Importing from China into Canada: CARM, duties, surtaxes, permits and product rules

Business number, CARM registration and financial security

An importer needs a 9-digit business number (BN9) from the Canada Revenue Agency (CRA) and an import-export program account (RM), which together form the 15-character BN15. The Canada Border Services Agency (CBSA) sets out the full process in its step-by-step guide to importing commercial goods.

• CARM: the importer itself must register in the CARM Client Portal. A customs broker cannot register on the importer's behalf. The first person to register becomes the Business Account Manager, and CBSA recommends at least two. Sign-in is by GCKey or Interac Sign-in Partner with multi-factor authentication.
• Release Prior to Payment (RPP): to get goods released before paying duties and taxes, the importer must enrol in RPP and post its own financial security in the portal, either a cash deposit or a surety bond. A broker's security can no longer be used. The transition period ended on 2025-05-20 (Customs Notice 25-22). Importers without security pay at the time of release. Importers of only zero-rated goods remain eligible without security.
• Non-resident importers, for example a Chinese supplier acting as importer of record, first obtain a BN from the CRA through the non-resident registration process, then register in CARM.

The importer of record remains liable for duties and taxes even when a broker is used. A common mistake is letting the broker "handle CARM".

What changed in 2025 and 2026

Several rules that importers of Chinese goods relied on in 2024 no longer apply. In date order:

• 2025-05-20: the CARM transition period for Release Prior to Payment ended. Importers need their own financial security.
• 2025-07-31: a 25% surtax on steel goods containing steel melted and poured in China, and aluminum goods containing aluminum smelted and cast in China, whatever the country of export. Mill test certificates or similar documents are required from 2025-09-22.
• 2025-12-26: steel tariff rate quotas for non-FTA countries, including China, were set at 20% of 2024 import volumes with a 50% surtax above quota, and a 25% surtax began on listed steel derivative products from all countries.
• 2026-01-30: the China surtax remission order was extended from 2025-12-31 to 2026-12-31 and widened (SOR/2026-14).
• 2026-03-01: the 100% surtax on Chinese EVs was repealed and replaced by an import permit and a 49,000-vehicle quota at the 6.1% MFN duty. The second quota period opened on 2026-09-01.
• 2026: the Global Affairs Canada backgrounder on the January 2026 arrangement says Canada will not impose the tariffs on Chinese solar products and semiconductors that were floated in 2024.
• 2026: CBSA's proposed amendments to the Valuation for Duty Regulations were paused after a consultation that ran from 2025-12-03 to 2026-01-23.

Tariff classification and treatment: China pays MFN, not GPT

Every product is classified under a 10-digit number in Canada's Customs Tariff; the first six digits are the international HS code. The current schedule is the Customs Tariff 2026, effective 2026-01-01, published by CBSA on its Customs Tariff page.

China has not been eligible for the General Preferential Tariff (GPT) since 2015-01-01. The General Preferential Tariff Withdrawal Order (2013 GPT Review), SOR/2013-161, lists China among the countries withdrawn. Canada and China have no free trade agreement. Chinese goods therefore pay the most-favoured-nation (MFN) rate shown in the schedule, before any surtax or trade remedy duty.

What to check:

• The 10-digit classification, since the duty rate, surtax schedules and anti-dumping measures are all defined by product description and tariff item.
• Whether an advance ruling would help. Importers can ask CBSA for a ruling on classification, origin or valuation.
• The Canada Tariff Finder, a Government of Canada tool with BDC and EDC, for a quick look at rates by HS code and country.

Common mistakes are assuming that GPT still applies to China, or that a Canada-China free trade rate exists. Neither is the case, and older quotations or supplier price lists sometimes still reflect the GPT rate.

Electric vehicles: import permit and quota instead of the 100% surtax

The China Surtax Order (2024), SOR/2024-187, imposed a 100% surtax on Chinese EVs from 2024-10-01. SOR/2026-33, in force 2026-03-01, repealed it, and SOR/2026-32 added Chinese-origin EVs to the Import Control List. Global Affairs Canada administers the regime on its page Electric vehicle imports from China.

• Every commercial shipment of covered vehicles needs a shipment-specific import permit. Without it CBSA rejects the entry (Customs Notice 26-05).
• Quota year 1 (2026-03-01 to 2027-02-28) is 49,000 vehicles in two periods of 24,500; unused first-period volume rolls into the second. The quota grows 6.5% a year. Once it is used, no further permits are issued for that year.
• In-quota vehicles pay only the 6.1% MFN duty.
• Eligible applicants are Canadian-resident EV original equipment manufacturers, or Canadian-resident agents appointed by a non-resident manufacturer. Permits are first-come, first-served, can be requested up to 30 days before entry and are valid for up to 60 days.
• Notice to Importers No. 1168 covers the second period from 2026-09-01.

