Customs Notice 24-17: CARM: Launch to External Clients Rescheduled to October 2024

Ottawa, April 26, 2024

1. On April 19, 2024, the CBSA issued a news release to provide an update on its plans for the launch of the CBSA Assessment and Revenue Management (CARM) system.

2. The CBSA communicated that CARM will launch Release 2 internally at the CBSA on May 13, as planned, to advance the Agency’s compliance and enforcement efforts.

3. Responding to uncertainty in the labour environment, the CBSA also indicated that it is preserving the status quo for industry when they account for duties and taxes. It is therefore the intention of the CBSA to reschedule the launch to Trade Chain Partners (TCPs) to October 2024.

4. As a result, the CARM system will not become the official system of record that importers and other trade chain partners will use to account for imported goods and pay for duties and taxes, on May 13 2024, as previously communicated.

5. This notice is to address potential impacts of the rescheduling of the external launch of the CARM system may have on TCPs and also to provide information on what to expect during the period leading to the new October implementation date.

Cancelled customs notices

6. In light of the move of the external launch of CARM to October 2024, the CBSA proceeded to cancel the following recently published Customs Notices, that provided TCPs with instructions for the period leading up and during the cutover to CARM, as well as details on transition measures that were to be introduced following the implementation:

• CN 24-11 Submission and Processing Single and Blanket B2 Adjustments or Voluntary Disclosure requests on or after April 1, 2024
• CN 24-12 CARM Administrative Measures related to the Duties Relief Program, Duty Drawback Program and Commercial Temporary Importations under Tariff Item No. 9993.00.00
• CN 24-14 Preparing for CARM Release 2 Implementation, Cutover Period
• CN 24-15 Preparing for CARM Release 2 Implementation, Transition Measures

Cutover period

7. The previously announced CARM Release 2 cutover period, previously scheduled for April 26 to May 13, will not occur as planned. The CBSA is maintaining the legacy environment for accounting and payment, and current state processes will remain in effect.

8. Cutover activities to support the internal launch of CARM Release 2 will not impact CBSA external operations, or TCPs directly. A previously planned outage of the ACROSS system on April 27 and April 28 will not occur. Any future planned ACROSS maintenance outages will be communicated through the CBSA regular planned outage bulletin.

9. The CARM Client Portal (CCP) will continue to be available allowing TCPs to continue registering to CARM.

10. The CBSA will be communicating the dates and instructions on the new cutover period leading to the CARM October launch at a later date.

Transition measures

11. The CBSA has developed and communicated transition measures to ensure continued border fluidity and timely submission of accounting and payment of duties after CARM implementation. These measures will only be introduced following the October 2024 implementation of the CARM.

12. The CBSA will be communicating the details of the transition measures to TCPs at a later date.

Accounting

13. Until implementation of CARM in October 2024, CCS will continue to be the system of record for TCPs to account for imported goods and pay for duties and taxes. CADEX will continue to be available to TCPs to submit of electronic accounting documents (B3s).

Statement of Account and Payment Processing

14. The April Statement of Account (SOA) will be available on April 25, as per current process. There will be no interruption to the issuance of Daily Notices (DN) to TCPs .

15. For the April SOA, payments must be made by April 30. Payments by Pre-Authorized Debits (PAD) will be withdrawn on April 30, as per current process.

Disbursements – casual refunds

16. System connections linking to the Casual Refund System (CRS) will not be impacted. The CBSA will continue to review casual refund claims and process disbursements, as per current-state processes.

Release prior to payment and financial security

17. Existing Release Prior to Payment (RPP) program requirements remain in place until the October 2024 implementation of the CARM. Importers will continue to be able to use a broker's RPP financial security to obtain the release of imported goods prior to accounting and payment of duties and taxes.

18. The ability for a TCP to post their financial security through the CARM Client Portal (CCP) will only be made available following implementation of CARM in October 2024.

19. The existing paper-based process to post a financial security with the CBSA, using form D120 Customs Bond, remains in effect.

Other business and operational processes

20. Single and Blanket B2 Adjustments, or Voluntary Disclosure requests can continue to be submitted using current-state processes.

21. Duties Relief Program (DRP) applications, Drawback claims, DRP Diversions and commercial temporary importations under Tariff Item No. 9993.00.00 can continue to be submitted using current-state processes.

22. On March 28, 2024, the CBSA published Customs Notice CN 24-10 Termination of the temporary electronic procedures for Canada Border Services Agency’s Trade Programs (COVID-19) – GTA Pilot , which remains applicable. This pilot project was terminated on March 31, 2024. Electronic submissions made after this date for Single and Blanket B2 Adjustments or Voluntary Disclosure requests will not be accepted nor acknowledged.

Customs Bonded Warehouse – One-time inventory capture

23. Customs Bonded Warehouse (CBW) TCPs (including operators, importers and brokers) are no longer required to send their formal up-to-date baseline inventory count before April 26, as previously communicated.

24. The new date to submit the CBW inventory count will be announced once the CARM implementation date is confirmed. The CBSA will be updating CN 23-20 Introduction to the CARM for CBW Licensees and Importers to reflect the revised dates.

CARM testing and certification

25. The CARM testing environment will be supported and available to TCPs to continue their testing and certification activities until May 31, 2024.

CBSA compliance verification activities following internal launch of CARM release 2

26. The implementation of CARM Release 2 for internal CBSA use, as part of its CBSA compliance verification activities, will follow the same existing processes:

• Industry's compliance obligations will not change.
• The CBSA will continue its compliance assurance activities, leveraging the CARM tool and other existing tools in accordance with CBSA's culpability framework.
• The CBSA is simply adding CARM to its compliance toolkit, as planned.

Business Number (BN)

27. Business Numbers can continue to be requested from Canada Revenue Agency (How to register for a business number or Canada Revenue Agency program accounts).

28. Work is underway on developing a CBSA administered process for the registration and maintenance of program (RM) accounts for importers and exporters. Details will be published on the CBSA website.

Additional Information

29. The CBSA will be communicating information on detailed activities leading up to the implementation of CARM in the coming months.

30. If you have any questions about the rescheduled launch of CARM to TCPs, please contact us at cbsa.carm_engagement-engagement_de_la_gcra.asfc@cbsa-asfc.gc.ca.