Cross-border selling to Canada 2025–2026: 60-day compliance playbook for used phones

Key Takeaways

• Most consumer phones fall under EAR99 and don’t need a license for Canada—but you must verify device, buyer, and end use every time.
• USMCA/CUSMA preference can reduce or remove duty exposure when you have origin facts and a proper certification.
• The U.S. suspended its de minimis exception on August 29, 2025, raising stakes on small-parcel classification and documentation.
• Restricted party screening is mandatory on every shipment; penalties include fines up to $1 million and prison time up to 20 years.
• Clean documentation speeds clearance—include IMEI, HS code, unit value, and country of origin on every invoice.

Why cross-border selling into Canada is still viable in 2025–2026

January is upgrade season. People traded in their phones for the holidays. That means more used devices in the U.S. It also means buyers in Canada are hunting for deals on late‑model iPhones and flagship Androids.

If you work your costs—shipping, brokerage, and any duties—there’s room for margin. The CAD/USD exchange rate can help, too. A steady spread can pad net proceeds when your workflow is tight.

The key is to treat compliance as a profit tool. When your export docs are clean, shipments clear faster. When your origin story is ready, you can claim preference when it’s allowed. When your buyer is screened, you lower risk. All of that adds up to smoother sales and better net.

The regulatory backbone: EAR, BIS, ECCN, and EAR99

Here’s the base you need before you list a single device.

Who’s in charge. Most consumer phones sit under the U.S. Export Administration Regulations (EAR), run by the Bureau of Industry and Security (BIS). They are not defense items. They are civil goods. Exporting to Canada: What You Need to Know confirms this framework.

Classify your device. You must find the right export classification. For many used smartphones, the likely bucket is EAR99. EAR99 means “low‑risk, civil use.” It often means no export license for Canada. But you still need to check your exact device, your buyer, and the final use. Do this before you market the phone.

The four questions. Good exporters ask: What is my ECCN or EAR99 status? Where is it going (Canada)? Who is the end user? What is the end use? If any answer is risky, stop and get advice. These questions appear throughout Shipping Solutions’ Canada guide as the foundation of compliance.

USMCA/CUSMA origin and duty‑free eligibility in 2025–2026

Now the big trade piece. 2025 brought sharp shifts. The United States used the International Emergency Economic Powers Act (IEEPA) to set new tariffs on Canadian imports into the U.S. (25% starting March 4, 2025, then 35% on August 1, 2025).

But goods that qualify for preferential duty‑free treatment under the Canada‑United States‑Mexico Agreement (CUSMA, also known as USMCA) were exempted from those U.S. tariffs as of March 7, 2025. For context, this matters to the overall U.S.–Canada trade climate and how preference is treated, as detailed in the Step‑by‑step guide to CUSMA compliance.

What does that mean for a U.S. phone going north? If your shipment meets USMCA/CUSMA origin rules and you have proper origin certification, you may claim preferential treatment in Canada. This can reduce or remove certain duty exposure tied to the trade environment. The catch: you need to have your origin facts straight, especially for used electronics. You must document what you know and only claim preference when the device truly qualifies.

“Practical tip: collect origin details at intake. If you buy back devices from U.S. sources and can confirm origin, store that info with the IMEI.”

Then, when you ship, you can prepare a USMCA certification of origin with confidence. It is not a fancy form. It is a set of required data points you place on your commercial docs, as outlined in the Trade Commissioner Service guide.

Tariffs, de minimis shifts, and small‑value shipments

Here’s the twist that tripped many sellers in 2025. On August 29, 2025, the U.S. suspended its de minimis exception—the duty‑free threshold for shipments valued at $800 or less. That changed the field for small parcels and returns moving across the border. It also put more focus on proper classification and origin claims because there’s less room to hide under a “small value” umbrella, according to the CUSMA compliance guide.

For a U.S. seller exporting a phone to Canada, plan for two price scenarios:

• With USMCA/CUSMA preference: You claim preference with an origin statement. You reflect lower potential duty impact, but you still estimate taxes and brokerage.
• Without preference: You remove any assumption of duty relief. You plan for higher border costs. You also set buyer expectations in your listing.

By doing this, you can toggle your list price or your “buyer pays taxes/brokerage” note. Your listing stays honest. Your margin stays safe if rules tighten again.

Mandatory documentation and shipping best practices

Good paperwork gets you paid faster. Here’s the core export package for phones headed to Canada, drawn from Shipping Solutions’ expert list:

• Commercial or Canada Customs Invoice. Fill it fully. Include the IMEI, accurate description (e.g., “Used Apple iPhone 14, 128GB, unlocked”), quantity, and unit value.
• Bill of lading or airway bill. This is your carrier’s transport doc.
• Packing list. Match it to your invoice.
• Sales contract or order confirmation. Keep it in your file.
• USMCA certification of origin (only if you claim preference). Include the required data points and keep a copy.

