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 first 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
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.
- 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.
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