Customs Notice 24-29: Preparing for the CARM October Implementation - Cutover Period

Ottawa, August 30, 2024

1. Effective October 21, 2024 the CBSA Assessment and Revenue Management (CARM) system will become the official system for importers and other trade chain partners (TCPs) to account for their goods and pay applicable duties and taxes owed to the Canada Border Services Agency.

2. This notice provides TCPs with important information regarding the cutover period, which is required for the CBSA to migrate existing systems and functionality to CARM systems and functionality for the CARM October 21, 2024 implementation. The CARM cutover period will extend from October 4 (4:00 pm ET) to October 21 (3:00 am ET).

3. At the beginning of the cutover period, some CBSA legacy systems, such as the Customs Commercial System (CCS) and the Customs Automated Data Exchange (CADEX), will be retired.

CARM registration and program enrollment

4. The CARM Client Portal (CCP) will not be available during the cutover period. TCPs will not be able to onboard to the portal until availability resumes on October 21.

5. Trusted Trader Enrolment: Customs Self-Assessment (CSA) enrolment activities will be paused during cutover, resuming October 21, 2024. Starting on October 21, all CSA applications must be submitted via the CCP. Partners in Protection (PIP) enrolment remains available in the Trusted Trader Management System (TTMS).

CARM testing environment availability

6. The CARM testing environment will not be available during the cutover period. TCPs will be able to access the lab the week of October 28, 2024.

New business number (BN)

7. New commercial importers, including non-resident importers, requiring a business number (BN) and importer program account (RM) in order to obtain release for their importation of commercial goods can continue to work with the CRA to obtain a BN, and the CBSA to obtain the RM account for their importing activities via the interim process established in May 2024. This service will be offered until 12:00 pm ET, October 18, 2024.

8. Following CARM implementation on October 21, 2024, for the purposes of commercial business with the CBSA, the BN should be obtained via the CCP, however, CRA’s business number registration process remains available. The program account (RM) can only be obtained via the CARM Client Portal.

Important note: any non-resident requiring a BN, must follow CRA’s business number registration process and then use the CCP to enrol in CBSA programs to obtain a RM account.

9. Alternatively, Customs Brokers may choose to use their broker BN/RM for new importers who have not yet been assigned their own BN/RM account. CBSA will also facilitate the release of goods by extending the use of the CBSA administrative BN on paper C-Type B3 entries for importers that are not using a customs broker during the cutover period, and then on a C-type Commercial Accounting Declaration (CAD) following CARM implementation.

10. The CBSA will continue to designate new exporter RM accounts during the cutover period until October 18, 12:00 pm ET, but exporters will not be able to use their new BN/RM to register for the Canadian Export Reporting System (CERS) or G7 Electronic Data Interchange Export Reporting system until the cutover period is complete. This includes associations of a new BN/RM to a customs services provider.

11. Exporters who obtain their new export BN/RM during the cutover period may use one of the following two options to report the export of commercial goods.

• Option 1: One-time submission
  • Use the services of a customs service provider to report on your behalf;
  • The customs service provider will use the “one time submission” reporting option in CERS to submit an export declaration;
  • Once the cutover period is complete, the exporter completes the CERS or G7-EDI registration process for future export reports.
  Note: New exporters using this option will not be required to re-submit their declaration when their registration is complete.
• Option 2: BSF844 Exporter contingency form
  • Complete the paper BSF844 Exporter contingency form, entering the newly issued BN/RM on the form;
  • Submit two copies of the form to the CBSA export reporting office where the goods are exported, or by email to offices providing the eLongroom service, for review and stamping by a CBSA officer;
  • Once the cutover period is over, complete the CERS or G7-EDI registration application, and re-submit the export declaration electronically using either the CERS or G7-EDI electronic reporting method once your registration process is complete.
  Note: Exporters who submit a paper contingency form and do not complete their registration and submit an electronic declaration, may be subject to penalties.

12. New exporters may continue to submit CERS and G7-EDI registration forms during the cutover period, however these will not be processed until the cutover is complete. New exporters must use one of the two options listed above to submit their declarations during the cutover period. CERS and G7-EDI applications will be processed after the cutover period and exporters will receive notification when their registration is complete.