Labeling and data tips to avoid delays: Put the full HS description and code on the invoice. Include the IMEI on invoice and packing list—it stops confusion. State the country of origin (only what you know and can support). Declare the lithium battery as per carrier rules. Keep seller and buyer names and addresses consistent across all docs.

Restricted party screening: do it every shipment

This step is simple but crucial. Screen the buyer, the consignee, and any middle party against denied and restricted lists, every time. Even for Canada. You do it before you take payment and again before you ship. Save time‑stamped proof.

Why so strict? The penalties for getting this wrong are scary, as noted in Shipping Solutions’ compliance section:

• Criminal fines up to $1 million per violation
• Administrative penalties of $250,000 or twice the transaction value (whichever is higher)
• Prison time up to 20 years for criminal violations
• Denial of export privileges

“Check every restricted party list every time you export.”

You can start with the U.S. Consolidated Screening List. It’s a one‑stop search of many U.S. lists. Save the results to your order file.

A value‑first pricing framework for cross‑border phones

You want a clear math model. Keep it simple and honest.

Start with comps in Canada—what do similar unlocked units sell for today? Add the CAD/USD rate and convert your target price to U.S. dollars. Subtract platform fees (think marketplace cut or payment fees). Subtract shipping and insurance using real carrier quotes to the buyer’s postal code.

Estimate border costs twice: Scenario A with USMCA/CUSMA preference, and Scenario B without preference. Add possible brokerage and taxes. Your net proceeds = List price – platform fees – shipping – estimated border costs.

With this, you can set a list price ladder by SKU. Refresh the exchange rate and border assumptions weekly in Q1. If costs rise, your price ticks up. If costs drop, you can be sharper on price and win more deals.

60‑day rollout plan: test, learn, scale

You can build a compliant cross‑border flow in two months. Keep it calm. Keep it steady.

Days 1–15: Set your foundation. Classify your top 10 devices—confirm EAR status and likely EAR99 classification, then record it with each SKU. Build your document templates: invoice, packing list, USMCA certification of origin, and a consistent sales contract. Set up restricted party screening by testing the U.S. Consolidated Screening List search and saving a sample result. Validate your HS code and your invoice description language.

Days 16–30: Run a pilot. Pick one clean, low‑value unit and ship to a cooperative buyer in Canada. Use your full doc set—include IMEI on docs and follow battery rules. Watch the clearance, capture real brokerage, tax, and transit time, and save all paperwork. Update your pricing calculator with actuals.

Days 31–45: Lock preference workflow (if eligible). If your pipeline has U.S.‑origin phones, finalize your USMCA origin statement process. Train your team on when and how to claim preference—be strict and only claim when the origin rule is met and documented. Update your listings with a clear note on who pays taxes and brokerage.

Days 46–60: Scale with control. List your top three SKUs with refined prices. Do a weekly review of exchange rates and border trends. Archive all shipment docs by order number for audit readiness. Keep a small “test budget” to try different carriers or service levels.

Channel strategy and risk management

Pick the right sales path for your goals and your nerves.

Direct private sales offer the highest margin potential but also more hands‑on work with buyers and border questions. Marketplaces give you a bigger audience, though platform fees and rules apply—great for speed if your listings are sharp. Wholesale to Canadian resellers means lower margin per unit but faster turns and simpler paperwork in bulk.

Whatever you choose, build trust with device safety and clarity. Wipe and verify—remove all data and confirm activation lock is off, then show a proof screen. Share the IMEI in your invoice and provide it to the buyer on request. Show power‑up photos, share battery health, and note any repairs. Make your “who pays taxes/brokerage” line bold and clear.

At GizmoGrind, we live this. We do fast quotes and payouts for used smartphones, tablets, MacBooks, Apple accessories, and smartwatches across the U.S. We never accept iCloud‑locked, blacklisted, lost/stolen, or water‑damaged devices. That same care helps cross‑border deals land smooth.

“Activation lock is the number one deal‑breaker for resale.” Clear it before you list.

Real‑world scenarios to lock in your workflow

Scenario A: US‑sourced iPhone 15, clean origin, courier ship. You have a U.S.‑sourced iPhone 15, 128GB, unlocked. The IMEI is clean. You gathered origin details at intake. You prepare a USMCA certification of origin. You add the HS description and code, IMEI, unit value, and country of origin on the invoice. You ship by courier with insurance. You claim preference. The shipment clears faster. Your landed costs are lower than your “no preference” model. Your margin holds.

What worked: Early classification (EAR99 likely) and clean documentation. Origin certification ready at ship time. Honest, complete invoice data.

