Customs Clearance Without a Local Entity: Key Differences Between Canada NRI and U.S. CAIN

“Can we clear customs under our company name even if we don’t have a legal entity in Canada or the U.S.?”

“Do we need to use an Importer of Record (IOR) service every time, or can we switch to being the importer ourselves?”

These are the questions we hear most often when handling North American (U.S./Canada) import and export logistics.

The short answer is:

Even without a local legal entity,

• Canada can be approached through an NRI (Non-Resident Importer) structure, and

• the United States through a FIOR (Foreign Importer of Record) framework combined with a CAIN (Customs Assigned Importer Number),or alternatively by proceeding via an IOR (Importer of Record) service provider.

Trufulfillment supports direct import structures in both countries, but the preparation requirements, lead times, and cost/settlement structures differ significantly between Canada and the U.S.

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1. Terminology Overview: NRI / FIOR / CAIN / IOR Service

NRI (Non-Resident Importer) – Canada

An NRI structure allows a non-resident company to act as the importer of record in Canada by setting up the required tax and import/export accounts (BN/RM/GST/HST, etc.).

There is no single standalone “NRI number”. Rather, it refers to the operational status of acting as the importer once the required accounts are properly established.

FIOR (Foreign Importer of Record) & CAIN – United States

FIOR is a conceptual framework/qualification that allows a foreign company to act as the importer of record without a U.S. legal entity.

A CAIN (Customs Assigned Importer Number) is the unique identifier required to clear customs under the FIOR framework.

In short:

• FIOR = eligibility / framework (concept)

• CAIN = identification number actually used in customs clearance

Note: In the U.S., operating as an importer also requires the use of a Customs Bond.

What Is an IOR Service?

An IOR service means that a third party or local entity acts as the importer of record on behalf of the overseas seller.

This option is convenient for one-time or urgent shipments, but for long-term operations, it is critical to clearly define cost accumulation, liability scope (settlement, claims, regulatory response) at the contract stage..

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2. Core Comparison: Canada NRI vs. U.S. FIOR

The table below compares only the “direct importer” frameworks for overseas companies.

Category	Canada – NRI	United States – FIOR
Nature	Direct importer operation based on Canadian account setup (BN)	Framework/qualification allowing a foreign company to act as importer without a U.S. entity
Practical Identifier	Account-based operation (BN / RM / GST / HST)	CAIN used when clearing under FIOR
Key Preparation	Tax and import/export account setup (multiple requirements)	CAIN issuance + Bond structuring
Perceived Lead Time	Relatively longer (2–3 months for account setup/review)	CAIN issuance is relatively fast (often within one week via a customs broker)
Long-Term Suitability	Well-suited for recurring imports and inventory operations	Option to reduce reliance on IOR services for recurring imports

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3. Country-Specific Operating Options: Direct Importer vs. IOR Service

In practice, companies typically choose between the following two options in each country.

Canada: NRI vs. Canadian IOR Service

Category	NRI (Direct Importer)	IOR Service
Recommended Use	Advantageous for recurring imports and long-term operations	Convenient for one-time or urgent shipments
Settlement & Tax	Tax and settlement structured around your own company; tax refunds possible	Separation risk between customs name and sales/settlement entity → structure must be carefully designed
Risk Considerations	Initial setup burden (time and documentation)	Cost accumulation; complexity in liability, ownership, and settlement structure

United States: FIOR (CAIN) vs. U.S. IOR Service

Category	FIOR + CAIN	IOR Service
Core	Use of CAIN + Bond management	Third party acts as IOR
Recommended Use	Reducing dependency on IOR services for recurring imports	Speed and convenience for one-off or urgent shipments
Risk Considerations	Bond structuring required (optimized by volume/frequency)	Cost accumulation, dependency on agent, need for clear liability definition

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4. Trufulfillment Recommendation Guide: Which Option Fits Your Case?

① Recurring imports (monthly or more) + inventory stored in North America

• Canada:Structuring operations around NRI (direct importer) with an NRI + CARM + Bond framework is more advantageous in the long run.

• United States:Consider transitioning to a direct importer model using the FIOR concept + CAIN issuance + Bond management.

  
  

② One-time shipments, promotions, or urgent dispatches

An IOR service is often the most practical option due to speed and minimal upfront setup.

However, the following three points must be clearly defined at the contract stage:

1. Customs clearance name vs. ownership/inventory attribution

2. Cost structure (per shipment / monthly / additional fees)

3. Liability in the event of claims, recalls, or regulatory issues

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⭐ Trufulfillment Insight ⭐

For overseas sellers, designing the right structure based on annual shipment volume and frequency is critical.

If you ship once per month or more, or 10+ times per year, and maintain ongoing inventory in 3PL warehouses:

• Canada: Focus on an account-based operational structure

• United States: Design a CAIN + Bond operating model

If shipments are one-off, for initial market testing, or fewer than 10 times per year:

• Canada / United States: IOR services are generally more efficient

Trufulfillment designs optimized logistics structures tailored to your shipment volume, sales channels, and settlement flows, supporting both:

• Short-term speed through IOR services, and

• Mid-to-long-term stability by transitioning to a direct importer model.