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Memorandum D23-3-1 - Customs Self-Assessment Program for Importers

Note to reader

Canada Border Services Agency is currently reviewing this D-memo. It will be updated in the context of the CBSA Assessment Revenue Management (CARM) initiative and made available to stakeholders as soon as possible. Find out about CARM.

Ottawa, November 10, 2022

ISSN 2369-2391

This document is also available in PDF (1.2 MB) [help with PDF files]

In brief

1. The definitions section has been revised.

2. References to Free and Secure Trade (FAST) lane use have been amended and now state that only members of Partners in Protection (PIP) or members of both Customs Self-Assessment (CSA) and PIP can access these lanes.

3. The Privacy Statement section has been amended to include the appropriate section of the Act.

4. The Eligibility Criteria have been revised to be consistent with the Accounting for Imported Goods and Payment of Duties Regulations (AIGPDR).

5. The Transfer of CSA Authorization section has been revised.

6. The Place of shipment section has been revised.

7. This memorandum has been revised to remove the references to invalid service options 539 and 547 and replaced with service options 984 and 976.

8. The CSA Late Accounting Penalties section has been revised.

9. NAFTA has been replaced by CUSMA.

10. This memorandum has been revised to include new excise duty code 49435 on vaping products in APPENDIX G - Line object codes for RSF effective .

11. New Appendix F — Letter of Authorization has been added to the memorandum.

12. Certain terminology, web site references, form names, and contact information at the Canada Border Services Agency (CBSA) have been updated.

This memorandum must be read in conjunction with memorandum D23-2-1.

This memorandum provides information and guidelines regarding the CSA Program for Importers. This memorandum reflects the modifications resulting from the implementation of the Accounts Receivable Ledger which introduces a new client account where invoices are posted to clients’ accounts under Release Prior to Payment Privileges and an electronic payment option. This revision also reflects the amendments made to the Accounting of Imported Goods and Payment of Duties Regulations and to the Reporting of Imported Goods Regulations and explains the requirements for CSA. This memorandum now includes updates to CSA program policy. Paragraphs have been added or moved to consolidate and/or clarify information.