Official utilization data updated 2026-09-11 show 15,603 permits used in the first period and 15,763 of 49,000 used for the year to date. Non-commercial personal imports under Chapter 98 are exempt.

Surtaxes and quotas on Chinese steel and aluminum

Several measures overlap. The Department of Finance page Canada's tariffs: Steel and aluminum says they do not stack: only the highest-priority applicable measure applies to a given product.

• China Surtax Order (2024), Schedule 2: a 25% surtax on listed steel and aluminum products originating in China, in force since 2024-10-22.
• Steel Goods and Aluminum Goods Surtax Order: from 2025-07-31, a 25% surtax on steel goods from any country containing steel melted and poured in China, and on aluminum goods containing aluminum smelted and cast in China. From 2025-09-22 importers must hold mill test certificates or similar documents, not just invoices. Exemptions include US-origin goods and declarations under CAD 5,000. Surtax codes are 25154A (steel) and 25154B (aluminum).
• Steel tariff rate quotas: since 2025-12-26, 20% of 2024 import volumes for non-FTA countries, which includes China, with a 50% surtax above quota.
• Steel Derivative Goods Surtax Order: from 2025-12-26, 25% on listed steel derivative products from all countries.
• Remission: the China Surtax Remission Order (2024) covers goods in short supply, contracts made before 2024-08-26 and exceptional circumstances. SOR/2026-14 extended it to 2026-12-31. Remission is not available for goods resold unchanged to the United States.

A common mistake is buying steel goods from a third country without checking where the metal was melted.

Anti-dumping and countervailing duties under SIMA

Under the Special Import Measures Act (SIMA), CBSA investigates dumping and subsidizing, and the Canadian International Trade Tribunal (CITT) decides whether Canadian producers are injured and runs expiry reviews. The duties are payable by the importer, in addition to regular duty and any surtax.

The place to check is CBSA's Measures in Force list, which was dated 2026-09-02 when this guide was reviewed. China is a subject country for dozens of products on it. Examples include aluminum extrusions, carbon steel welded pipe, concrete reinforcing bar, cold-rolled steel, corrosion-resistant steel sheet, fasteners, mattresses, upholstered domestic seating, photovoltaic modules and laminates, stainless steel sinks, steel wire, thermal paper rolls, decorative and other non-structural plywood, steel racks, container chassis and wind towers.

What to check for each product:

• Whether the goods fall within the product definition of a measure. The definition, not the HS code alone, decides coverage.
• Which exporters have their own rates and what applies to all other exporters.
• Whether an expiry review or re-investigation is under way.

A common mistake is not checking SIMA measures before quoting a landed cost. Anti-dumping duty on items such as upholstered seating, mattresses, fasteners or solar modules can be far larger than the MFN duty.

Forced labour: the import prohibition and the annual report

Two separate obligations apply.

Import prohibition: tariff item 9897.00.00 prohibits goods mined, manufactured or produced wholly or in part by forced labour or prison labour. CBSA administers it under Memorandum D9-1-6 and works with the Labour Program of Employment and Social Development Canada, which researches supply chains. An importer whose goods are detained can seek a tariff classification review under section 60 of the Customs Act, export the goods or abandon them.

Annual reporting: the Fighting Against Forced Labour and Child Labour in Supply Chains Act has been in force since 2024-01-01. An entity must report if it is listed on a Canadian stock exchange, or operates in Canada and meets at least two of three tests (CAD 20 million or more in assets, CAD 40 million or more in revenue, 250 or more employees), and it produces goods, imports goods into Canada, or controls an entity that does. Reports are due by May 31 each year for the previous financial year and are filed through Public Safety Canada's online questionnaire.

Canadian subsidiaries of Chinese companies that import goods are covered on the same terms as any other entity. Common mistakes are missing the May 31 deadline, or assuming that a foreign parent's subsidiary is exempt.

Product safety, electrical certification and radio equipment

Three regulators matter for most consumer and electronic goods from China, and none of them is CBSA.

• Consumer product safety: under the Canada Consumer Product Safety Act, administered by Health Canada, the importer is treated like the manufacturer. Importers must not import or sell products that are a danger to human health or safety, must report incidents and defects (and foreign recalls) to Health Canada and the supplier, and must keep records identifying the supplier and the period and place of sale. Product-specific regulations (toys, children's jewellery, cribs, lighters, phthalates, surface coatings and others) sit under the Act. Health Canada's recalls database is useful for vetting a product type or supplier.
• Electrical safety: certification marks are enforced by provincial and territorial electrical safety regulators, not by CBSA at the border. Ontario's Electrical Safety Authority publishes its list of recognized certification marks and field evaluation labels. It is official for Ontario only; other provinces have their own regulators.
• Radio and telecom equipment: Innovation, Science and Economic Development Canada (ISED), through its Certification and Engineering Bureau, handles certification of radio equipment and links to the Radio Equipment List search. Check that the exact model of any product with Wi-Fi, Bluetooth, cellular or RFID functions is listed.

