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:
- Who will act as your primary account holder for CCP access?
- 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:
- 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?
- Do you have consultants that will need access to import records for one or all of your brokers?
- How will you manage changes in brokerage firms and other service providers and changes to delegation options?
- Will you need to consolidate some of your customs business or service providers to reduce the number of firms you need to manage?
- 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
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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