13. Following CARM implementation on October 21, 2024, for the purposes of commercial business with the CBSA, the BN should be obtained via the CCP, however, CRA’s business number registration process remains available. The program account (RM) can only be obtained via the CARM Client Portal.

Important note: any non-resident requiring a BN, must follow CRA’s business number registration process and then use the CCP to enrol in CBSA programs to obtain a RM account.

Release processing

14. Release processing is not impacted during the cutover period and remains available with the exception of a maintenance window that will extend from the evening of Saturday, October 5, 2024 to the morning of Sunday, October 6, 2024. Details on this maintenance outage will be communicated through the CBSA’s planned outage bulletin.

15. Existing Release Prior to Payment (RPP) privileges remain in place and broker RPP bonds can be used as per current processes.

16. The CADEX Release Notification messages will no longer be sent to importers and brokers as of October 4 (4:00 pm ET). The Release Notification System (RNS) will continue to transmit messages during and post cutover. Importers and Brokers relying solely on the CADEX system to obtain Release Notifications will need to look into alternate ways of obtaining the information. Please refer to the Release Notification System (RNS) application form on the CBSA website for more information. Post CARM implementation, TCPs will also be able to query transactions using the Application program interface (API) or refer to the transactional information available on the CCP.

17. New warehouses cannot be registered during the cutover period. TCPs will not be able to submit cargo and release documents to those warehouses.

Accounting

18. CCS and CADEX will no longer be available starting October 4 at 4:00 pm ET. The submission of electronic accounting documents (B3s) must be held until CARM functionality and the Commercial Accounting Declaration (CAD) is available on October 21   paragraph 22 provides additional details on how to process these withheld B3s.

19. Paper C-Type B3 accounting documents will continue to be accepted and processed at Commercial Office of Release. Customs Commercial Entry Processing System (CCEPS) terminals and printers will remain available to create C-Type B3s.

20. Submission of V-type B3s are to be withheld during the cutover period and submitted via the CCP after it becomes available on October 21.

21. CSA importers can submit their final Revenue Summary Form (RSF) no later than October 3 at 4:00 pm ET for payment by October 31, 2024. All transactions not captured on the final RSF must be accounted for in CAD format after October 21. Additional information on CARM cutover for CSA importers can be found on Customs Notice 24-30 Preparing for the CARM October Implementation – Trusted Trader CARM Cutover Procedures.

Electronic accounting documents (B3/CAD) withheld during cutover Period

22. Starting on October 21, 2024, TCPs will be required to submit, in the new CAD format, their electronic accounting documents that were withheld during the cutover period (backlog of CADs). In order to allow the CARM system to efficiently process this significant volume of expected CADs, the CBSA has established a schedule, instructing TCPs on how to submit their backlog of CADs.

23. For the period of October 21 to October 29, 2024, TCPs should be submitting the following CADs:

Transmission Date	Expected Due Dates of CADs that Were Withheld During CutoverTablenote 1	Due Date of CADs for Current PeriodTablenote 2	Included on SOA (Month)
October 21, 2024	October 4 to October 5	October 21, 2024	October
October 22, 2024	October 6 to October 7	October 22, 2024	October
October 23, 2024	October 8 to October 9	October 23, 2024	October
October 24, 2024	October 10 to October 11	October 24, 2024	October
October 25, 2024	October 12 to October 13	October 25, 2024	November
October 26, 2024Tablenote 3	October 14 to October 15	Weekend	November
October 27, 2024Tablenote 3	October 16 to October 17	Weekend	November
October 28, 2024	October 18 to October 19	October 28, 2024	November
October 29, 2024	October 20	October 29, 2024	November

24. Accounting timeframes for Courier Low Value Shipments (CLVS) and Continuous transmission commodities (CTC) remain the same. Accounting declarations for CLVS and CTC are due by the 24th day of the month following the month in which the goods were released.

Statement of account (SOA) and payment processing

25. The October Statement of Account (SOA) will be available on October 25 as per current process.

26. The October SOA will include all B3s and payments submitted between September 25 and October 4 and all CARM transactions submitted and processed between October 21 and October 24.

