Customs Notice 24-25: Submission and Processing of Single B2 and Blanket B2 Adjustments, or Voluntary Disclosure Program Requests on or After September 1, 2024

Ottawa, August 02, 2024

1. Effective October 21, 2024, Release 3 of the CBSA Assessment and Revenue Management (CARM) system will become the official system of record that importers and other trade chain partners (TCPs) will use to account for their commercially imported goods and pay duties and taxes owing to the Canada Border Services Agency (CBSA).

2. This will result in the elimination of Form B2, Canada Customs - Adjustment Request, which is currently used to submit and process adjustments to Form B3-3, Canada Customs Coding Form. This process will be replaced by the submission of an adjustment against a Commercial Accounting Declaration (CAD) in CARM.

3. This notice is to inform TCPs that single B2 adjustments, blanket B2 adjustments or voluntary disclosure requests submitted on or after September 1, 2024, will be accepted by the CBSA but are unlikely to be processed before CARM Release 3 (R3). As an exception during this period, B2 blanket requests must contain both the B2 blanket authorization application and a completed Form B2 Adjustment Request.

4. B2s not processed by the CBSA before R3 will be manually entered in CARM starting October 21, 2024. While the Agency will strive to meet its service standards, TCPs will experience processing delays during this transition. To limit the accrual of interest, TCPs are encouraged to submit B2s with payments for amounts owed to the Receiver General. Note that any payment processed after R3 will be posted to the importer’s account and not allocated to the adjustment specifically. Account based accounting will offset any credit according to the clearing order.

5. In order to benefit from electronic processing and to avoid delays resulting from CBSA manually keying B2s into CARM, trade chain partners are asked to refrain from submitting single B2 adjustments, blanket B2 adjustments and voluntary disclosure authorization requests to the CBSA for the period between September 1 and October 20, 2024. Submission via CARM instead of a Form B2 is recommended, as electronic processing is quicker than manual entry by the CBSA.

6. CBSA’s service standard of 90 days to process an adjustment will not change before or after CARM implementation.

7. Starting October 21, 2024, trade chain partners must submit single adjustments to Form B3-3s by following the guidance in Memorandum D17-2-4: Preparation and Presentations of Pre-CARM Adjustment. Form B2: Canada Customs - Adjustment Request will not be accepted on or after October 21.

8. At R3, TCPs will also be able to report their Duties Relief Program (DRP) Diversions for transactions using the same pre-CARM blanket process listed in D17-2-4.

9. In cases where an importer’s 90-day reason to believe obligation under section 32.2 of the Customs Act expires between September 1 and October 20, 2024, the CBSA will use its discretion in applying penalties during that timeframe. This includes contraventions C080, C081, C082, C083, C350, C351, C352 and C353. Discretion will be applied on a case-by-case basis as the CBSA will consider the guidance from this notice prior to application. The agency will also use its discretion in applying prescribed interest rate instead of specified interest rate to these adjustments.

10. In cases where adjustments are a result of a trade compliance verification or a voluntary disclosure authorization, TCPs should consult with the responsible senior officer trade compliance for guidance.

Exceptions

11. This notice does not apply to appeal submissions under section 60 of the Customs Act. 12. This notice also does not apply to cases where a transaction is within two months of expiry, adjustments should still be submitted following the existing procedures outlined below:

• a. For the requirements of the submission of Form B2, please refer to Memorandum D17-2-1: The Coding, Submission and Processing of Form B2 Canada Customs Adjustment Request
• b. For the requirements for Blanket B2 Adjustment requests, please refer to Memorandum D17-2-4: Preparation and Presentation of Blanket B2 Adjustment Requests
• c. For the requirements of the Voluntary Disclosure program, please refer to Memorandum D11-6-4: Relief of Interest and/or Penalties Including Voluntary Disclosure
• d. For the requirements of the Duties Relief Program and Duty Drawback program, please refer to Memorandum D7-4-1: Duties Relief Program and Memorandum D7-4-2: Duty Drawback Program
• e. For guidance on Re-determinations and Appeals Under the Special Import Measures Act, please refer to Memorandum D14-1-3: Re-determinations and Appeals Under the Special Import Measures Act

13. Should a TCP fail to make a submission by their four year legislative deadline, their time limit will not be protected.

14. For more information, contact CBSA Border information services:

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

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