Updated: September 11, 2024
Importers (who haven’t yet done so) should prepare the information and documentation needed to register their business with the Canada Border Service Agency’s (CBSA) online client portal now.
The CBSA Assessment and Revenue Management (CARM) will come into effect on October 21, 2024, so businesses will need to register ahead of this deadline. The CARM Client Portal (CCP) will become the only way for importers to transact with the CBSA—namely the way CBSA collects duties and taxes for commercial goods imported into Canada. The CARM registration process can be complex—reach out to our customs and global trade advisors to help you prepare for this upcoming change.
Background on CARM
Importers and their service providers gained limited access to the CARM client portal on May 25, 2021 (CARM Release 1), which allowed users to view transactions and statements of account, request an advance customs ruling, and pay invoices. CBSA provided select industry partners with further access in October 2023 (CARM Release 2) before it becomes fully accessible to all importers (CARM Release 3) on October 21, 2024. Importers who haven’t registered yet should note that there will be a “cutover period” between the end of the old system and the beginning of CARM where registration will not be possible. This cutover period begins October 4th 2024.
The final release will introduce the following features:
- electronic commercial accounting declarations that you can correct and adjust
- changes to the release prior to payment (RPP) program
- harmonized billing cycles
- new offsetting options
- electronic management of appeals and compliance actions
- the ability to:
- register for an importer account with an existing Business Number (BN9); and
- enroll in various CBSA commercial programs
How will CARM affect your business?
Importers will notice some key changes with the introduction of CARM. Other than the need to register your business, importers will see changes that include:
- a requirement to post security with CBSA to continue RPP privileges
- a requirement to delegate authority in the CARM portal to your chosen customs broker(s) and trusted advisors
- real time visibility to your business’ import data
In addition, as of May 2024, importers will be required to register for an importer or exporter account (RM) with CBSA. The CRA will no longer provide this service.
How do I delegate authority to my customs broker?
Once the initial setup of your CARM client portal account is complete, you can delegate authority to your chosen customs broker(s) in the portal so they can continue to submit information on your behalf to CBSA and effect release of your shipments. You'll have complete control over which service provider can perform tasks for you, as well as visibility to your import data. This will effectively increase compliance with customs regulations and streamline communication.
As an incentive to register with CARM before October 2024, importers who are registered by this date will have a 180-day grace period to post security with CBSA.
How will posting security change?
Security is required if an importer wants to obtain the release of their shipments, prior to payment of duties and taxes to CBSA. Many importers rely on their customs broker’s customs bond when importing goods. With CARM, importers are required to post a minimum of $5,000 with the CBSA for each Business Number registered with an import program identifier. The CBSA notes that security can be in the form of a bond purchased from a surety or cash.
If you choose to post security in the form of a bond from a surety, the security needs to be able to cover 50% of the highest amount owed to CBSA in the previous rolling 12-month period. The CBSA says it'll regularly review bond sufficiency and send notices through the CARM portal to increase or decrease security.
If you choose to post a cash security, the amount posted needs to be 100% of the highest amount owed to CBSA in the previous rolling 12 months.
Alternatively, importers will always have the option to meet their shipments at the port of arrival, submit the customs entry, and pay CBSA at the port to have the goods released; this option doesn’t require security be posted, but it’s not feasible to many importers.
Takeaway
Our experienced advisors can support you in registering for CARM and understanding how this new initiative will affect your business and your imports. We’re here to support you in all cross-border customs matters.
Contact your local advisor or reach out to us here.
Disclaimer
The information contained herein is general in nature and is based on proposals that are subject to change. It is not, and should not be construed as, accounting, legal or tax advice or an opinion provided by Doane Grant Thornton LLP to the reader. This material may not be applicable to, or suitable for, specific circumstances or needs and may require consideration of other factors not described herein.
