSA statement itself. You are checking that every transaction on it is actually yours, and that the valuation and classification behind the duty look right.
- Know your due date and who pays. Some importers pay CBSA directly. Some still flow payments through their broker. Both work; problems come from each party assuming the other did it. Interest and penalties attach to the importer.
Errors you find on the statement are your errors to correct. If you have declared an incorrect value, classification or origin, there is a mechanism to file a correction, and doing so voluntarily before CBSA finds it generally puts you in a better position than the alternative. What that looks like procedurally has changed under CARM — ask your broker how corrections are filed on your account today.
Where shipments actually get held up
The failure modes are boring and repetitive:
- The legal entity on the commercial invoice is not the entity registered in CARM.
- Delegation to the broker expired, or was never granted for the second broker.
- The surety bond lapsed for non-payment of premium and nobody noticed until a release was refused.
- Security was sized for last year's volumes and the importer grew.
- The sole BAM left the company.
- A non-resident importer assumed their Canadian customer's account covered them. It does not — if you are the importer of record, you register, even from outside Canada.
None of these are customs-classification problems. They are administrative, and they are all preventable with a calendar reminder.
A quarterly review
Once a quarter, confirm: BAM list current, delegations active and correctly scoped, bond in force with a known renewal date, security amount still appropriate for your volumes, statements reconciled with nothing outstanding. Fifteen minutes.
Getting your duty right depends on getting your valuation and classification right, and that starts upstream — with your Incoterms, your supplier documentation, and a real landed-cost model. CARM is the collection layer sitting on top of all that. It does not forgive a bad declaration; it just makes the bill arrive faster and with your name on it.
The importers who have trouble with CARM are rarely the ones who misunderstood a rule. They are the ones who set it up once, in a rush, and never looked at it again. Assume your registration has drifted, go and check it this week, and confirm anything specific against CBSA's current guidance rather than a guide written last year.