De minimis thresholds for duty and tax remission
Canada operates a de minimis regime under which low-value shipments may be imported without payment of customs duties and, depending on the threshold met, excise taxes (including the Goods and Services Tax (GST), Harmonized Sales Tax (HST), and Provincial Sales Tax (PST)). The operative thresholds and the applicable tax relief depend on the mode of transport and, in the case of courier shipments, the country of direct export.
Courier shipments: CUSMA-enhanced thresholds from the United States or Mexico. Section 4.1 of the Courier Imports Remission Order (CIRO), SI/85-182, as amended by SI/2020-34 effective July 1, 2020, implements Canada's obligations under Article 7.8(1)(f) of the Canada–United States–Mexico Agreement (CUSMA). For goods imported from Mexico or the United States that are transported by courier, remission is granted of:
- (a) customs duties paid or payable, if the goods have a value for duty of CAD $150 or less; and
- (b) excise taxes paid or payable, if the goods have a value for duty of CAD $40 or less.
The term "courier" is defined in section 2 of the CIRO as "a commercial carrier that is engaged in scheduled international transportation of shipments of goods other than goods imported by mail." Critically, goods do not need to originate from a CUSMA Party to benefit from the higher thresholds; however, they must be shipped from the United States or Mexico and the goods must have entered into the commerce of either Party prior to shipment to Canada. Goods that are merely transshipped via the United States or Mexico—that is, goods that do not enter the commerce of those countries—are subject to the lower CAD $20 threshold set out in section 4 of the CIRO.
Courier shipments from all other countries. Section 4 of the CIRO, as amended by SI/92-128, grants remission of customs duties and excise taxes in respect of imported goods, other than goods imported from Mexico or the United States, that are transported by courier and have a value for duty of CAD $20 or less. This CAD $20 threshold remains the baseline for courier shipments from countries other than the United States and Mexico.
Mail shipments. The Postal Imports Remission Order (PIRO), SI/85-181, provides a remission regime parallel to the CIRO. Section 4 of the PIRO, as amended by SI/92-129, grants remission of customs duties and excise taxes paid or payable on goods imported by mail and having a value for duty not exceeding CAD $20. The CUSMA-enhanced thresholds do not apply to postal shipments; mail imports from the United States and Mexico remain subject to the CAD $20 threshold.
Excluded goods. Section 2 of both the CIRO and the PIRO defines "goods" to exclude the following categories, which are therefore ineligible for de minimis remission even if they fall below the relevant value thresholds:
- (a) alcoholic beverages, cannabis products, vaping products, cigars, cigarettes, and manufactured tobacco;
- (b) goods classified under tariff item No. 9816.00.00 in the List of Tariff Provisions (casual goods previously exported from Canada) and goods for which the value for duty is reduced by the application of section 85 of the Customs Tariff (goods subject to drawback or refund); and
- (c) goods that are imported by a person other than the person in Canada who ordered or purchased the goods (shipments through intermediaries or freight forwarders).
Anti-avoidance: shipment-splitting prohibition. CBSA Memorandum D8-2-16 affirms that to receive the benefit of the CIRO, the total shipment must be subject to a single transaction. It is not acceptable to divide a shipment into several packages so that individual shipments have a value for duty below the thresholds prescribed in the CIRO. If the value for duty of the shipment exceeds the thresholds, customs duties are applicable to the entire value of the shipment in accordance with the Customs Tariff. The transaction-aggregation rule prevents an importer from artificially fragmenting a single order to fall under the de minimis ceiling.
Claim procedure. If the benefit of remission is not received at the time of importation, section 5 of the CIRO and PIRO provides that remission is granted on condition that a claim for remission is made to the Minister of National Revenue. Post-importation, CBSA may request source documentation to substantiate the claim, which may include a commercial invoice, Canada Customs Invoice, or proof of payment.
