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The short answer
Once CBSA releases your Nigerian goods, you (or a licensed customs broker) account for them by submitting a commercial accounting declaration in the CARM Client Portal and paying the duty and tax. CBSA's accounting memo D17-1-5 sets the time limit for importers in Release Prior to Payment at five business days after release for shipments over CAN$2,500, with lower-value shipments due by the 24th of the following month. The memo predates CARM and is flagged for revision, so check the deadline shown in the portal before you rely on it.
A container of yam flour, a pallet of fabrics or a box of shea butter from Lagos is not finished with once the border officer lets it go. In Canada, release and accounting are separate steps. Release lets you take the goods. Accounting is the formal declaration of what the goods are, what they are worth, where they come from and what duty and tax you owe. Under the CBSA Assessment and Revenue Management system (CARM), that declaration is the commercial accounting declaration, usually shortened to CAD. This guide covers who files it, when, what it needs to say and what happens if it is late.
Before you can account: the CARM set-up
CBSA's CARM page says an importer needs a business number with an RM import-export program account before importing or exporting commercial goods. The CRA issues the RM account when you register your business number; the CRA's registration page lists RM as the import-export program account alongside GST/HST (RT) and payroll (RP). If you have not done that yet, start with registering for CARM as a small importer.
Customs Notice 25-32 explains what follows. To get goods released before paying duty and tax, commercial importers, including non-resident importers, should register in the CARM Client Portal, get a BN15 and enrol in the Release Prior to Payment (RPP) sub-program, which includes posting financial security. The CARM page adds that the transition measures have ended, so importers who did not post security in time must enrol in RPP to keep using it. Without RPP, you are a cash client: CBSA's memo D17-1-5 says cash clients give a completed accounting document and pay before the goods are released.
What the declaration has to show
The accounting declaration is where the duty is actually worked out. Each line needs to be right, because CBSA can reassess later and you remain responsible even when a broker files for you. The core elements are:
- Tariff classification: the code that sets the duty rate. CBSA's import guide says classification should be based on descriptive literature, composition and samples where possible. See finding the tariff rate for Nigerian goods.
- Country of origin: CBSA's guide stresses that origin is where goods were made, produced or grown, not simply where they were shipped from. Origin decides which tariff treatment can apply; proof-of-origin rules are in memo D11-4-2. Whether Nigerian goods qualify for a preferential rate is covered in does Nigeria get preferential tariffs in Canada.
- Value for duty: normally the price paid, converted to Canadian dollars, with the adjustments the customs rules require.
- Business number: D17-1-5 says all release, interim and final accounting documents for commercial importations must show a valid BN.
- Duty and tax: the customs duty at the applicable rate, plus GST and any other tax that applies to the goods.
The deadlines CBSA has published
D17-1-5 (dated 13 March 2013) sets these limits for importers who have security on file and get release before payment. The memo page itself says a revision is pending to reflect the CARM rollout of October 2024, and we could not open a current CBSA page restating the deadline under CARM, so treat these as the published rule and check the portal for your account.
| Shipment | Account by | Source |
|---|---|---|
| Over CAN$2,500 (RPP importer) | Within five business days of release; release day counts as day zero | D17-1-5 |
| CAN$2,500 or less (RPP importer) | By the 24th of the month after release; if the 24th is a weekend or civic holiday, the previous business day | D17-1-5 |
| Cash client (no security) | Account and pay before release | D17-1-5 |
| Monthly payment | Received at CBSA by 16:30 local time on the last business day of the month | D17-1-5 |
Worked example
Example only: a Toronto importer with RPP has a shipment of Nigerian dried foods valued at CAN$9,000 released on a Tuesday with no holidays that week. The Tuesday is day zero. Counting five business days, the accounting is due by the following Tuesday. Because the value is over CAN$2,500, the 24th-of-the-month route does not apply. The duty and tax on that declaration then fall into the monthly statement and are paid by the last business day of the month, under the D17-1-5 timetable.
Late, wrong or changed declarations
D17-1-5 sets a CAN$100 late accounting penalty for each overdue transaction. Late payment attracts daily interest at the Treasury Bill rate plus 6%, and further penalties may apply under CBSA's Administrative Monetary Penalty System. Requests to waive or cancel a penalty use Form E571 and generally have to be filed within 90 days of the penalty being assessed.
Corrections matter as much as deadlines. Under the memo, clerical errors could be fixed before the monthly statement was generated, while changes to classification, origin, value for duty or tax status had to be submitted formally. Ask your broker or CBSA how a correction is filed for your account under CARM before you rely on the older memo process. Customs Notice 25-32 also confirms that the importer of record is liable, with the importer and owner of the goods, for duties and taxes owed, including amounts assessed after accounting.
Doing it yourself or using a broker
CBSA's import guide says you may prepare your own documents or authorise a licensed customs broker, whose fees are set by the brokerage, and that you stay responsible for accounting, duties, taxes and later corrections. D17-1-5 adds that only a licensed broker can account and pay as your agent. Many first-time importers from Nigeria use a broker for the first few shipments and learn the classification and valuation on the way. See do you need a customs broker to import from Nigeria.
What to check first
- Your BN has an active RM account and is linked to the CARM Client Portal.
- You know whether you are enrolled in RPP with security, or are paying before release.
- Commercial invoice, packing list and transport document match the goods and value you will declare.
- You have a calendar reminder for day five after release, and for the month-end payment.
- You have kept the supplier's proof of origin and payment, in case CBSA verifies the declaration.
Where Pryme fits
Accounting starts with the invoice value you paid the Nigerian supplier. A Pryme business account opened from Canada holds NGN, USD, GBP and EUR, so you can pay a supplier in naira or dollars and keep the payment record beside the invoice. The Finance agent can prepare the payment and match it to the shipment; a person approves before anything moves. Duty and GST are paid to CBSA from your Canadian channels, not through Pryme.
Questions people ask
What is a CAD in CARM?
It is the commercial accounting declaration, the formal record of classification, origin, value, duty and tax for goods CBSA has released. It is filed in the CARM Client Portal by the importer or a licensed broker.
How many days do I have to account after CBSA releases my goods?
CBSA memo D17-1-5 says five business days after release for RPP importers on shipments over CAN$2,500, and the 24th of the next month for lower-value shipments. The memo predates CARM, so confirm in the portal.
What is the penalty for late accounting with CBSA?
D17-1-5 sets a CAN$100 late accounting penalty per overdue transaction, with interest on late payments and possible AMPS penalties.
Can I file the declaration myself without a broker?
Yes. CBSA says you can prepare your own documents, but you need a BN with an RM account and CARM access, and you remain responsible for the accuracy of the declaration.
Sources
- CBSA Memorandum D17-1-5: Registration, Accounting and Payment for Commercial Goods (13 Mar 2013) · accessed Oct 2026
- CBSA: CBSA Assessment and Revenue Management (CARM) · accessed Oct 2026
- CBSA Customs Notice 25-32: End of CARM transition measures and importer of record changes · accessed Oct 2026
- CBSA: Step-by-step guide to importing commercial goods into Canada (archived) · accessed Oct 2026
- CRA: Register as a resident with a Canadian business (modified 19 Oct 2026) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.