Non-Resident Importer (NRI) Guide: How a Foreign Business Imports Into Canada

What Is a Non-Resident Importer?

A non-resident importer is a business without a place of business in Canada that acts as the importer of record for goods entering Canada. A U.S. manufacturer that sells to Canadian customers on a delivered basis, and clears the goods in its own name, is a typical example.

CBSA treats a non-resident importer like any other importer: it has the same obligations as a resident importer, owner or consignee of the goods. That includes accurate declarations, paying duties and taxes, keeping records and correcting errors. See Importer of Record Responsibilities in Canada.

NRI or Canadian importer of record?

A foreign seller doesn't have to be the importer. If the Canadian buyer is the importer of record, the buyer uses its own Business Number and import account. Becoming an NRI makes sense when the foreign business wants to sell to Canadian customers with duties and taxes already handled, so its customers receive the goods without import paperwork.

Registration Is Mandatory, and It's Yours to Complete

Every commercial importer, resident or not, needs its own Business Number, RM import account and CARM registration before its goods can be cleared. These are registrations the business completes itself:

• The Business Number is issued by the CRA to the business, not to its broker
• CBSA's CARM rules say importers register themselves; customs brokers can't register on an importer's behalf
• The business's own staff become the CARM business account manager and decide who else gets access

Garden City cannot import your goods on our Business Number. Once your registrations are done, you delegate Garden City in CARM and we clear your shipments as your customs broker.

Step by Step: Setting Up as a Non-Resident Importer

1. Get a Business Number from the CRA

   Non-residents register for a BN with the CRA, not through CARM. The CRA's page is for businesses incorporated or located outside Canada, and individuals with no social insurance number or one starting with 0.

   The easiest way is the CRA's Non-Resident Business Registration online form, which can also register GST/HST and other CRA program accounts at the same time. It's available 21 hours a day (not from 3 to 6 a.m. Eastern), times out after 30 minutes of inactivity, and can't be saved part way. If you can't use the online form, send Form RC1 to the CRA by mail or fax: CRA: Business number registration for non-residents.

2. Register your business in the CARM Client Portal

   With the BN9 in hand, create a user profile in the CARM Client Portal and choose to register your business. The first person to register becomes the business account manager (BAM); CBSA recommends naming a backup BAM. CBSA asks non-residents to get their BN9 from the CRA before starting, to avoid errors: CBSA: Register for the CARM Client Portal.

3. Set up the RM import-export account

   The RM account (for example RM0001) is the import-export program account attached to your BN9. Since October 21, 2024 it is administered by CBSA, and an importer that doesn't have one yet can get it while registering in CARM.

4. Arrange your books and records

   Importers must keep their import records in Canada unless CBSA approves otherwise. A non-resident can have a licensed customs broker, accountant or other authorized agent keep them in Canada, or apply through the CARM Client Portal for an Agreement to Maintain Records Outside Canada (form BSF900). See below.

5. Decide on Release Prior to Payment

   CBSA recommends importers consider the Release Prior to Payment (RPP) privilege, which lets goods be released before duties and taxes are paid and requires financial security. Without it, duties and taxes are paid before the goods are released. See Release Prior to Payment in Canada.

6. Delegate your customs broker

   In CARM, delegate authority to your customs broker so it can act for your business. Then send the broker your commercial invoices and shipment details for each load.

Keeping Records Outside Canada

A non-resident importer usually has no place of business in Canada, which is where Canadian law expects import records to be kept. There are two options:

• Keep them in Canada through an agent: a licensed customs broker, accountant or other authorized agent maintains them for you
• Keep them outside Canada with CBSA approval: apply through the CARM Client Portal for an Agreement to Maintain Records Outside Canada, using form BSF900, Agreement to Maintain Records Elsewhere than the Place of Business in Canada

The application must give the corporate address, the place-of-business address, the address where the records will be kept, and the agent's name and relationship to the importer. Post office boxes and mail forwarding services are not accepted. Either way, the importer stays legally responsible for keeping the records and producing them when CBSA asks.

GST and Other Taxes

A non-resident importer pays GST, or the federal part of the HST, on most commercial goods it imports into Canada, whether or not it is registered for GST/HST.

Whether it can get that tax back depends on its registration. A GST/HST registrant can generally claim an input tax credit for import GST. A non-registrant can't, although a GST/HST-registered Canadian customer who receives the goods may be able to. Some non-residents can register voluntarily. Tax registration is a CRA matter, so confirm your situation with the CRA or a tax advisor: CRA RC4027: GST/HST information for non-residents.

For how duties, GST and surtaxes are calculated, see Understanding Duties, Taxes & GST in Canada.

Licences and Permits for Regulated Goods

An NRI's goods face the same permit rules as anyone else's. For example, most foods need a Safe Food for Canadians licence to import; the CFIA says non-resident importers without a fixed place of business in Canada may be able to get one. See Import Permits and Regulated Goods.

How Garden City Works With Non-Resident Importers

Garden City Customs Services Inc. supports commercial importers and non-resident commercial importers. We can explain what each registration involves and what to have ready, but the CRA and CARM registrations must be completed by your business. Once you are registered and have delegated us in CARM, we prepare and submit your customs declarations, release requests and accounting as your customs broker.

Trucking into Ontario through Niagara? We have offices at the Peace Bridge and the Queenston-Lewiston Bridge. See also What Is a PARS Number?

Official Sources

• CRA: Business number registration for non-residents
• CBSA: Register for the CARM Client Portal
• CBSA Memorandum D17-1-21: Maintaining books and records
• CRA RC4027: Doing Business in Canada, GST/HST information for non-residents
• CFIA: Importing food with a Safe Food for Canadians licence