Intersection with other programs. The de minimis remission regime is distinct from—and may be claimed in conjunction with—the low-value shipment (LVS) threshold of CAD $3,300, which governs simplified reporting, release, and accounting procedures but does not convey duty or tax remission. Section 7(2)(a) of the Accounting for Imported Goods and Payment of Duties Regulations, SOR/86-1062, expressly permits certain goods to be released without a requirement of accounting if the goods are within the scope of the Postal Imports Remission Order or the Courier Imports Remission Order.
Source: Courier Imports Remission Order, SI/85-182 Source: Postal Imports Remission Order, SI/85-181 Source: CBSA Memorandum D8-2-16, Courier Imports Remission Source: Accounting for Imported Goods and Payment of Duties Regulations, SOR/86-1062
Customs bonded warehouses — licensing, storage limits, and duty deferral
Customs bonded warehouses (CBWs) are privately operated facilities licensed and regulated by the Canada Border Services Agency (CBSA) under the Customs Bonded Warehouses Regulations, SOR/96-46, made pursuant to sections 91–100 of the Customs Tariff. A CBW permits importers to store imported goods — and to consolidate imported and domestic goods destined for export — without payment of customs duties, excise duties, or taxes (including GST/HST) for the period the goods remain in the warehouse. Duty and tax deferral is complete for goods subsequently exported; duties and taxes become payable only on goods released for entry into the Canadian domestic market.
Licensing authority and application. Section 3(1) of the Regulations provides that the Minister of Public Safety and Emergency Preparedness may issue a licence to a person to operate a bonded warehouse if the applicant (a) provides such security as may be required under subsection 91(4) of the Customs Tariff and in accordance with section 4 of the Regulations, and (b) meets the requirements of section 3(4), which include that the Canada Border Services Agency is able to provide customs services with respect to the proposed bonded warehouse. An application for a licence must be submitted in the prescribed form (CBSA Form E401) together with a detailed plan of the proposed bonded warehouse indicating whether the place exists or is to be constructed, the type of construction, and the area within the place to be used for storage of goods (section 3(2) and (3)). Both Canadian residents and non-residents may apply to operate a CBW; applicants may operate a private bonded warehouse (for storage of their own imported goods) or a public bonded warehouse (for storage of goods imported by various importers).
Security requirement. Section 4 of the Regulations, as amended by SOR/2024-41, provides that security must be provided in accordance with the requirements of the Financial Security (Electronic Means) Regulations. CBSA policy (Memorandum D7-4-4) specifies that operators of a customs bonded warehouse must post security of, at minimum, 60% of the maximum total amount of duties and taxes payable at any time following the issuance of the licence. Security is payable to the Receiver General for Canada.
Maximum storage period: four years. Imported goods may be stored in a customs bonded warehouse for up to four years from the date the goods are first accounted for on the Commercial Accounting Declaration (CAD). This limit is set out in section 2(b) of the Storage of Goods Regulations and confirmed in CBSA Memorandum D4-1-7, "Extension of Time Limits for the Storage of Goods." Exceptions to the four-year limit are outlined in Schedule II to the Storage of Goods Regulations; these exceptions include, among others, goods held by auction houses for sale by auction, certain cultural or heritage goods, and vehicles subject to safety or emissions certification processes. Upon written request, the CBSA may extend the maximum storage time limit for goods held in a customs bonded warehouse pursuant to subsection 37(3) of the Customs Act, where extenuating circumstances preclude the removal of unclaimed goods (with the exception of tobacco products, packaged spirits, and vaping products) within the specified time limits. Extensions are considered on a case-by-case basis and must be requested prior to the expiration of the specified time limit.
Allowable activities and manipulation. The Customs Bonded Warehouses Regulations permit certain activities to be performed in a CBW that do not change the condition of the goods. Section 20 of the Regulations, as incorporated by reference in licence terms and conditions, allows goods to be manipulated, unpacked, packed, altered, or combined with other goods only for the purpose or in the course of specific operations listed in the Schedule to the Regulations, including: disassembling or reassembling goods that have been assembled or disassembled for packing, handling, or transportation; displaying, inspecting, or testing goods; ticketing goods with origin information or price; marking, labelling, tagging, or otherwise preparing goods for shipment or sale; packing and unpacking; cleaning, preserving (by the application of preservative, lubricants, protective encapsulation, freezing, drying, or freeze-drying, provided the condition of the goods is not changed), maintaining, and repairing goods; sorting, grading, trimming, filing, slitting, and cutting goods; diluting or blending goods with domestic or imported goods; and removing a small quantity of material, a portion, a piece, or an individual object that represents the goods, for the sole purpose of soliciting orders. Section 20 expressly provides that goods in a CBW shall not be further manufactured. Item 3 of the Schedule contains special provisions allowing goods to be held for marking purposes or display at conventions, exhibitions, or trade shows for up to 90 days, after which the goods must be either exported from or entered (accounted for under section 32 of the Customs Act) in Canada.