Legislation

Customs Act, paragraph 32(2)(b) and section 32.2

Accounting for Imported Goods and Payment of Duties Regulations

Reporting of Imported Goods Regulations

Guidelines and General Information

Definitions

1. The following definitions apply to this memorandum:

Account Security
The pre-authorized amount of money or bond posted in accordance with Memorandum D1-7-1, Posting Security for Transacting Bonded Operations to secure the duties and taxes debt on imported goods.
Account Security Number
The account security number (ASEC) is a 5-digit number assigned by the CBSA to an importer or licensed customs broker who has posted security with the CBSA number.
Accounting Trigger
A process initiated from within the CSA importer’s business systems that notifies them that there are imported goods for which customs accounting is required. The accounting trigger replaces the notification process that occurs when goods are released by the CBSA.
ACROSS
Accelerated Commercial Release Operations Support System
Act
Customs Act
Authorized Officer
A person holding legal signing authority for the company that is applying for authorization under CSA.
AIGPDR
Accounting for Importer Goods and Payment of Duties Regulations
AMPS
Administrative Monetary Penalty System (AMPS). A system whereby the CBSA issues monetary penalties to commercial clients for violating the Canada Border Services Agency's (CBSA) trade and border legislation. The purpose of AMPS is to provide the CBSA with a means to deter non-compliance by its clients and create a level playing field for all Canadian businesses.
Authorized to Deliver
The status of a CSA shipment that allows the carrier to deliver the goods directly to the place of business of the importer, owner, or consignee where the importer and carrier are authorized. In highway mode, the driver is registered under Commercial Driver Registration Program (CDRP) or FAST. The carrier is liable for duties until the importer, owner or consignee receives the goods.
Border Services Officer (BSO)
Formerly, Customs Officers, Immigration Officers, and Food Inspection Officers, BSO is the new term used to designate any and all of these CBSA officers.
Business Day
Any day during which the customs office is open and accepts delivery or removal of commercial goods.
Business Number (BN9)
A 9-digit numerical Canada Revenue Agency (CRA) business registration number used to uniquely identify legal entity information of a business when dealing with the federal, provincial and municipal governments (e.g., 123456789).
Business Number (BN15)
A 15-character alphanumeric identifier assigned by the Canada Revenue Agency to identify a business, made up of the 9 digit business number appended by a 6 digit alpha-numerical number used to uniquely identify the business’s import/export accounts (e.g., 123456789RM0001).
CADEX
Customs Automated Data Exchange
CAD
Canadian dollars
Carrier Code
A unique 4-digit identifier issued by the CBSA to identify a specific carrier.
Carrier/Transporter
A person who, in accordance with the Transportation of Goods Regulation, is authorized to transport goods or to cause goods to be transported.
CCN
The Cargo Control Number (CCN) is a number assigned to a transport document. It uniquely identifies cargo detailed on a cargo submission. The cargo control number consists of the Carrier code followed by a unique reference number assigned by the carrier/representative and cannot contain spaces. The first four characters are the CBSA approved carrier code.
CCS
Customs Commercial System
Clearance
A function performed by the CBSA that provides authorization to move inward or outward from the CBSA’s control. Under the CSA program, the clearance process occurs at the first point of arrival and provides the carrier with authorization to deliver the shipment. It is different from the release of the goods that occurs when the goods are delivered.
Commercial Driver Registration Program (CDRP)
A voluntary CBSA program to register commercial truck drivers and allow them to participate in the CSA program. Drivers that meet the qualifications of the program become registered drivers and receive a photo identification card.
Commercial Goods
Goods imported into Canada for sale or for any commercial, industrial, occupational, institutional or other like use.
Control Port
A valid CBSA port number selected by the CSA importer for CSA processing.
CSA
Customs Self-Assessment
CSA Clearance
Goods that are eligible to enter Canada under a CSA service option, which are imported by an authorized importer and transported into Canada using an authorized carrier. In the case of commercial highway conveyances, the driver is to be registered under the CDRP or FAST.
CSA Carrier
A carrier that holds a CSA authorization.
CSA-Eligible Goods
Eligible goods mean commercial goods that have been shipped directly from the United States or Mexico, where those goods do not require, under any Act of Parliament or of the legislature of a province, a permit, license or other similar document to be presented to the CBSA at the time of report.
CSA Importer
An importer that holds a CSA authorization.
CSA Release
The date on which goods of the authorized importer are physically received on site, at the place of business of the importer, owner or consignee, regardless of when the goods are actually received into inventory.
CUSMA
Canada United States Mexico Free Trade Agreement
DAS
Detailed Adjustment Statement, Form B2-1. A statement of adjustment issued in response to a request made by an importer/agent or as a result of the CBSA's review of an accounting document.
Date of Decision
For automated self-adjustments, the decision date is the date on which CCS accepts the transmission of an error-free adjustment entry type “X”. For adjustment submitted to the CBSA on a hard-copy B2, the decision date continues to be the “decision date” of the DAS.
Date of Payment/Duty Paid Date
The date that a designated financial institution receives the CSA remittance voucher (BSF645) with the accompanying payment. The date of payment is not the date of the related Revenue Summary form.
Date of Release
The date the goods are received at the place of business of the CSA importer, owner or consignee, regardless of when the goods are actually received into inventory; or the date goods were released by the CBSA.
Daily Notice (DN)
A report for brokers and importers using release prior to payment privilege to import goods into Canada. This report contains accounting transactions for debits, credits and payments per importer.
Division
A branch of a company that is not separately incorporated.
ECCRD
Electronic Commerce Client Requirements Document (ECCRD). Document that provides comprehensive information about business and system requirements of various electronic transactions for multiple import and export programs.
EDI
Electronic Data Interchange is the method to electronically transmit import or export data and accounting documents to the CBSA.
FAST
Free and Secure Trade. A commercial clearance initiative designed to ensure safety and security while expediting legitimate trade across the Canada-U.S. border.
Financial Institution
  • (a) a bank;
  • (b) a credit union;
  • (c) a corporation authorized by an Act of Parliament or of the legislature of a province to carry on the business of offering its services as a trustee to the public; or
  • (d) a corporation authorized by an Act of Parliament or of the legislature of a province to accept deposits from the public and that carries on the business of lending money on the security of real property or of investing in mortgages or hypothecs on real property.
FTZ

