The United States Trade Representative (USTR) published its 2026 National Trade Estimate this week. Similar to the 2025 version, the USTR report identifies the implementation of the CBSA Assessment and Revenue Management (CARM) system, and its accompanying policies and processes, as one of Canada’s barriers to customs efficiency and trade facilitation. With respect to CARM, the report states:
“On October 21, 2024, the Canadian Border Services Agency (CBSA) officially launched the CBSA Assessment and Revenue Management (CARM) system to assess and collect duties and taxes for commercial goods imported into Canada. The new system requires importers of record to register in the CARM Client Portal and post a financial security with the CBSA. Previously, these steps could be taken by a customs broker on behalf of an importer. Transition measures that allowed commercial importers who were not registered to rely on their customs broker until they could finalize their own registration ended on January 1, 2026. U.S. exporters have called for permanent exceptions or accommodations to the registration and financial security requirements for small and infrequent importers, especially non-resident importers.
Many U.S. exporters to Canada previously relied on the “Non-Resident Importer” program to obtain “Release Prior to Payment.” Release Prior to Payment allows goods to physically clear customs while duties and tax payments are being calculated, in compliance with Canada’s World Trade Organization (WTO) Trade Facilitation Agreement commitments. With the launch of CARM and the end of the transition period, goods are held at customs until payment is made unless an importer has set up an account in the CARM Client Portal and posted a financial security or cash deposit with CBSA. Early implementation of CARM led to a number of issues for U.S. exporters, including express shipments piling up at the U.S. border because Canadian and non-resident importers were unaware of the need to register in CARM. System outages still pose a problem for those seeking to use the CARM system, whether to register or to file corrections. U.S. exporters are also concerned about reports that the customs data submitted in the CARM system is not stored in a government-owned or -monitored system. The United States will continue to monitor this situation.”
The full chapter referencing Canada can be found on pp. 60-67 of the report: https://ustr.gov/about/policy-offices/press-office/press-releases/2026/march/ustr-releases-2026-national-trade-estimate-report