Scenario B: Mixed‑origin lot, no preference, reseller buyer. You hold 20 mixed‑origin Androids. You can’t claim preference. You sell to a Canadian reseller at a two‑tier price: “Ex‑works price” and “delivered estimate.” You disclose that taxes and brokerage are buyer‑paid. You ship with a full packing list and clean IMEIs. Clearance goes fine because your docs are complete and your expectations were real.

What worked: Clear pricing toggle with and without preference. Listing transparency on who pays what. Tight inventory records matched to invoices.

Common pitfalls to avoid

Missing origin details. Don’t guess. If you can’t support preference, don’t claim it.

Wrong HS codes or vague descriptions. Be precise. Add the IMEI and features (model, storage, unlocked).

Underestimating brokerage and taxes. Use real quotes. Refresh weekly in busy seasons.

Skipping restricted party screening. Screen twice: before payment and before shipping. Save proof.

Incomplete invoices. Don’t forget country of origin, unit value, and battery notes.

Vague listing language. State who pays taxes and brokerage in bold.

A cross‑border pricing worksheet you can copy

Try this simple flow for each SKU:

Target Canadian sale price (CAD): Look at live comps. Convert to USD at today’s rate. Subtract platform fee (percent + fixed). Subtract shipping and insurance (carrier quote to buyer’s postal code). Subtract border cost estimate A (with USMCA preference, when eligible). Subtract border cost estimate B (without preference). Set your list price so that your net hits your margin target under both paths. If you can claim preference, great. If not, your margin still holds.

Compliance quick‑start checklist

• EAR/EAR99 classification checked and saved by SKU.
• Buyer, consignee, and intermediary screened and cleared; results saved.
• Invoice, packing list, airway bill, and insurance prepared; IMEI on docs.
• HS description and code, unit value, and country of origin included.
• USMCA certification of origin ready when you claim preference.

Listing updated with “who pays taxes/brokerage.” Pricing calculator updated with weekly rates and real brokerage actuals.

Your 2025–2026 watchlist

Policy shifts. The U.S. de minimis suspension made small parcels more complex in 2025. Keep watching cross‑border updates from the Trade Commissioner Service so you can price smart and file right.

Origin discipline. Preference can help, but only when you truly qualify. Build origin capture into your intake and keep it tied to IMEIs.

Screening rigor. Restricted party screening is a must on every deal. Save your results every time—guidance is clear on both Shipping Solutions and the Consolidated Screening List.

Doc quality. Clean docs speed clearance. Sloppy docs stall and cost money.

Your cross‑border selling playbook, in one page

Decide your channel: direct, marketplace, or wholesale. Classify devices and confirm EAR99 when it fits—save it per SKU. Build your invoice, packing list, and origin certification templates. Screen buyers every time and save proof. Ship a pilot to learn real brokerage and clearance timing.

Price with two scenarios (with preference vs. without). Keep clean IMEI records and show device health. Review rates and policies weekly. Adjust fast.

The bottom line

Cross‑border selling into Canada in 2025–2026 is still very doable. It just asks for discipline. Classify your phones. Screen your buyers. Document well. Price with eyes wide open. When you do, you can turn a post‑holiday supply wave into steady Q1 wins—and do it the right way.

Key sources

• Step‑by‑step guide to CUSMA compliance – Trade Commissioner Service: IEEPA tariff context, USMCA/CUSMA preference, and de minimis suspension timeline
• Exporting to Canada: What You Need to Know – Shipping Solutions: EAR/EAR99, required documents, and restricted party screening with penalties
• U.S. Consolidated Screening List: run denied party checks and save results

Frequently Asked Questions

Do I need an export license to sell a used phone to Canada?
Often no. Many consumer smartphones are EAR99 and do not need a license for Canada. But you must verify your device, end user, and end use before you ship, as detailed in Shipping Solutions’ guide.

What is USMCA/CUSMA preference and how do I claim it?
It’s a trade benefit that can reduce or remove duties if your goods meet origin rules. To claim it, include a USMCA certification of origin with your shipment. Only claim it when your facts support it, following the Trade Commissioner Service guidance.

What changed with small shipments in 2025?
The U.S. suspended its de minimis exception for shipments at $800 or less on August 29, 2025. That tightened the small‑parcel landscape and raised the stakes on proper classification and documentation, per the CUSMA compliance guide.

Do I really need to screen Canadian buyers?
Yes. Screen every party on every shipment. The penalties for violations are high, including massive fines and possible jail time. Start with the U.S. Consolidated Screening List and save proof, as emphasized in Shipping Solutions’ compliance section.

What should I put on my invoice?
A full description, HS code, IMEI, unit value, country of origin, buyer and seller info, and a battery declaration if needed. If you claim preference, add your USMCA certification of origin. Full guidance is available at Shipping Solutions.