Foreign-Trade Zones are secure areas under U.S. Customs and Border Protection (CBP) supervision that are generally considered outside CBP territory upon activation. Foreign-trade zone sites are subject to the laws and regulations of the United States as well as those of the states and communities in which they are located.

The usual formal CBP entry procedures and payments of duties are not required on the foreign merchandise unless and until it enters CBP territory for domestic consumption, at which point the importer generally has the choice of paying duties at the rate of either the original foreign materials or the finished product. Domestic goods moved into the zone for export may be considered exported upon admission to the zone for purposes of excise tax rebates and drawback.

GST
Goods and Services Tax
Harmonized System (HS)
The Harmonized Commodity Description and coding system of tariff classification for imported goods.
HVS
High Value Shipment. Commercial goods with a value for duty exceeding $3,300 CAD.
In-Bond Movement
The inland movement of goods that have not yet obtained Customs release. Only a carrier who has posted security with the CBSA may use the in-bond process.
Interim Payment
An amount paid at the end of a month for the estimated duty and taxes owing on goods that were received/released but were not accounted for before the submission of the RSF.
LTL
Less than Truckload
LVS
LVS – Low Value Shipment. Commercial goods with a value for duty of $3,300 CAD or less
NAFTA
North American Free Trade Agreement
OGD
Other Government Department
Owner-operator
A person who owns and operates transportation equipment, and has a written contract to provide equipment exclusively to a CSA carrier.
Post-Incident Analysis
The activities undertaken with a member following a breach of supply chain security. The PIA will investigate the incident, identify any mitigating circumstances, and formulate a strategy for the prevention of future incidents.
Revenue Summary Form (RSF)
A monthly revenue summary prepared by the importer electronically that includes a breakout (by line object code) by tax and duty type; a summary of self-assessed adjustments; self-assessed interest amounts, either debit or credit; CBSA-assessed payment such as AMPS (e.g. late accounting) penalties, or DASs; the interim payment reconciliation (when required), and the total revenue remittance amount. The RSF is prepared in lieu of the SOA.
RM
The import/export account identifier used to distinguish an importing or exporting branch or division of a business. The account identifier consists of six digits; the RM program identifier to indicate that it is an import/export account, and a four-digit reference number that is unique to each account.
RMD
Release on Minimum Documentation, allows importers to obtain release of goods by presenting interim documentation
Service Option (SO)
A numeric identification used in ACROSS to identify a specific clearance program.
Shipment
  • (a) A shipment for which a carrier is responsible is one that consists of:
    • (i) A specified good or collection of specified goods that is listed in a single bill of lading, waybill or other similar document that is issued by the carrier and that relates to the carriage of those goods; or
    • (ii) A specified good that is an empty cargo container that is not for sale that is transported by the carrier but that is not listed in a bill of lading, waybill or other similar document; and
  • (b) A shipment for which a freight forwarder is responsible is one that consists of a specified good or collection of specified goods that is listed in a single bill of lading, waybill or other similar document that is issued by the freight forwarder and that relates to the carriage of those goods
SIMA
Special Import Measures Act, which governs the assessment of anti-dumping and countervailing duties on imported goods.
Statement of Account (SOA)
For brokers: A report showing a summary of all debits and credits per calendar day for each of their importer clients. For importers: A report showing a summary of all debits and credits per calendar day for each of their RM accounts, including a total payable (only non-CSA importers using Release Prior to Payment Privilege will receive SOAs).
Summary of Drawback Activity (SDA)
A form (CBSA130) used by a CSA importer to report summary drawback information in place of individual drawback claims.
Sweep
A process within the importer’s business systems that will identify unmatched orders/receipts/ invoices to ensure that all goods are accounted for and duty paid in accordance with the Customs Act.
TCCU
Technical Commercial Client Unit – unit of the CBSA that provides technical advice and testing to external commercial clients.
Trade Chain Partner (TCP)
An enterprise that is directly involved in the importation or cross-border movement of goods imported or transported by a CSA importer. TCP names are captured in ACROSS as part of an ongoing risk process and to verify legitimacy of a shipment. TCPs of the importer include United States and Mexico vendors and consignees in Canada that receive direct shipments.
TRQ
Tariff Rate Quota. A specified quantity that determines the applicable tariff rates of certain goods imported into Canada. Goods classified under a “within access commitment item” are subject to reduced duty rates.
UN/EDIFACT
United Nations/Electronic Data Interchange for Administration, Commerce and Transport is the international EDI standard developed under the United Nations
United States Goods
Goods that are imported from the United States, including US FTZs, not having been trans-shipped through the United States from a third country. United States goods may include goods originating in the United States, or goods that have legally entered the commerce of the United States.