Restrictions on certain goods. Section 15 of the Regulations prohibits licensees from receiving into or removing from a bonded warehouse imported tobacco products, or imported packaged spirits or wine, unless the goods are to be removed for sale to a foreign diplomat in Canada, export from Canada, sale to a duty-free shop, or use as ships' stores (and, in the case of spirits or wine, supply to an air carrier licensed under the Canada Transportation Act to operate an international service). Section 16.1, added by SOR/2019-70, prohibits licensees from receiving into or removing from a bonded warehouse imported vaping products unless they are to be removed for sale to a foreign diplomat in Canada or export from Canada.
Suspension and cancellation of licence. Section 8(1) of the Regulations provides that the Minister of Public Safety and Emergency Preparedness may suspend or cancel a licence where the licensee (a) is the subject of a receivership; (b) fails to comply with any Act of Parliament, or any regulation made pursuant to an Act of Parliament, that prohibits, controls, or regulates the importation or exportation of goods; (c) has acted dishonestly in business dealings with customs brokers, importers, carriers, or Her Majesty; (d) has not met any of the requirements set out in sections 11 and 12 (which govern storage, identification, and control of goods within the bonded warehouse); or (e) has been incompetent in the operation of the bonded warehouse. Section 8(2) further permits the Minister to cancel a licence where (a) the volume of goods being received is no longer sufficient to warrant continued operation; (b) there is no longer a need for a bonded warehouse in the area; (c) the CBSA is no longer able to provide customs services; or (d) the licensee manipulates, unpacks, packs, alters, or combines goods while in the bonded warehouse other than in accordance with the terms and conditions set out in the licence. Section 9(1) provides that immediately after suspending a licence, the Minister must give the licensee a notice that confirms the suspension and provides all relevant information concerning the grounds for the suspension. Where a licence is suspended, an officer may lock and seal the bonded warehouse and keep it locked and sealed during the period of suspension (section 8(3)).
Operator liability for duties. Section 28(1) of the Customs Act provides that the operator of a bonded warehouse is liable for all duties or taxes levied under the Customs Tariff, the Excise Act, the Excise Act, 2001, the Excise Tax Act, the Special Import Measures Act, or any other law relating to customs on goods that have been received in the warehouse unless the operator proves (a) that the goods were delivered to the importer or owner or to a person authorized by the importer or owner; (b) that the goods were exported in accordance with the Customs Act; or (c) that the goods were destroyed under such conditions as may be prescribed.
Integration with other government departments. All goods being entered into a CBW are considered to be imported into Canada and are required to meet all other government department requirements and conditions (such as permits, authorizations, waivers, and rulings under the Participating Government Agencies (PGA) regime). Goods subject to Tariff Rate Quotas (TRQs) must present the required documentation upon entry; goods without permits or authorization may not be allowed to enter a customs bonded warehouse. This requirement is confirmed in CBSA Memorandum D7-4-4, which states that the CBW program does not waive the import-control requirements of other Acts of Parliament.
