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What is CARM?

The CBSA Assessment and Revenue Management (CARM) project is a multi-year initiative that will transform the collection of tax and duty for goods imported into Canada.

Through CARM, the Canada Border Services Agency (CBSA) will also introduce a new suite of online tools to help streamline the process of importing commercial goods into Canada.  

Read more on CBSA’s CARM webpage

Features & Benefits of CARM Initiative

Watch the CBSA’s CARM video

The development and release of this new program is on a very rapid timeline.  Although design and policy has not yet been finalized by CSBA, the agency has released information about many of CARM’s upcoming features, requirements, and functions. 

Keep in mind these may be subject to some change before the full program launches. Please visit this site regularly or subscribe to our CARM e-bulletins for ongoing updates.

CBSA's Implementation Timeframes

Fall 2020: CARM Release 0 will have no impact on importers. CBSA will simply move the existing Accounts Receivable Ledger (ARL) system from its current data centre configuration to the more robust SAP S4/HANA system in the cloud.

May/June 2021: CARM Release 1 will provide businesses with the first opportunity to register for access to the CARM Client Portal (CCP). The CCP will allow them to see their amounts owing and manage their accounts with the CBSA , including the receipt of Daily Notices (DN’s) monthly Statements of Account (SOA) and the ability to make payments directly to CBSA. Payment directly to CBSA will require almost all importers to post a yearly surety bond.  This email address is being protected from spambots. You need JavaScript enabled to view it. to request a bond or contact your local account representative.

June 2022: CARM Release 2 will introduce a new electronic commercial accounting declaration (CAD) that will replace the current customs coding form (B3) and request for adjustment form (B2). As well, new features for payment and billing processes will make it easier to make corrections and adjustments. Importers will have to be enrolled on the CCP as of the start of this phase or risk having their shipments held at the border.

Subscribe to CARM Updates

Need more information?

Cole is ready to help. If you have further questions, please do not hesitate to contact your local account manager or This email address is being protected from spambots. You need JavaScript enabled to view it. today.

Require a customs bond? This email address is being protected from spambots. You need JavaScript enabled to view it. to submit a request and one of our CARM representatives will contact you directly. 



 

Most of CARM’s key features have been established and will be part of the new CARM Client Portal (CCP).

With the implementation of the CCP, all importers will be required to register for access to the portal and participate in managing their own customs activities and profiles in closer coordination with customs brokers and other service providers.

CBSA has advised that failure to apply for CCP access will prevent your goods from crossing the border. 

Primary features of the CCP

Account management 

  • All importers will be required to self-manage access to their profile in the secure CCP site by delegating authority to their employees, customs broker/s or other service providers, to allow them to manage specific tasks within the portal.

Customs payment

  • Under CARM, importers will be responsible for making all payments for duty and taxes directly to CBSA.  
  • Payment will be facilitated via electronic funds transfer (EFT), electronic data interchange (EDI) payment, credit card, or pre-authorized debit (PAD). CBSA will be phasing out payment by cash or cheque.

Release prior to payment (RPP) bond

  • The new program will require all importers to supply CBSA with a surety bond to guarantee the payment of all duties and taxes before goods will be released from Customs control. 
  • Importers will be required to proactively review security requirements for their bond through the CCP and proactively increase bond levels as required to meet their on-going import needs. 
  • Customs has advised that the system will also prompt importers as their levels approach the maximum limit of the current bond. 

Customs Accounting Declaration (CAD)

  • Once a customs release is arranged by a customs broker or a customs authorized courier, the CCP will allow the importer to prepare and electronically submit their own CAD should they choose.
  • Customs brokers will still be able to file CADs on behalf of any importer that designates that broker as their agent within their CCP profile.

Corrections

  • The CCP will allow the importer to file corrections to almost any field within their CAD, without penalty or interest, up until the payment due date. 
  • Customs brokers, when designated, will also be able to file these corrections via their existing EDI programs with CBSA.

Mass claims

  • The new CCP will give importers the ability to prepare and electronically submit mass blanket adjustments or refunds. 
  • It will also allow importers to delegate portal access to their customs broker or customs consultants so they may prepare these claims through the portal on their behalf.

Customs rulings

  • Importers will be able to file requests for customs rulings directly with CBSA via the portal or delegate CCP access to their customs broker, allowing them to prepare and file these rulings on their behalf.

E29B temporary import permit

  • Importers will be able to file requests for an E29B temporary import permit directly to the CBSA via the portal or delegate their customs broker to access their CCP to prepare and file these permits on their behalf.

HS tariff search engine

  • The CCP will incorporate a search engine to assist importers with identifying the correct 10-digit Harmonized System Tariff (HS) codes for their product. 
  • It is important to note that the HS tariff provided by the CBSA CCP portal will not be considered binding on CBSA, unless the importer files for a Customs ruling on the product.

