Move to Canada from US: What the Supply Chain Crime Crackdown Means for New Importers

Key Takeaways

• The Canadian Trucking Alliance’s call for stricter enforcement means CBSA will intensify audits on new importer accounts, especially those with cross-border US parent entities.
• US companies moving Canadian import operations must register a CARM Client Portal account and post RPP bond security before first release—no paper B3 workaround exists anymore.
• Forced labour compliance under CUSMA Article 23.6 now triggers retroactive duty assessments and AMPS penalties, not just cargo holds.
• Due diligence on your Canadian freight forwarder and warehouse partner is no longer optional—CBSA treats supply chain crime as a shared importer liability.

US Companies Moving North Face Tighter Border Compliance

If you are planning to move to Canada from US operations, the compliance landscape just got narrower. The Canadian Trucking Alliance (CTA) has formally asked Ottawa to crack down on organized crime, forced labour, and regulatory evasions across the freight sector. For US businesses setting up Canadian import programs, that means CBSA will scrutinize new importer accounts more closely, your freight forwarder’s compliance record matters, and the old “we didn’t know” defence no longer works when your supply chain touches forced labour or trade fraud.

This is not abstract policy. The CTA’s submission calls out concrete threats: forced labour in domestic trucking fleets, trade-based money laundering through shell carriers, and systematic safety violations that undercut legitimate operators. CBSA already has the enforcement tools (AMPS penalties, detention authority, post-release verification audits). The question is whether Ottawa will fund the staffing and data systems to use them at scale. For new Canadian importers, assume the answer is yes and build your compliance posture accordingly.

What the Crackdown Means for Your First CAD Filing

Canada replaced the paper B3 customs form with the CARM Client Portal in 2024. Every commercial importer now files a Commercial Accounting Declaration (CAD) electronically and posts financial security through a Release Prior to Payment (RPP) bond before CBSA releases the goods. If you are moving warehouse operations or supplier relationships from the US to Canada, you cannot import on a casual basis. You need a Business Number with an RM account, a CARM Portal login, and a licensed Canadian customs broker to file on your behalf.

The minimum RPP bond is CAD 25,000, but most mid-market importers post CAD 50,000 to CAD 100,000 depending on projected monthly duty and GST. Bond sizing is not a one-time decision. CBSA recalculates your exposure monthly via the K84 statement, and if your actual import volume exceeds the bonded amount, CBSA can suspend release until you top up security. We see this frequently with US companies underestimating their Canadian duty liability in the first quarter.

Forced Labour Compliance Is No Longer Optional

As of July 1, 2024, Canada’s forced labour import ban took effect under amendments to the Customs Tariff Act. CBSA can detain any shipment suspected of being made wholly or in part by forced labour, demand supply chain documentation back to raw material origin, and assess duties retroactively if you cannot prove clean sourcing. This is not a cargo hold that clears after a phone call. Detention can run weeks while CBSA verifies your supplier attestations, and if the goods are ultimately deemed inadmissible, you pay storage, return freight, and potential AMPS penalties.

For US companies moving to Canada from US manufacturing or sourcing networks, this means auditing your supply chain before your first import, not after CBSA flags a container. CUSMA Article 23.6 already prohibits forced labour in goods claiming CUSMA origin preference, so if you are relying on duty-free treatment under the trade agreement, forced labour exposure kills both the preference claim and the broader admissibility of the shipment. The compliance burden is on you as importer of record, not your broker, not your freight forwarder, not your overseas supplier.

Vetting Your Canadian Freight and Warehouse Partners

The CTA’s submission focuses on criminal infiltration of domestic trucking fleets—shell carriers with no legitimate operations, forced labour in driver recruitment, and systematic evasion of hours-of-service and safety regulations. CBSA does not publish a public blacklist of flagged carriers, so due diligence falls to you. When you engage a Canadian freight forwarder or warehouse provider, ask for their CBSA compliance history, whether they have been subject to post-release audits, and how they vet their drayage and cartage subcontractors.

We routinely refer clients to FENGYE LOGISTICS for bonded and sufferance warehousing in Montreal because we know their CBSA standing, their security protocols, and their cartage network. If you pick the lowest-cost warehouse or forwarder without vetting, and that provider is later flagged for organized crime or customs fraud, your shipments get caught in the investigation even if you had no knowledge. CBSA treats supply chain crime as a shared importer liability, not just a carrier problem.

