Update: The CBSA has indicated policies for a transitional period to the CARM system will be issued.
Executive summary
The CBSA Assessment and Revenue Management (CARM) system will enter into use on May 13th, 2024. CARM will be the system of record to interact with the CBSA for commercial import shipments into Canada. Proactively ensuring necessary registrations and other requirements are met before May 13th will prevent interruptions in importing and doing business with the CBSA.
New mandatory system for Canadian importation
The Canada Border Services Agency (CBSA) has announced that the CBSA Assessment and Revenue Management (CARM) system will enter into use on May 13th, 2024 (Release 2). CARM will be the system of record to interact with the CBSA for commercial import shipments into Canada. The CARM system introduces material procedural changes for importers. Proactively ensuring necessary registrations and other requirements are met well before May 13th will assist in preventing interruptions in importing and doing business with the CBSA.
The CBSA has recently advised that it is revising its mandatory CCP registration prior import requirement to allow for a limited transition period. However, importers trying to import commercial goods on or after May 13th without a CARM Client Portal (CCP) account may face challenges to account for the goods released using release prior to payment privileges and have penalties levied if the goods are not accounted for by the due date. More details from the CBSA will likely follow shortly on this important change in policy. The best practice remains to register for the CCP well before May 13th and avoid this confusion, disruption and potential penalties.
It is likely that some importers will not be prepared for CARM by May 13th causing congestion and potential supply chain disruptions. Importers should therefore consider increasing critical imports into Canada prior to May 13th to plan for this.
Registration
Importers will need to register for a CCP account to continue importing activities. To complete the CCP registration process, the business will need the following information:
- A GCKey or the ability to use a sign-on partner (financial institution linked to the CBSA systems)
- Business Number (BN 9)
- Import/Export Program account (RM)
- Statement of Account and/or Daily Notice
Individuals at the business that require CCP access will need their own personal CARM profile. The level of access and authorization each individual will have to the business’ account can be controlled. The individual who initially registers the business will normally be the business account manager and have the highest level of access and authorization.
Delegation of authority
Importers can delegate their customs broker the authority to act on their behalf in the CCP. To ensure a smooth transition with the new system, importers should ensure this authority is delegated in CARM well before May 13th.
Release prior to payment privileges
Importers that participate in the Release Prior to Payment (RPP) program can have their imported goods released by the CBSA before payment of duties and taxes if sufficient security is posted. Importers may currently be utilizing the RPP security of their custom broker for the expedited release of their imported goods. However, once CARM becomes mandatory on May 13th, commercial importers will need to transition to their own financial security to participate in RPP. The CBSA has advised as long as importers have registered in the CCP, they will have 180 days to transition to meet the required financial security obligations to continue to enjoy RPP benefits.
Potential opportunity for rationalization
Given this system change, it is suggested that importers review all of their RM accounts and consider consolidating and/or eliminating any unnecessary RM accounts. Financial security requirements will need to be met for all RM accounts.
Recommended practices for use of CARM
There may be unexpected issues with CARM uncovered as it becomes available and used by a wider audience. To ensure a smooth transition, those who import commercial goods into Canada should register their businesses in the CCP and delegate necessary authorities prior to May 13th. Importers looking to use the RPP should also ensure they are positioned to post the necessary security being mindful of the transition timelines for doing so. For additional assistance with navigating the transition to CARM, please see the CBSA’s resources1 and contact your RSM Canada trade advisory team.