Introduction

2. Customs Self-Assessment (CSA) is a Canada Border Services Agency (CBSA) program designed to streamline the import process for authorized low-risk importers who have the systems capability to self-assess the accounting for imported goods to the CBSA, report revenue , and pay duties and taxes.

3. To use Free and Secure Trade (FAST) lanes into Canada, carriers and importers must be authorized under the Partners in Protection (PIP) program or under both the CSA and PIP programs. The driver must be registered in either the FAST Commercial Driver Program or the Commercial Driver Registration Program (CDRP). For additional information about FAST and PIP, refer to the CBSA website.

4. All legislative references to sections, subsections and paragraphs in this memorandum are from the Customs Act (the Act), unless otherwise stated.

5. The CSA program is comprised of two components:

(1)  Accounting, Revenue Reporting, Payment and Adjustment – Importers authorized under the CSA program use the CSA accounting and payment processes for all commercial goods imported, regardless of the clearance process used to report the goods to the CBSA.

(2)  Clearance (Transportation and Reporting of Goods)CSA clearance is an optional reporting process available only to members of CSA. To use CSA clearance, the following conditions must be present:

6. The fundamental features of the CSA program include:

General Process Requirements

7. The points below are provided as a general overview of the CSA process requirements for a CSA importer:

For border processing:

For accounting, adjustment, revenue reporting and payment:

Privacy Statement

8. The information collected under the CSA program application and supporting documents is done in accordance with the authority of section 32 of the Customs Act for the purposes of administering or enforcing the CSA Program. The information will be used to determine the eligibility of an applicant and to conduct compliance reviews (e.g. to ensure that members continue to adhere to program requirements) and may be disclosed internally for the purposes of investigation and enforcement activities relating to program applicants and members. The information may also be used for statistical purposes and program evaluation. Disclosure of the information collected under the CSA program application and supporting documents is governed by section 107 of the Customs Act.

9. In addition to the information outlined in the CSA program application and supporting documents, the CBSA may disclose the business name, address, contact information, business number, membership dates, membership status and business identifiers to other programs within the CBSA and to other government agencies, to confirm membership status, conduct debt checks or carry out the mandate of the CBSA, as applicable, under section 107 of the Act.

10. Individuals have the right of access and/or can make corrections to their personal information under the Privacy Act. The information collected is described within Info Source under the CSA program detailed in the CBSA Info Source Chapter.

Section 1 - CSA Authorization

CSA Eligibility Criteria

11. To participate in the CSA program, the importer must meet the following basic eligibility criteria:

Residency Requirements

12. Pursuant to paragraphs 10.5 2(a) and (b) of the AIGPDR, the importer must have its head office within Canada or the US, or operate a branch office in Canada or the US. Specifically,

13. The Canadian or American business entity maintains separate books and records in relation to the Canadian or American business operations, and prepares separate financial statements; files Canadian income tax returns; maintains and controls bank accounts in Canada or the US; accounts for the imported goods and is responsible for paying the applicable duties and taxes.

