Valuation
When importing into Canada, the declared value for duty determines the amount of customs duty and import GST payable. For brands expanding into Canada, the most efficient and flexible path is often to import goods directly from the factory on an unsold, or “at-risk,” basis, the same way most brands import into their home market.
Importing Unsold (“At-Risk”) Goods
When goods are shipped directly from the manufacturer (e.g., Vietnam, Italy, or Cambodia) into Canada without a confirmed buyer, the import is considered unsold at the time of entry.
In these cases, the fair market value for duty must be declared. This value represents what an independent Canadian buyer would reasonably pay for the product if purchased under normal trade conditions—but before any markup for wholesale or retail sale.
Key points:
- The transaction value used for customs should reflect the factory selling price (including any commissions, packing, and assist costs), converted to Canadian dollars.
- Because there is no buyer yet, the declared value is typically significantly lower than the price at which the goods will ultimately be sold in Canada.
- This allows duty to be calculated on the factory value, not the later wholesale or retail value.
For example: A jacket purchased from a Vietnamese factory for USD $50 and imported directly into Canada would be valued for duty at roughly CAD $68 (after exchange and freight).
If that same jacket were instead imported only after being sold to a Canadian retailer at CAD $120 wholesale—or to a consumer at CAD $180 retail—duties would be assessed on those higher amounts.
Importing at-risk, unsold stock allows brands to manage their landed costs more efficiently, while keeping goods available and ready to fulfill once demand materializes.
Transfer Pricing and Related-Party Shipments
As brands grow their Canadian presence, many begin to transfer unsold goods from other markets—such as a U.S. or European warehouse—to supplement Canadian inventory.
In these related-party transactions, the Canada Border Services Agency (CBSA) expects the declared value to reflect an arm’s-length equivalent—the price an independent buyer would have paid for the same goods.
Because there is no sale for export to Canada, valuation is generally derived from internal landed cost plus a modest uplift to represent the fair market value in Canada.
- A common and accepted industry practice is to apply about a 1.2× factor to the landed cost from the first destination (for example, the U.S.) when declaring value for duty into Canada.
- This ensures compliance while preventing overvaluation of goods that remain unsold.
Customs brokers are accustomed to supporting this methodology and can assist in documentation, worksheets, and periodic audits to validate that the pricing remains consistent with CBSA standards.
When Goods Are Imported as a Sale
When goods enter Canada as part of a confirmed sale, the valuation rules change.
- If you are selling to a Canadian retailer, duties are assessed on the wholesale selling price.
- If selling directly to the Canadian consumer, the retail price forms the basis for duty.
In both cases, duty is calculated on a substantially higher amount than when the same goods are imported unsold.
That difference between a factory value and a wholesale or retail value can represent a 30–60% reduction in dutiable value simply by importing into Canada first, then selling once goods are in market.
Risks of Undervaluation
CBSA permits flexibility in valuation for unsold or related-party imports, provided the declared values are reasonable and well supported.
- Declaring below fair market value can lead to reassessments, penalties, and interest.
- Always retain supporting documentation such as cost sheets, factory invoices, or correspondence with your customs broker.
- Maintain consistency across import entries and periodically review your declared values for reasonableness.
Key Takeaways
- Unsold (“at-risk”) imports allow brands to pay duty on the factory cost—not the final sale price.
- Direct-to-Canada importing is both compliant and cost-efficient, mirroring the process most brands already use in their home market.
- Transfer shipments from the U.S. or Europe should use an uplifted landed-cost model (commonly 1.2×) to establish fair market value.
- Goods imported after a sale face higher duties, as valuation is based on the wholesale or retail selling price.
- Declaring accurate and defendable values ensures compliance while protecting your margins and pricing flexibility in Canada.
|
Scenario |
When Applied |
Basis for Value-for-Duty |
Typical Declared Value |
Duty Exposure |
Notes / Takeaways |
|
Factory (Unsold / “At-Risk” Import) |
Goods shipped directly from factory (e.g., Vietnam) with no confirmed sale |
Factory invoice + packing, freight to Canada, assists |
≈ CAD $68 (from USD $50 factory cost + freight / exchange) |
Lowest |
Most common for NRI brands. Duty calculated on factory value. Ideal for stocking Canada before sales. Flexible for both DTC & wholesale. |
|
Wholesale (Sold-to-Retailer) |
Goods imported after a sale to a Canadian retailer |
Canadian wholesale invoice price |
≈ CAD $120 |
Medium |
Duty now based on the transaction price to the retailer. |
|
Retail (Sold-to-Consumer) |
Goods imported only after DTC sale |
Retail selling price to consumer |
≈ CAD $180 |
Highest |
Duty calculated on the final sale price. Increases cost and erodes margin. |
Summary
Importing unsold (at-risk) inventory into Canada lets brands pay duty on the factory value, not the wholesale or retail price.
The result is a 30 – 60 % reduction in dutiable value, lower landed costs, and more flexibility to fulfill both Canadian and U.S. orders from in-country stock — all while remaining fully compliant as a Non-Resident Importer.
This article is intended to share general information and practical insights only. It is not legal advice. Laws and regulations vary by jurisdiction and circumstance, and readers should consult with qualified legal counsel before making decisions based on the information provided.
Subscribe to our newsletter
Sign up for our newsletter to stay up to date with our latest projects, news and job postings.