Source: Customs Bonded Warehouses Regulations, SOR/96-46 Source: CBSA Memorandum D7-4-4, Customs Bonded Warehouses Source: CBSA Memorandum D4-1-7, Extension of Time Limits for the Storage of Goods Source: Customs Act, R.S.C., 1985, c. 1 (2nd Supp.), s. 28
Duty drawback — refund on exported goods
Canada's duty drawback program permits importers, exporters, processors, and owners of goods to claim a refund of customs duties, excise duties, and anti-dumping / countervailing duties (but not the Goods and Services Tax / Harmonized Sales Tax (GST/HST)) paid on imported goods that are subsequently exported from Canada. Drawback operates as post-export duty recovery, distinct from the Duties Relief Program (which grants upfront exemption from duty at the time of importation for goods that will later be exported) and from customs bonded warehouses (which defer duty while goods remain in the warehouse). The statutory framework is set out in section 113 of the Customs Tariff, S.C. 1997, c. 36, and is operationalized through the Goods Imported and Exported Refund and Drawback Regulations, SOR/96-42.
Statutory authority. Section 113(1) of the Customs Tariff grants a refund or drawback of "all or a portion of duties" if (a) relief or a refund of all or a portion of the duties could have been, but was not, granted under section 89 or 101 of the Act at the time of importation. Section 89(1) describes the scenarios in which relief may be granted, and section 113(1) extends those scenarios to circumstances where the importer paid duties at the time of entry but the goods subsequently satisfy one of the export-related conditions. Section 113(2) authorizes the Governor in Council to make regulations prescribing (among other matters) the portion of duties that may be granted as a drawback, the persons or classes of persons who may apply, the time within which an application must be made, goods that are considered to be "of the same class" or "in the same condition," and restrictions as to classes of goods for which a drawback may be granted.
Eligible scenarios. Under the Goods Imported and Exported Refund and Drawback Regulations, SOR/96-42, Part I (sections 3–14.1) applies to the grant of a drawback under subsection 113(1) of the Customs Tariff in respect of imported goods described in subsection 89(1) of the Customs Tariff, other than goods in respect of which the Exported Motor Vehicles Drawback Regulations apply (section 3 of the Regulations). Section 89(1) of the Customs Tariff identifies five categories of imported goods for which relief (or, retrospectively, drawback) may be granted:
- (a) Goods imported for processing or further manufacturing, that are exported in the same condition (other than incidental alterations such as repacking or displaying, inspecting, or testing);
- (b) Goods that are consumed, expended, or absorbed directly in the processing or manufacture in Canada of goods that are subsequently exported—often called "duty drawback on inputs" or "further manufacture";
- (c) Domestic or imported goods that are used or consumed in the processing or manufacture in Canada of other goods that are subsequently exported, provided the domestic or imported goods are of the same class as imported goods on which duties were paid;
- (d) Imported goods that are exported in the same condition but for which identical, equivalent, or similar domestic goods or imported goods of the same class were substituted (the "substitution drawback" mechanism); or
- (e) Identical, equivalent, or similar domestic goods or imported goods of the same class that are used or consumed in the processing or manufacture of other goods subsequently exported, and for which imported goods on which duties were paid may be treated as having been consumed (the "substitution + consumption" drawback).
"Same class" for domestic and imported goods is defined in section 11 of the Regulations: goods are considered to be of the same class if they are "so similar that they may be used interchangeably in the processing or manufacture of other goods."
Eligible claimants. Section 9(1) of the Regulations provides that a drawback may be claimed by any person who is the importer or exporter of the imported or exported goods, or is the processor, owner, or producer of those goods between the time of their direct shipment to Canada and their export or deemed export. Section 9(2) provides a special restriction: in the case of spirits, wine, or beer described in paragraph 89(1)(b) of the Customs Tariff (goods consumed directly in production of exported goods), a drawback may be claimed only by the importer of the goods. Section 119 of the Customs Tariff further requires that an application for drawback must be accompanied by a waiver, in the prescribed form, from every other person eligible to claim a drawback, to prevent double recovery.
Application deadline. Section 8 of the Regulations, as amended by SOR/2020-64, provides that an application for a drawback must be made within four years after the date on which the imported goods were released. This four-year limitation is a statutory ceiling; late applications are not accepted. CBSA Memorandum D7-4-2, last updated November 24, 2025, confirms this four-year window and specifies that applications are now submitted via the CARM Client Portal (CBSA's Assessment and Revenue Management system).
