Canada's De Minimis Threshold and What It Means for Your Courier Clearances

Key Takeaways

• Canada’s de minimis thresholds remain CAD $20 for duty and CAD $150 for GST/HST, but CARM Phase 2 now requires full CAD filings for shipments previously cleared under simplified courier programs.
• E-commerce parcels from China that once cleared in hours now trigger formal Commercial Accounting Declaration submissions, adding 12 to 48 hours to release timelines.
• Couriers are passing CARM compliance costs downstream, and importers ordering frequent small shipments will see per-parcel fees climb even when duty remains zero.
• If your business imports samples, replacement parts, or marketing materials valued under CAD $3,000 per shipment, review your courier account terms before Q4 peak season hits.

CARM Made Courier Clearances Slower and More Expensive

Canada’s de minimis thresholds have not changed in substance, but the clearance process around them has. Under CARM Phase 2, which went mandatory in May 2024, couriers must submit a full Commercial Accounting Declaration for every commercial parcel, including those valued below the CAD $20 duty exemption or the CAD $150 GST/HST exemption. The old Section 7.3 low-value shipment program allowed simplified reporting with minimal data fields. That program still exists on paper, but CARM’s data requirements have effectively forced couriers to treat every parcel as a formal entry.

The result is longer release windows and higher per-parcel fees, even when no duty is owed. A shipment that cleared in two hours a year ago now waits 12 to 48 hours while the courier’s brokerage team validates the HS classification, confirms the country of origin, and submits the CAD through the CARM Client Portal. The work is the same whether the shipment is worth CAD $15 or CAD $1,500. The fee structure has adjusted accordingly.

Volume Surge from Chinese E-Commerce Platforms

E-commerce parcels from China have grown faster than CBSA’s infrastructure could absorb. Platforms like Temu, Shein, and AliExpress ship millions of individual parcels into Canada each quarter, almost all of them valued under CAD $150. The majority claim duty exemption under the CAD $20 threshold. CBSA has flagged undervaluation as a persistent compliance issue, and couriers are now liable for the accuracy of the declared value and HS code on every LVS declaration they file.

That liability shift has pushed courier brokerage fees up across the board. Where a parcel might have cleared for CAD 10 in processing fees two years ago, the same parcel now carries a CAD 25 to CAD 35 charge to cover the cost of CAD preparation, CARM portal access, and audit defense. If you import samples, replacement parts, or marketing materials in frequent small shipments, those fees add up faster than the duty savings.

What Section 7.3 Used to Do and What CARM Does Now

Section 7.3 of the Customs Act allows the Minister to prescribe alternate reporting for low-value or low-risk shipments. For decades, that meant couriers could batch-report hundreds of parcels per flight with minimal line-item detail, as long as each parcel stayed under a value threshold. CBSA accepted the courier’s summary manifest and released the goods on a trust basis. Formal CBSA verification happened only when a parcel was flagged for exam.

CARM Phase 2 kept the Section 7.3 authority but added data requirements that make batch reporting impractical. Every CAD must include a six-digit HS code, a country of origin, a declared value broken out by line item, and the importer’s business number if the shipment is commercial. Couriers cannot submit a CAD without that data, so they now require full commercial invoices even for parcels that will owe zero duty and zero tax. The compliance burden moved from the courier’s operations team to the shipper and the importer, and most small shippers are not equipped to handle it.

Freight Forwarder Consolidations Offer a Workaround

If your business imports 20 or 30 small shipments per month, courier clearance fees will exceed the actual import duty you would pay on many of those parcels. Freight forwarder consolidation is the obvious answer. A forwarder can batch your shipments into a single master air waybill, clear the consolidated shipment as one CAD, and deliver the goods to a bonded warehouse in Montreal for deconsolidation and local delivery.

The per-kilogram cost is lower, the clearance timeline is more predictable, and you avoid the courier’s markup on disbursements. The tradeoff is lead time. Consolidation adds two to five days compared to express courier, and you lose the door-to-door tracking simplicity that e-commerce sellers expect. For commercial importers bringing in components or samples on a recurring schedule, the cost savings justify the longer transit.

CARM Client Portal Access and Release Prior to Payment

One side effect of CARM’s mandatory CAD filing is that more importers are registering for direct access to the CARM Client Portal. If you file your own CADs, you bypass the courier’s brokerage fee entirely. The catch is that CARM requires financial security for release prior to payment, and the minimum RPP bond sits at CAD $25,000. That is not practical for an importer clearing 15 parcels per month, but it makes sense for a business that imports CAD $100,000 or more per year in dutiable goods.

Direct portal access also gives you visibility into what the courier is filing on your behalf. We see discrepancies in HS classification and origin claims regularly, and those discrepancies become your liability once the CAD is accepted. If the courier classifies your goods wrong and you overpay duty, CBSA will not refund it unless you file a correction within 90 days. If the courier underclassifies and you underpay, you owe the shortfall plus interest, and possibly an AMPS penalty.

Why This Matters More in Q4

E-commerce import volumes spike in Q4 as retailers stock inventory for holiday sales. CBSA exam rates go up, courier processing backlogs stretch from hours to days, and any shipment flagged for document review can sit in a customs examination facility for a week or more. If your supply chain depends on courier parcels clearing within 24 hours, that assumption will fail during peak season.

The fix is to move time-sensitive or high-volume SKUs to a scheduled freight consolidation that clears before goods arrive. We run PARS pre-arrival filings for air freight clients who need release within four hours of wheels-down. The CAD is submitted and paid before the shipment lands, and the goods release on a green light as soon as the carrier delivers the paperwork to CBSA. That does not work for every product category, but it works for anything where you can forecast demand two weeks out.

If your inbound parcel costs are climbing and you are not sure why, the answer is usually CARM compliance overhead layered on top of courier service fees that were already high. We file CADs against courier invoices every day. Get in touch and we will walk through what your actual landed cost per parcel should be.

Frequently Asked Questions

What is Canada’s current de minimis threshold for imports?

Canada maintains a CAD $20 threshold for duty exemption and a CAD $150 threshold for GST/HST exemption, as outlined in CBSA D17-1-10. Shipments above either threshold require full customs clearance and applicable charges.

How does CARM Phase 2 affect low-value e-commerce shipments?

CARM Phase 2 Release 3, rolled out in May 2024, requires couriers to submit Commercial Accounting Declarations for all commercial shipments, including those under de minimis thresholds. Previously, many low-value parcels cleared under Section 7.3 simplified reporting without a formal CAD.

Do I still pay brokerage fees on shipments under CAD $20?

Yes. Even when duty is zero, couriers charge brokerage and processing fees to cover CAD filing costs under CARM. Typical courier brokerage fees range from CAD 15 to CAD 35 per parcel, regardless of the shipment’s dutiable status.

Can I self-clear low-value shipments to avoid courier fees?

Technically yes, but couriers hold the cargo and most will not release without payment of their brokerage fee. Self-clearance works better for freight forwarder shipments delivered to a bonded warehouse where you control the release timing.

Is Canada planning to eliminate or raise the de minimis threshold?

There is no active legislative proposal to change the thresholds as of mid-2024. The CAD $150 GST/HST exemption was raised from CAD $20 in July 2024, but the duty exemption remains at CAD $20 and is unlikely to move without broader tax policy reform.

What happens if my parcel is misclassified to stay under de minimis?

CBSA routinely audits courier LVS declarations. Undervaluation or misclassification to avoid duty triggers AMPS penalties starting at CAD $1,500 for Level 1 contraventions, and the importer of record is liable even if the shipper prepared the commercial invoice.

Source: The Loadstar