The development and release of this new program is on a very rapid timeline.  Although design and policy has not yet been finalized by CSBA, the agency has released information about many of CARM’s upcoming features, requirements, and functions. 

Keep in mind these may be subject to some change before the full program launches. Please visit this site regularly or subscribe to our CARM e-bulletins for ongoing updates.

Subscribe to CARM Updates

Need more information?

Cole is ready to help. If you have further questions, please do not hesitate to contact your local account manager or This email address is being protected from spambots. You need JavaScript enabled to view it. today.

Require a customs bond? This email address is being protected from spambots. You need JavaScript enabled to view it. to submit a request and one of our CARM representatives will contact you directly. 



 

The first impact to importers will be the release of the CARM Customs Portal (CCP).  

CARM Customs Portal (CCP)

All importers will need to register for CCP access once it is released in the second quarter of 2021. Please note that this is mandatory. Failure to register will prevent customs release of your goods at the border.  

Through the CCP, importers will have the ability to manage a variety of customs processes. Read more about the portal’s features here.

You’ll be able to:

  • manage your CBSA daily activity notices and monthly statement of account
  • electronically pay your customs duties, taxes, and fees directly to CBSA
  • apply for customs rulings
  • apply for temporary import permits
  • prepare a Commercial Accounting Declaration (CAD)
  • make individual corrections and prepare mass adjustments to a CAD
  • research HS tariff codes

Importer responsibilities 

CARM changes the customs landscape for importers, requiring you to manage and oversee some tasks your customs broker may currently handle. CARM does include delegation to your customs broker, however some things need to be handled by your internal operations.

Payments and account management

  • Under CARM, importers are responsible for paying CBSA directly for duties, taxes, and fees. 
  • Importers must manage their own statements, account balances, discrepancies, and payments through the portal.
  • Payments are required within specific timelines, which may differ from your current payment timelines with your customs broker.  

Importers will have the ability to assign/delegate some or all of these functions to their customs brokers or other service providers. However, you will still need to proactively monitor and manage the delegation of those authorities.

Surety bond

  • Almost all commercial importers will be required to purchase a surety bond to indemnify CBSA relating to the payment of duty and taxes to CBSA.
  • It is expected (but not yet finalized) that the bond amount will be based on the importer’s highest level of monthly duties, taxes, and CBSA fees (including GST) for a single month, from their past 12-month history. 
  • The minimum bond level is proposed at $25,000 and the maximum bond will be $10 million.
  • For any importers exceeding the minimum bond threshold, CBSA has proposed a bond equal to 50% of the highest monthly duties, taxes, and fees (including GST) for a single month, from their past 12-month history. 

For example: if the highest monthly payable to CBSA is $200,000, the bond amount will be $100,000. If the highest monthly payable is $80,000 then the importer will need a $40,000 bond.

CARM does not affect the customs release process. Customs release will still be done by customs brokers and customs authorized couriers in the same manner as it is done today.

The development and release of this new program is on a very rapid timeline.  Although design and policy has not yet been finalized by CSBA, the agency has released information about many of CARM’s upcoming features, requirements, and functions. 

Keep in mind these may be subject to some change before the full program launches. Please visit this site regularly or subscribe to our CARM e-bulletins for ongoing updates.

Subscribe to CARM Updates

Need more information?

Cole is ready to help. If you have further questions, please do not hesitate to contact your local account manager or This email address is being protected from spambots. You need JavaScript enabled to view it. today.

Require a customs bond? This email address is being protected from spambots. You need JavaScript enabled to view it. to submit a request and one of our CARM representatives will contact you directly. 



 

CBSA has not finalized all of the processes and policies for CARM, but here are a few things you can do now to prepare. We advise you to take these steps as soon as possible.

Step 1: Get your customs bond now 

There will be approximately 300,000 importers and trade chain partners that will have to obtain and register their customs bonds within the next 12 months. To avoid backlogs, delays, or the inability to get a bond before the go live date for CARM, obtain and register your bond with CBSA now. 

Step 2: Register for your CCP portal access as soon as it becomes available

The CCP portal is scheduled to tentatively go live Spring 2021 and the full CARM program has been delayed due to COVID-19 issues. We will provide an update as soon as the final date is announced. Once live, register for your account as soon as possible to avoid potential backlogs in filing for on-line access.

IMPORTANT: CBSA has advised that without a CCP portal account and a surety bond, you may not be allowed to import your goods once the CARM program goes live.

  • All importers that obtain a bond prior to the release will automatically be set up with a basic sign-on as soon as the CCP goes live.  
  • For all other companies, you will need to apply for a CCP sign on/account as soon as the portal system goes live. Each CCP user will also need to create and account and request access to their business portal account.
  • As noted above, there will be thousands of importers that have to register within a relatively short period of time.