Documentation and proof of export. The application for drawback must be accompanied by supporting documents demonstrating that the conditions prescribed in the Act and Regulations have been satisfied, which may include (but are not limited to) a copy of the export sales invoice and proof of exportation (Memorandum D7-4-2, paragraphs 7–10). Acceptable proof of exportation is described in CBSA Memorandum D20-1-4, Proof of Exports, Canadian Origin and Destruction of Commercial Goods, and typically consists of a stamped export declaration, carrier waybill, or customs-certified export document from the destination country. For goods that are merely transferred between Duties Relief Program participants (certificate holders), a transfer certification is used, but export documentation is required at the time the goods ultimately leave Canada.
Exclusion for goods damaged before export. Section 4 of the Duties Relief Regulations, SOR/96-44 (which applies by cross-reference to the drawback regime), provides that relief—and by extension drawback—may not be granted in respect of the imported goods where the exported goods are damaged before being exported. This exclusion prevents recovery on goods that have lost value due to damage that occurred while in Canada.
Exclusions for certain goods classes. Section 5 of the Duties Relief Regulations provides that, for purposes of paragraphs 89(1)(c) and (e) (the "same class" and substitution scenarios), relief may not be granted in respect of the goods described in Schedule I to the Regulations, which enumerates specific tariff headings or categories of goods that are ineligible for substitution drawback. (Schedule I includes, among others, certain motor vehicles, textile and apparel articles, and agricultural products subject to tariff-rate quotas.)
CUSMA (formerly NAFTA) restrictions: the "lesser-of" rule. When imported goods (or substitutes) are used as materials in the production of other goods that are subsequently exported to the United States or Mexico and that benefit from preferential tariff treatment under CUSMA (the Canada–United States–Mexico Agreement), section 113 drawback and section 89 relief are subject to CUSMA Article 5.7 restrictions. CBSA Memorandum D7-4-3, CUSMA Requirements for Drawback and Duty Deferral Programs, explains that the drawback or relief of customs duties shall not exceed the lesser of (a) the total amount of customs duties paid or owed on the imported goods when imported into Canada, and (b) the total amount of customs duties paid on the goods when imported into the United States or Mexico. This "lesser-of" calculation prevents a CUSMA Party from refunding more duty than the importing CUSMA country collected. The CUSMA drawback restrictions do not apply to goods that originate in a CUSMA Party under Chapter 4 (Rules of Origin) of CUSMA, nor to goods exported to non-CUSMA countries. Similar restrictions apply under other Canadian free-trade agreements that include drawback-limitation articles, including CETA (with the European Union), CUKTCA (with the United Kingdom), and CPTPP.
GST/HST exclusion. Section 2 of Memorandum D7-4-2 and paragraph 30 of the French-language version of the same memorandum confirm that the Goods and Services Tax / Harmonized Sales Tax (GST/HST) cannot be refunded through the duty drawback mechanism. Importers seeking recovery of GST/HST on exported goods must apply to the Canada Revenue Agency under the Excise Tax Act and its GST/HST rebate provisions (typically a GST/HST rebate for exports or the Input Tax Credit mechanism).
Interest on late payment of drawback. Section 127 of the Customs Tariff (as referenced in sections 114 and 115 of the Customs Tariff) provides that any person who receives a drawback of duties other than duties levied under the Special Import Measures Act (AD/CVD duties) is entitled to interest at the prescribed rate, calculated from the 91st day after the CBSA receives the application and ending on the day the drawback is granted. For drawbacks of AD/CVD duties, interest accrues at the prescribed rate for each month or part of a month from the 91st day after the CBSA receives the application until the day the drawback is granted (Memorandum D7-4-2, paragraphs 29–30).
Repayment obligation if ineligible. Section 114(1) of the Customs Tariff imposes a statutory obligation on any person who receives a refund or drawback and is subsequently found not to be eligible for all or part of it: the person must pay to His Majesty in right of Canada, on the day the refund or drawback is received, (a) any amount for which the person is not eligible, and (b) any interest granted under section 127 on that amount. While the amount remains unpaid, it is deemed to be a debt owing to His Majesty under the Customs Act (section 114(2)).
