Customs Notice 24-27: CARM October Implementation – Transition Measures
Ottawa,
1. The information contained in this Customs Notice is applicable to importers and customs brokers (hereafter referred to as “broker”) involved in the importation of goods into Canada.
2. Effective the CBSA Assessment and Revenue Management (CARM) system will become the official system that importers and other trade chain partners will use to account for imported goods and pay for duties, including taxes, (hereafter referred to as “duties”) owing on the goods. Additionally, the CARM Client Portal (CCP) also becomes the Agency’s centralized system for trade chain partners to register their CBSA account and enroll in the various CBSA programs (e.g., Importer; Release Prior to Payment; etc.)
3. The CBSA has developed transition measures to ensure continued border fluidity and timely submission of accounting and payment of duties after CARM implementation on .
Release Prior to Payment (RPP)
4. When CARM becomes the official system of record on , obtaining the release of imported goods prior to accounting and payment of duties will change for importers. They will no longer be able to use a broker's RPP security to obtain the release of imported goods before paying duties. Importers who want to obtain the release of imported goods prior to the payment of duties will be required to post their own financial security through the CCP.
5. Regulatory changes have been made and will come into force on . Regulations introduced a 180-day transition period following CARM implementation, from to , to allow time for importers to obtain financial security. This will give importers and their service providers time to adapt to the new financial security model and avoid border disruptions.
6. All commercial importers with a history of accounting for commercial goods using their importer business number within the past four years will automatically benefit from RPP for a period up to 180 days following CARM implementation on .
7. After , new importers without a history of importing commercial goods into Canada within the past four years will also be able to benefit from the remainder of the 180 day transition period. Since CARM would have no historical data for the new importer, the financial security requirement would be calculated at zero dollars. Therefore, the importer will only be required to complete the RPP sub-program enrollment in order to qualify for the remainder of the 180-day transition period.
8. During the 180-day transition period, importers will need to ensure they are registering in the CCP and posting applicable financial security in order to avoid disruption to the release prior to payment of duties of goods they import after the 180-day transition period ends.
9. Following the , implementation of CARM, trade chain partners will register for a new import-export program (RM) account via the CARM Client Portal. The CBSA will terminate its interim process for the registration and maintenance of import-export program (RM) accounts, that was introduced on .
Use of Broker Business Number (BN15) – Commercial Goods
10. For a 12-month transition period, the use of broker BN15 will be allowed under specific scenarios as set out below.
11. A broker can use their BN15 to account for commercial goods on behalf of an importer (including Non Resident Importers (NRIs)) who has a BN15 and obtained the release of imported goods using the importer’s BN15 but has not yet registered to the CCP. This transitional measure is designed to mitigate potential for late accounting and payment. For this scenario, the submission of Form A48 RMD Correction by the broker will not be required. Please note that use of broker BN15 at the time of release is not permitted when the importer already has a BN15 or has not yet obtained one unless the circumstances meet one of the criteria listed below.
12. For a period of 12 months post CARM implementation, a broker can use their BN15 at time of release and accounting for commercial goods for a new NRI who has not registered or is in the process of registering in the CCP to obtain a BN15.
13. For first-time commercial importers (including NRIs), brokers should direct the importer to register to the CCP and obtain a BN15 immediately and prior to submitting release. If it is not feasible or would result in the release of goods upon arrival being delayed, the CBSA will allow, for a period of up to 12 months post CARM implementation, the use of a broker BN15 for the purpose of obtaining the release and to account for commercial goods. The CBSA will also facilitate the use of a CBSA administrative BN15 on paper C-Type CAD for importers that are not using a broker.
14. For one-time commercial importers, the CBSA will allow, for a period of up to 12 months post CARM implementation, the use of a broker BN15 for the purpose of obtaining the release and to account for commercial goods. The CBSA will also facilitate the use of a CBSA administrative BN15 on paper C-Type CAD for importers that are not using a broker.
15. For a 12-month transition period, the CBSA will allow for the continued use of a broker BN15 to account for commercial goods on the F-type CAD in the CLVS stream when the importer, including NRIs have not registered to the CCP. The release of CLVS shipments will not be delayed due to the commercial importer not having a BN15, not being registered to the CCP, not having delegated authority to a broker or not having enrolled in RPP.
16. For a 12-month transition period following CARM implementation, if it is determined post release and delivery, that goods did not qualify for CLVS clearance (e.g., HVS, OGD regulated, etc.), broker BN15 may be used on the V-type CAD.
Use of Broker BN15 – Non Commercial (Casual) Goods
17. Current policy permitting the use of broker BN15 and RPP to obtain release and to account for non-commercial goods cleared through the commercial stream will be maintained. This policy will be maintained beyond the 12-month transition period after .
18. As a general rule, the BN15 belonging to an approved CLVS participant should be used for accounting when submitting the F-type CAD for non-commercial CLVS goods.
19. When a General Agency Agreement is in place with a non-commercial CLVS importer, a broker will be permitted to submit the non-commercial F-type CAD using the broker BN15.
Use of Broker BN15 - Other Business and Operational Processes
20. The CBSA will continue to allow use of broker BN15 for the temporary importation of trade show and convention goods for both release and accounting on behalf of Importers. This policy will be maintained beyond the 12-month transition period after .
21. CBSA will allow for the continued use of broker BN15 to represent Auction House for both the release and accounting of importations on behalf of Importers who are not registered in the CCP or obtained a BN. This policy will be maintained beyond the 12-month transition period after .
Coming into Force of the Importer of Record Amendments
22. The legislative amendments to Section 17 of the Customs Act are not yet in force, but will come into effect on a day or days to be fixed by order of the Governor in Council (GIC). The requirement to have an order of the Governor in Council fixing the coming into force date is reflected in Section 331 of Budget Implementation Act, 2022, No. 1.
23. The amendments under Section 17 of the Customs Act are worded in such a way that that they will come into force, and subsequently enforced, on a day to be fixed by order of the Governor in Council. This date is yet to be determined. If you are an entity that becomes subject to Section 17, solely due to these amendments, your liability will begin on the date the Section 17 amendments come into force.
Additional Information
24. If you have any questions about the transition measures, please contact us at cbsa.carm_engagement-engagement_de_la_gcra.asfc@cbsa-asfc.gc.ca
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