Customs Notice 24-23: CARM: Customs Bonded Warehouse Baseline Inventory Count

Ottawa, July 8, 2024

1. The purpose of this Customs Notice is to provide Trade Chain Partners (TCPs), specifically Customs Bonded Warehouse (CBW) licensees (including operators, importers and brokers) with an introduction to the CBSA Assessment and Revenue Management System (CARM) system. This notice will also outline the expectations for CBW TCPs and further communicate new program enhancements and requirements.

2. The CARM platform will be used by CBW TCPs for enrolment and future accounting, as well as to submit a one-time baseline inventory count of goods in their respective warehouses prior to the implementation of the CARM Client Portal (CCP). Note: All current program based requirements and legislative obligations remain in effect.

3. The CARM platform will provide improved mechanisms for CBW TCPs to better communicate and provide all necessary documentation to the CBSA in a secure electronic environment, which will facilitate compliance and traceability requirements of the various CBSA trade programs to which they have applied and/or are enrolled.

4. Although CARM will allow for the electronic submission of applications and documents, the requirement remains for TCPs to keep a hard copy of all electronically submitted applications and associated supporting documentation, as per section 42(2) (a), subsections 43(1) and (2), section 40 of the Customs Act and section 2 of the Imported Goods Records Regulations. These records must be made available to the CBSA upon request.

5. CARM will become the official system for the collection of duties and taxes on October 21, 2024 for goods imported into Canada. At that time, CARM will expand the program based functionalities of the CCP to include electronic accounting and application submission for CBWs. Visit the CARM: CBSA Assessment and Revenue Management webpage for more information pertaining to the CARM system initiative and their phased deployment approach.

6. In preparation for CARM becoming the official system of record for the collection of duties and taxes for goods imported into Canada , Customs Bonded Warehouse TCPs are required to:

1. provide their up-to-date baseline inventory count of all unreleased goods.
2. register in the CARM Client Portal (CCP).
3. keep an accurate account of all CBW movements before, during the cutover period and beyond.

7. It is important to note that the inventory information provided is considered to be a legal declaration and any inaccuracies, errors and/or omissions may result in Administrative Monetary Penalties. All inventory declarations are subject to post-compliance verification. Please note that all CBW TCPs will have the option to provide their inventory declaration directly to the CBSA, or have their representative (agent, customs broker, etc.) submit this information. Should a CBW TCP choose to use a broker to submit their information on their behalf, a copy of Power of Attorney is required before any information can be accepted and processed.

8. The exact dates for the transition measures and the cutover period will be published in a subsequent Customs Notice at a later date.

Recommended procedure for providing an up-to-date baseline inventory count of all unreleased goods

9. CBSA recommends that CBWs use the Application Programming Interface (API) or Electronic Data Interchange (EDI) to transmit inventory counts of all unreleased goods. API and EDI submission methods both allow CBW TCPs to transmit their goods movements into and out of a CBW, and will be used during this one-time CBW inventory exercise to transmit their inventory to the CBSA using their system or their service provider’s system.

10. EDI, a software provision certified by the CBSA, and API, a system integration already tested by CBSA, are the recommended electronic transmission options due to their efficiency and the accuracy of data capture on an individual transaction basis. With EDI or API, data is transmitted directly to the CARM solution with no need for a CBSA officer to review or validate data before it is entered in the solution.

11. Information regarding a submission via EDI or API can be found in Chapter 26: Commercial Accounting Declaration (CAD) of the Electronic Commerce Client Requirements Document ECCRD. Contact the CARM Stakeholder Engagement Team if you require a copy of Chapter 26 of the ECCRD: cbsa.carm_engagement-engagement_de_la_gcra.asfc@cbsa-asfc.gc.ca.

Alternative option 1: Manual CAD submission post-implementation

12. TCPs without EDI or API access, either directly or through their service provider, are required to submit a Type 10 Commercial Accounting Declaration (CAD) via the CCP within the first two weeks of CARM becoming the system of record, to reflect their current warehouse inventory. The date that the CAD is submitted via the CARM portal becomes the date of accounting.

Alternative option 2: Manual review and upload by the CBSA

13. For CBWs unable to transmit their inventories using one of the two recommended options above, the CBSA will provide a one-time file-upload option immediately prior to the cutover period to CARM becoming the official system for the collection of duties and taxes for goods imported into Canada.

14. CBWs will be required to submit inventories into an Excel template provided by the CBSA. A CBSA officer will review and validate entries. CARM technical providers will then upload approved templates during the cutover period.

15. Due to the manual validation required by CBSA officers during a limited cutover window, the Agency has implemented the following procedure for participants who wish to pursue this option:

• Participants must advise the CBSA in writing by August 1, 2024 at the following email address: duty_deferral_notice_comments-avis_report_des_droits_commentaire@cbsa-asfc.gc.ca
• Participants must use a spreadsheet template to be provided by the CBSA to capture inventory data
• Participants must submit a sample inventory of data representing at least 5% of their inventory (minimum 20 lines) in the CBSA-provided template by August 16, 2024. Participants must also indicate the approximate number of importers and the approximate number of total lines of data they will provide for the manual review and upload by the CBSA.
• Participants must submit their complete inventory by the first day of the cutover period
• Participants must login to the CARM portal within the first two weeks of CARM becoming the official system for the collection of duties and taxes for goods imported into Canada, to review and submit any updates or corrections.

16. Important: In the event that a template cannot be uploaded during cutover due to formatting or other issues, including data entry issues discovered by a CBSA officer, the CBW will be required to transmit their inventory via a Type 10 CAD entry at Go Live, as described in paragraph 10 above.

17. Any goods movements that occur once CARM becomes the system of record will have to be declared in CARM.

Engagement

18. For all CARM related questions, the point of contact is the CARM Stakeholder Engagement Team: cbsa.carm_engagement-engagement_de_la_gcra.asfc@cbsa-asfc.gc.ca.

19. For issues relating to the CARM system once an account is created, please complete the client support contact form.

20. For more information, contact the CBSA Border Information Service (BIS):

Calls within Canada and the United States (toll free): 1-800-461-9999

Calls outside Canada and the United States (long distance charges apply):
1-204-983-3550 or 1-506-636-5064
TTY: 1-866-335-3237
Contact us online
Contact us at the CBSA website may also be accessed for information.