Some questions to consider before CCP is released:

  1. Who will act as your primary account holder for CCP access?
  2. Who will be the alternate account holder? 

You may wish to have the primary account holder be your main in-house customs contact, someone familiar with customs issues. The alternate may be someone within your Accounting or Finance group that will manage the statement and payment processes.

Step 3: Review your payables process well in advance

CBSA has very specific guidelines for when payments must be made. On time payment is critical under this new system.

In most cases, the payment terms/timelines you currently have in place with your customs broker will not be the same as the required CBSA timelines. 

You will need to review your payables process and payment timeframes to:

  • Confirm your bank is set up to receive and transmit payments on behalf of CBSA
  • Ensure your payment process is set up to meet the payment deadlines mandated by CBSA, including allowing sufficient timelines for any internal approvals
  • Verify you have the resources and processes in place to regularly review your daily activity notices and monthly statement of account to catch any potential errors and discrepancies
  • Confirm any applicable third-party payment companies at home or offshore have the ability to manage this process for you. This process is crucial to the ongoing movement of your goods across the border. You may need to reconsider these partners’ involvement with customs payments and bring this process back in-house so you have direct control of the process.
  • Non-resident importers may need to establish a Canadian bank account to support this payable process, as all payments must be in Canadian dollars. Many of the main US banks are not set up electronically with CBSA.

Step 4: Decide how you will manage your service providers

CBSA will require you to confirm, within your CCP profile, which customs brokers you use, including couriers. 

You will need to decide:

  • The level of information and features each broker will have access to, and
  • What each company will manage on your behalf. 

For importers with multiple brokers this may present a significant challenge.  

Some questions to consider:

  1. Do you have a primary broker that manages the bulk of your business? Will they have access to all your import information or just what they handle? 
  2. Do you have consultants that will need access to import records for one or all of your brokers?  
  3. How will you manage changes in brokerage firms and other service providers and changes to delegation options?  
  4. Will you need to consolidate some of your customs business or service providers to reduce the number of firms you need to manage? 
  5. What services within the portal will you manage yourself and what will you have managed by your service providers?

The final information relating to how access authority will be granted and how you can delegate that access has not yet been released by CBSA. Please visit our website or sign up for e-bulletins for further changes.

Step 5: Stay informed

Sign up for Cole’s electronic CARM updates
Regularly visit our CARM web page
Regularly visit CBSA’s CARM web page

The development and release of this new program is on a very rapid timeline.  Although design and policy has not yet been finalized by CSBA, the agency has released information about many of CARM’s upcoming features, requirements, and functions. 

Keep in mind these may be subject to some change before the full program launches. Please visit this site regularly or subscribe to our CARM e-bulletins for ongoing updates.

Subscribe to CARM Updates

Need more information?

Cole is ready to help. If you have further questions, please do not hesitate to contact your local account manager or This email address is being protected from spambots. You need JavaScript enabled to view it. today.

Require a customs bond? This email address is being protected from spambots. You need JavaScript enabled to view it. to submit a request and one of our CARM representatives will contact you directly. 



 

Monitoring CBSA notices

  • Importers will need to monitor their CBSA notices and messages daily.
  • This may require additional resources in some companies depending on how many business units are importing under the company’s 9-digit business number.

Strict penalties

  • Failure to fully pay your statements to CBSA within time limits or maintain appropriate levels of security may result in CBSA restricting your ability to clear goods at the border.
  • Your payables department will need to have access to your CCP account and will need to establish new procedures for reviewing your customs statements and paying CBSA electronically, within regulation guidelines. 
  • Importers will pay CBSA directly for all duties and taxes and pay their customs broker separately for their fees. Confirm that your bank is set up with CBSA for electronic payments.

New internal processes

  • Two contacts will need to be established as the primary and alternate CCP account managers within your organization. 
  • We would recommend the person in your organization interfaces with your customs broker act as the primary and someone in your accounts payable department that will manage your daily and monthly statements and payments to CSBA act as the alternate.

The development and release of this new program is on a very rapid timeline.  Although design and policy has not yet been finalized by CSBA, the agency has released information about many of CARM’s upcoming features, requirements, and functions. 

Keep in mind these may be subject to some change before the full program launches. Please visit this site regularly or subscribe to our CARM e-bulletins for ongoing updates.

Subscribe to CARM Updates

Need more information?

Cole is ready to help. If you have further questions, please do not hesitate to contact your local account manager or This email address is being protected from spambots. You need JavaScript enabled to view it. today.

Require a customs bond? This email address is being protected from spambots. You need JavaScript enabled to view it. to submit a request and one of our CARM representatives will contact you directly. 

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