27. Any transactions not submitted or processed by October 24 will be included on the November SOA.

28. For the October SOA, payments must be made by October 31st using Online Banking (via financial institution platforms); Electronic Data Interchange (EDI820); Point of Sale (POS) systems/Cash/Cheques at Points of entry; Cheques mailed to CBSA, Accounts Receivable Management Unit. Pre-Authorized Debits (PAD) will be initiated on October 31st for all existing registrants.

29. Notice of lien inquiries can continue to be sent using the Client support contact form by selecting “Financial account activities” and requesting assistance with “I cannot import because my account is frozen.” These requests will be dealt with on a case by case basis.

30. As a result of changes with the CARM October implementation, November 2024 could be the first month that an importer's SOA will be fully paid by the importer, based on the terms of the PAD agreement or other methods of payments. Importers who have registered or intend to register for PAD must discuss this payment option with their customs brokers to avoid duplicate payments.

31. Processing of any disbursement requests will not be available during the cutover period. Disbursements will resume following October 21 implementation.

32. Effective October 4th, if a Broker is making a payment, it must be directed to the Importer’s account (RM15) to allow the payment to be transferred to the Importer’s account at October 21st. The payment will clear against the debt on the Importer’s account starting October 21st. Payments on the Broker's account will not clear Importer's debt after go-live.

Note: The payment allocation process, performed before CARM R3 will no longer be executed, effective October 4th. This is applicable to all payment methods, such as cheque, EDI and online payments via financial institutions.

33. As part of the cutover period, Pre-Authorized Debits (PAD) were not withdrawn on October 1, 2024. The PAD for September SOA will be processed on October 21, 2024 for all existing registrants. Please note that no late payment penalties and interests will be charged as a result of this delayed PAD withdrawal.

Note: Please ensure that sufficient funds will be available for the PAD withdrawal on October 21, 2024.

Penalties and interest

34. During the cutover period and for a period of 90 calendar days following the October 21, 2024 implementation, the CBSA will not be issuing late accounting penalties, late payment penalties and late payment interest. The CBSA may adjust this timeline if it deems necessary to further mitigate the transition to CARM system.

Note: that an account for which a SOA has not been paid as per the specified due date may still be subject to collection measures by the Canada Revenue Agency during that period.

Exchange rate API

35. The Production API Exchange Rate was made available to TCPs on September 20, 2024.

36. In advance of cutover activities beginning on October 4, the CBSA will maintain the current CCS production exchange rate as well as the Production API Exchange Rate.

37. Once CARM R3 is implemented on October 21, the CBSA will maintain the Production API Exchange Rate.

Other business and operational processes

38. For Customs Bonded Warehouse (CBW) movements of goods, CBSA will accept and process paper type 10 B3s. TCPs will be required to capture in the CCP any Type 10s presented during the cutover period ensuring adjustments are made to their electronic inventories post October 21 CARM implementation. For CBW, ex-warehouse movements of goods, TCPs may reference and/or show proof of their approved in-warehouse movements in order to remove goods from their warehouses.

39. Commercial Temporary Importations will follow the current-state process using the E29B form. There will be no need to capture the E29B forms presented during cutover, in the CCP after CARM implementation.

40. Duties Relief Program (DRP) applications and Drawback claims will follow the current-state process.

41. CBSA recommends TCPs, where possible, to refrain from submitting any paper Single and Blanket B2 Adjustments, Voluntary Disclosure requests, Duties Relief Program diversions, Release Prior to Payment applications and wait to submit in CARM after October 21.

42. TCPs can submit their appeals using the recourse e-mail submission process or paper submission is also available.

43. CBSA will run all regular system batch programs the evening of October 4, which means that the exchange rates file will be made available to TCPs for the weekend of October 5-6 as per current process one last time.

New system connectivity and CARM profiles creation

44. For TCPs that are currently receiving Daily Notices (DN) and SOA documents, the CBSA will maintain and migrate their existing system profiles from the current environment to the CARM R3environment.

Additional information

45. During the cutover period, regular updates on cutover activities progress will be communicated to TCPs.

46. If you have any questions about the cutover period, please contact us at
cbsa.carm_engagement-engagement_de_la_gcra.asfc@cbsa-asfc.gc.ca.

47. For assistance, the CARM Client Support Helpdesk remains available before, during and after the cutover period. Please call 1-800-461-9999 and select option 2 or use our client support contact form on the CBSA website.