Source: Customs Tariff, S.C. 1997, c. 36, s. 113 Source: Goods Imported and Exported Refund and Drawback Regulations, SOR/96-42 Source: Duties Relief Regulations, SOR/96-44 Source: CBSA Memorandum D7-4-2, Duty Drawback Program (updated November 24, 2025)
Release prior to payment (RPP) — enrolment, financial security, and operational requirements
Release Prior to Payment (RPP) is an optional sub-program of the CBSA Importer Program that permits importers to obtain release of goods before paying customs duties and taxes, provided they post adequate financial security with the Canada Border Services Agency. RPP is the standard operating procedure for most commercial importers in Canada; without it, importers must submit a CAD Type C (cash entry) and pay all duties and taxes at the port of entry before goods are released. RPP authorization shifts the payment deadline from the moment of release to the monthly statement-of-account (SOA) payment due date, which falls on the last business day of the month following the billing period, enabling importers to obtain goods immediately and defer payment by up to approximately 60 days.
Enrolment and financial security requirement. To enrol in RPP, importers must provide financial security at the importer program account level (the BN15 RM account) and in the legal entity name registered against the business number. Enrolment is complete when an approved form of financial security meeting CBSA requirements has been accepted (CBSA Memorandum D17-1-8, paragraph 2; Memorandum D17-5-2, paragraph 2). The amount of security required is calculated by the CBSA and equals the highest monthly accounts-receivable balance (including customs duties, excise duties, GST/HST, and special-import-measures duties) over the preceding 12 months for the RM account in question (Memorandum D17-1-8, paragraph 15). The 12-month review period runs from July 25 of the prior year to July 24 of the current year (Memorandum D17-1-8, paragraph 24).
Importers who exclusively import goods unconditionally free of duties and taxes are not required to post financial security to maintain RPP enrolment; however, if the CARM system subsequently determines that duties or taxes are owed on a transaction, the importer will be required to post security or make a payment before further releases are authorized (Memorandum D17-1-8, paragraph 19; CBSA Customs Notice 25-22, paragraph 6).
Forms of security. The CBSA accepts two primary forms of financial security under the Financial Security (Electronic Means) Regulations, SOR/2024-42, which came into force on October 21, 2024 as part of CARM Release 3:
- Written Security Agreement (surety bond or financial-institution bond), which must be posted in an amount equal to at least 50% of the CBSA-calculated requirement, with a minimum of CAD $5,000 per RM account. The bond is provided by a CBSA-approved security provider (surety company, bank, trust company, or loan company) and is electronically transmitted to CARM via API. The 50% threshold reflects the fact that bonds provide the CBSA with recourse against the surety or financial institution in the event of default.
- Security deposit (cash deposit), which must be posted at 100% of the CBSA-calculated requirement. There is no minimum for a deposit, but deposits do not benefit from the 50% reduction applicable to bonds. Deposits are posted directly in the CARM Client Portal (CCP) by the importer.
Both forms of security are subject to a ceiling of CAD $10 million per RM account for all forms of security combined (Memorandum D17-1-8, paragraph 16). In exceptional circumstances where it is impracticable for an importer to provide electronic security due to circumstances outside the importer's control, the CBSA may approve non-electronic forms of financial security on a case-by-case basis; approval requests must be submitted to the CBSA RPP Financial Security inbox (Memorandum D17-5-2, paragraph 6).
CARM transition and current status. CBSA Assessment and Revenue Management (CARM) Release 3 was implemented on October 21, 2024, and introduced mandatory importer-provided financial security for RPP participants. Prior to CARM, many importers relied on their licensed customs broker's security to obtain release. Under CARM, importers must post their own security or elect to pay cash at the time of release. The CBSA granted a 180-day transition period during which importers enrolled in the Importer Program could benefit from RPP without posting security (pursuant to the Regulations Amending Certain Regulations Administered and Enforced by the Canada Border Services Agency, SOR/2024-178, subsection 69(2)). This transition period was extended by 30 days and ended on May 20, 2025 at 3:00:01 a.m. EDT (CBSA Customs Notice 25-22, paragraph 3). As of that date, importers without adequate financial security on file are not eligible for release using interim accounting service options (IID, PARS, or paper RMD) and must instead submit a CAD Type C (full accounting declaration) and pay all duties and taxes before release (Customs Notice 25-23, paragraph 2).