Bilingual labelling and country of origin marking

Labelling of non-food consumer goods is overseen by the Competition Bureau, whose Labelling page links to the guides for each statute.

• Prepackaged non-food consumer products must show product identity and net quantity in English and French, in metric units, plus the dealer's name and principal place of business.
• Textile articles need fibre content in English and French and a dealer identity (name and address, or a CA number).
• A one-year test-market exemption from bilingual labelling exists, with six weeks' prior notice to the Competition Bureau.

Country of origin marking is a separate customs rule, set out in CBSA Memorandum D11-3-1. Certain categories of goods (personal and household goods, hardware, novelties and sporting goods, paper products, apparel, horticultural products, and goods of steel or aluminum) must be marked with the country of origin in English or French. For non-CUSMA countries such as China, the origin for marking is where the goods were "substantially manufactured". Since 2020-07-01 CBSA issues National Customs Rulings, not advance rulings, on marking. Penalties can be civil (Customs Act section 109.1) or criminal (section 159.1). The phrase "goods that originate in China" in the China Surtax Order is defined by reference to these marking rules.

Common mistakes are English-only packaging, a missing dealer identity and missing fibre content labels on textiles.

Food imports: SFC licence, preventive controls and AIRS

Food is regulated by the Canadian Food Inspection Agency (CFIA) under the Safe Food for Canadians Regulations. The CFIA Food imports page, dated 2026-09-01, is the starting point.

• Most food importers need a Safe Food for Canadians (SFC) licence and a written preventive control plan, and must be able to trace products one step forward and one step back.
• The licence number goes on the import declaration.
• Non-resident importers can hold an SFC licence only in limited circumstances, which the CFIA page explains. This matters to Chinese suppliers that want to act as importer of record for food.
• The Automated Import Reference System (AIRS) gives the import requirements by HS code, origin (China) and end use.
• Meat from China is restricted to specific products and approved establishments.

Common mistakes are importing food without an SFC licence, or holding a licence that does not list importing as an activity for the right commodity. CBSA's guide also lists prohibited goods (used mattresses are one example) and points to the list of commodities that need permits from other departments, so the same check applies to non-food products that fall under another regulator.

Customs value, related-party pricing, GST and low-value shipments

Value for duty is normally the transaction value: the price paid or payable when the goods are sold for export to Canada to a purchaser in Canada, adjusted for items such as assists, royalties, commissions and freight to the place of direct shipment (Memorandum D13-1-1).

• Related parties, for example a Chinese parent selling to its Canadian subsidiary, must show that the relationship did not influence the price. A transfer pricing study can help, but CBSA says a TNMM-based study alone may not be enough (Memorandum D13-4-5). Year-end transfer price adjustments, upward or downward, must be reported as corrections.
• CBSA's proposed "last sale" and "purchaser in Canada" amendments were consulted on from 2025-12-03 to 2026-01-23, and CBSA says work on them is paused.
• GST of 5% is collected by CBSA on most imports. GST registrants can normally claim it back as an input tax credit.
• Courier and mail shipments from China are duty-free and tax-free only up to CAD 20. The CAD 40 (tax) and CAD 150 (duty) thresholds apply only to courier shipments from the United States and Mexico.
• The Courier Low Value Shipment Program streamlines release for shipments valued at CAD 3,300 or less. It does not waive duties, and larger shipments cannot be split. Commercial goods of CAD 3,300 or less are accounted for by the 24th of the month after release.

Before you ship: a checklist

The steps below restate the checks in this guide for the importer and the Chinese supplier. Each one points to a rule and an official source, not to a business decision.

1. Confirm who is the importer of record, that it has a BN15 and a CARM Client Portal account, and that its own financial security is posted if release before payment is wanted.
2. Confirm the 10-digit classification in the Customs Tariff and the MFN rate.
3. Check the CBSA Measures in Force list for anti-dumping or countervailing duty on the product.
4. For steel or aluminum goods from any country, obtain mill test certificates showing where the metal was melted and poured, or smelted and cast, and check the surtax orders and any remission.
5. For electric vehicles, confirm the import permit and the quota remaining before the vehicles ship.
6. Check product rules: consumer product safety, recognized electrical certification marks in the province of sale, the Radio Equipment List, bilingual labels and country of origin marking.
7. For food, confirm the SFC licence covers importing the commodity and look up the requirements in AIRS.
8. Be able to support the declared value, including related-party pricing and year-end adjustments.
9. Review forced labour risk in the supply chain and whether the annual report due May 31 applies.