Importer of Record Update and Case Study

The incoming amendments to the Canadian Customs Acts will affect importers, intermediaries, and third-party logistics providers involved in the importation of all goods into Canada.

The new requirements by the Canadian Boarder Service Agency (CBSA) are meant to enhance the customs system and hold importers accountable for their imports. These changes will affect all importers in Canada as it will shift the responsibility of payment for GST and Duties to the importer of record on file.

Case Study: Determination of the Importer of Record

Company X will be referred to as the importer in all examples:

 Case 1

Company X is importing paper bags into Canada. When they fill out the importer of record information they use their business number and company information. When payment of GST and Duty needs to be remitted to the CBSA, company X is responsible for the payment.

 Case 2

Company X is importing paper bags into Canada and does not want to use their information for customs clearance. Instead they ask to use their customs broker business number and information to clear the goods. At this point the customs broker has now become the importer of record and will be liable for the GST and Duty associated with that shipment.

 Case 3

Company Y will be referred to as the buyer of the goods for case study 3.

Company Y wants to buy and import their own paper bags into Canada but does not have a business importation number (RM0001). Company Y asks company X to use their business importation number as they know they have imported goods into Canada before.

On the house bill of lading company Y’s name is on it, but when filling out the importer of record information company X’s information and business number is used. When the payment of GST and Duty needs to be remitted, company X is responsible even though they did not buy the goods.

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