Security monitoring and utilization thresholds. Importers enrolled in RPP must ensure that the total security coverage is always higher than the account net open balance (debts minus available credits). The CARM system sends automated notifications to the importer when the utilization rate reaches 75% and 100% of posted security (Memorandum D17-5-2, paragraphs 9–10). When the net open balance meets or exceeds 100% of the posted security, the importer must either make a payment to reduce the outstanding balance or post additional security; failure to do so will result in suspension of RPP privileges, and the importer will be unable to obtain release without paying cash at the time of entry. Security levels are monitored continuously by the CBSA in the CARM system, and failure to comply with security requirements may also result in suspension or revocation of the release privilege and may trigger an Administrative Monetary Penalty (AMP) assessment (Memorandum D17-1-8, paragraph 25).
Annual security review and adjustments. CBSA recalculates the required security amount annually based on the importer's highest monthly accounts-receivable balance over the prior 12 months. Importers may request a modification (reduction or increase) of the system-calculated security requirement through the CARM Client Portal before the end of the annual review period (July 24); the CBSA may require supporting evidence to approve a reduction request (Memorandum D17-5-2, paragraph 8.4). Requests submitted after the end of the review period or after removal from the RPP program during the transition period are treated as new requests and must include updated rationale (Customs Notice 25-22, paragraph 12).
Liability and demand on security. The security holder (whether the importer or the customs broker providing the bond) is liable for payment of all debts recorded on the customs account that were covered by the financial security during its effective period (Memorandum D17-5-2, paragraph 15). The CBSA may initiate a demand against the security provider after reasonable attempts to collect from the debtor have failed or when the debtor has filed for bankruptcy or receivership. For Written Security Agreements (bonds), the CBSA may demand payment up to one year after the termination or expiry date of the bond, but only for debts incurred prior to the termination date (Memorandum D17-5-2, paragraph 17). For security deposits (cash), the CBSA will withhold a sufficient portion of the deposit to cover the amount owing (Memorandum D17-5-2, paragraph 15.2).
Alternative for non-RPP importers: cash entries. Importers who do not participate in the RPP program are required to pay duties and taxes at the time of release. Such importers must present a Commercial Accounting Declaration Type C (CAD-C or "cash entry") and make payment at the CBSA office where the goods are released (Customs Notice 25-22, paragraph 7; Memorandum D17-5-1). Payment may be made by electronic means, cheque, or—in exceptional circumstances and with prior CBSA approval—bank remittance. Non-resident importers may authorize a licensed customs broker to make payments on their behalf.
RPP Contingency Plan (broker-assisted release for time-sensitive or health-essential goods). Effective May 20, 2025, the CBSA reinstated a limited RPP Contingency Plan to address release of time-sensitive/perishable goods and goods deemed necessary to support an individual's continued health and well-being when the true importer lacks RPP privileges. Under the contingency plan, licensed customs brokers may use a special "RPP Contingency" BN15 (backed by the broker's own cash security deposit) to obtain release on behalf of such importers, provided the broker has not been delegated CARM Client Portal authority by the importer and the goods meet the contingency eligibility criteria. The broker must include the true importer's name, BN15, and street address in the IID release transmission. The contingency plan is temporary and will end upon notice by the CBSA (Customs Notice 25-23, paragraphs 8, 15).
Source: CBSA Memorandum D17-1-8, Release Prior to Payment Privilege (October 21, 2024) Source: CBSA Memorandum D17-5-2, Financial Security for Release Prior to Payment (October 21, 2024) Source: Financial Security (Electronic Means) Regulations, SOR/2024-42 Source: CBSA Customs Notice 25-22, End of Release Prior to Payment (RPP) Transition Period Source: CBSA Customs Notice 25-23, CARM RPP Contingency Plan