PARS, RMD, and Release Timing

Most commercial freight from the US enters Canada under PARS (Pre-Arrival Review System), which allows CBSA to review the CAD before the truck crosses the border. If the entry qualifies for Release on Minimum Documentation (RMD), the goods can be released at the border without physical exam. If CBSA selects the shipment for verification, the truck is referred to a sufferance warehouse for exam, and release timing depends on how fast you can produce the requested documentation (commercial invoice, CUSMA certificate of origin, supplier attestations, lab test reports for regulated goods).

US companies used to CBP’s ACE system often assume Canadian release works the same way. It does not. CBSA’s risk scoring under CARM Phase 2 Release 3 weighs your importer compliance history, the HS 6-digit classification you declared, the country of origin, and whether the declared value aligns with CBSA’s internal pricing database. A new importer account with no compliance track record will see higher exam rates in the first six months. Build that assumption into your inbound logistics planning, especially if you are moving time-sensitive inventory from a US fulfillment center to a Canadian warehouse operation.

What to Do Before Your First Canadian Import

1. Register your Business Number and RM account with CRA.
2. Set up your CARM Client Portal account and link it to a licensed Canadian customs broker.
3. Obtain an RPP bond sized to your projected monthly duty and GST exposure.
4. Audit your supply chain for forced labour risk, especially if you source from high-risk jurisdictions flagged by Global Affairs Canada.
5. Vet your Canadian freight forwarder and warehouse partner for CBSA compliance standing.
6. Review your HS classifications and CUSMA origin claims before first filing—CBSA’s interpretation of tariff headings may differ from CBP’s, and post-release corrections trigger interest and penalties under AMPS.

The forced labour ban, the CARM Portal mandate, and the CTA’s push for stricter enforcement are all live. If you are moving operations or opening a Canadian sales channel, treat customs compliance as a setup cost, not an afterthought. The importers who get this right in the first quarter avoid the multi-month cargo holds, bond suspensions, and AMPS assessments that we see hitting under-prepared US companies six months in.

We file CADs against these exact scenarios daily. If you are moving to Canada from US operations and need to map out your CBSA compliance posture before first import, come say hello.

Frequently Asked Questions

Do I need a Canadian business number before I can import into Canada from the US?

Yes. You need a Business Number (BN) with an RM (import-export) account from CRA, then register that BN in the CARM Client Portal to file Commercial Accounting Declarations (CADs). Processing time is typically 5–10 business days per CBSA guidance.

What is the minimum RPP bond amount for a new Canadian importer?

CBSA sets the minimum Release Prior to Payment bond at CAD 25,000 for most commercial importers. Actual bond sizing depends on your projected monthly duty and GST liability—we typically see initial bonds in the CAD 50,000 to CAD 100,000 range for mid-market US companies moving operations north.

How does Canada’s forced labour import ban affect US companies shipping to Canada?

As of July 1, 2024, Canada prohibits imports made wholly or in part by forced labour under amendments to the Customs Tariff Act. CBSA can detain shipments, demand supply chain documentation back to raw material origin, and assess duties retroactively if you cannot prove clean sourcing per CBSA D9-1-8.

Can I use my US customs broker for Canadian imports?

No. Only licensed Canadian customs brokers (CSCB members holding a CCS designation) can file CADs with CBSA. Your US broker cannot act on your behalf in Canada—you need a separate engagement with a Canadian brokerage like CanFlow.

What happens if my Canadian freight forwarder is flagged for supply chain crime?

CBSA treats organized crime exposure as a shared liability. If your forwarder or carrier is under investigation for forced labour, trade-based money laundering, or customs fraud, your shipments may be held pending verification even if you had no knowledge. We see this routinely when importers pick the lowest-cost provider without vetting CBSA standing.

Does moving my warehouse from the US to Canada trigger different duty treatment?

Yes, if you are shipping inventory from a US warehouse into Canada for Canadian sales, those goods are commercial imports subject to MFN duty, GST, and full CBSA clearance. CUSMA origin may reduce or eliminate duty if the goods qualify, but you still file a CAD and post bond for each entry.

Source: Inside Logistics