This is a reminder that as a non-resident importer you must have authorization from the Canada Border Services Agency (CBSA) to maintain books and records outside of Canada with regards to importing activity.
All importers—both Canadian residents and non-residents—are required to be registered on the CBSA Assessment and Revenue Management (CARM) Client Portal to import goods into Canada once CARM is fully implemented.
CBSA has set a target date of October 2023 for the implementation of CARM Release 2.
Non-Resident Importers are required to have their Agreement to Maintain Records Elsewhere than the Place of Business in Canada in place PRIOR to completing the CARM Portal application.
Importers can access documentation about the CARM onboarding process at the following link.
CBSA eManifest and CARM Portal users are required to retain separate records in respect of imported goods in accordance with the information provided in this memorandum. The eManifest and CARM Portals are not to be used for record-keeping.
Importers may also submit a request to the CBSA for an authorization to maintain records at their place of business or other location outside of Canada, more specifically in the United States of America or in Mexico, or designate an agent to keep records on their behalf. The importer must complete the form Agreement to Maintain Records Elsewhere than the Place of Business in Canada that can be found at the following CBSA link: BSF900.
The CBSA regards the authorization to keep records at a place other than the place of business (whether inside or outside of Canada) as the granting of a privilege. Non-compliance will result in the cancelation of the authorization and the possible application of administrative penalties.
An electronic copy of the completed agreement must be sent to cm-go@cbsa-asfc.gc.ca for review prior to sending the original agreement for processing. Once the Agreement has been reviewed and accepted by the CBSA, please mail the original hand signed copy to the following address:
Maintenance of Importer Records Program
Trade Operations Division
Canada Border Services Agency
Courier/street address
1980 Matheson Blvd East
Mississauga ON L4W 5R7
Canada
Alternatively, a signed electronic copy can be sent by email to cm-go@cbsa-asfc.gc.ca. The electronic document must be signed using an advanced electronic signature, which is uniquely linked with and correctly identifies the signatory.
Memorandum D17-1-21 – Maintenance of Records in Canada
BSF900 – Agreement to maintain records elsewhere than the place of business in Canada