CSA Application

14. An application for a CSA authorization is made to the Minister and is comprised of two parts which are to be completed by the importer accurately and completely:

15. Throughout the application process, the CBSA reserves the right to request information in addition to details provided by the importer in Parts I and II of the application.

16. The CBSA will refuse to issue a CSA authorization to any applicant, if it is found that the applicant provided false or misleading information in any part of its application and may assess a penalty of $25,000 CAD.

17. Should the business decide to hire a third party to complete the application process, and/or in any other interactions with the CBSA, they must provide the CBSA with a Third Party Authorization letter signed by an authorized officer (see “Definitions” for details) of the business. The letter of authorization should be printed on the business’ letterhead and should follow the suggested format outlined in Appendix G. The business maintains full liability for all information provided to the CBSA by their representative.

CSA Application - Part I

18. To apply for authorization, the importer must first complete Form E646, Customs Self-Assessment – Importer Application – Part I.

19. Part I of the CSA importer application must be signed by an authorized officer of the company.

20. When completed, the original signed application is submitted to the CBSA:

Courier or in Person:

Customs Self-Assessment
Canada Border Services Agency
1980 Matheson Boulevard East
Mississauga ON  L4W 5R7

Any information submitted by the importer, such as the CSA application information, is subject to the disclosure provisions under section 107 of the Act and the Privacy Act.

21. When Part I of the application is received, a CBSA officer is assigned to the importer. This officer serves as a single point of contact for the CSA program, manages the importer’s application, provides ongoing guidance and assistance, and monitors the importer’s CSA program compliance.

22. During Part I of the application process, the importer should confirm that the business is correctly registered under the Business Number (BN) program. To participate in the CSA program, it is essential that the legal entity is registered under only one nine-digit BN, and divisions or branches of the legal entity involved in the importation of goods are identified with a unique import/export (RM) account identifier. CSA importers are exclusively identified in the CBSA’s automated systems by their 15-digit BN/RM. The CBSA systems will recognize an importer BN/RM as being CSA approved, thus validating the importer authorization for the purposes of the CSA clearance. Additional information about the BN can be found in departmental Memorandum D17-1-5, Registration, Accounting and Payment for Commercial Goods.

23. An importer risk assessment is conducted and includes an examination of the legal business entity, and includes an assessment of compliance with CBSA program legislation, criminal convictions, and outstanding debts to the Crown.

24. The time frame for completion of the CSA risk assessment may vary from case to case, according to a number of factors, such as the corporate structure of the entity and the number of regions in which the importer conducts business.

Part I Approval

25. Importers who pass the Part I application are deemed to be low-risk and are invited to continue to Part II of the CSA application process. This notification is not a final authorization to participate in the CSA program, but permits the importer to proceed to Part II. Final approval for participation is obtained only when Part II of the application process is completed successfully and the Summary of Program Requirements is signed by the approved importer and accepted by the CBSA.

Part I Denial

26. Importers whose Part I application is denied will be notified of the reason for the denial in writing. The letter of notification will be sent to the attention of the authorized person in the business, who signed Part I of the application.

27. An importer who’s Part I application has been denied, may request a review of the decision by submitting a written request, accompanied by any supporting documentation, to:

Attention: CSA Importer Program
Canada Border Services Agency
1980 Matheson Boulevard East
Mississauga ON L4W 5R7

CSA Application - Part II

28. Importers who have received an invitation to continue to Part II of the CSA application must complete Form E655, Customs Self-Assessment Program – Importer Part II Application. Information concerning the completion of Form E655 may also be obtained by contacting their assigned CBSA officer.

29. An authorized officer of the business must sign Form E655 and certify that the information provided is true and complete. When completed, the original signed application is to be submitted to the CBSA office at the address listed in paragraph 20 above.

30. During the Part II application process, the CBSA will ensure that the importer’s business systems allow for the complete and accurate reporting of the trade data for all imported goods. The importer must describe their business systems for the import process, including audit trails and internal controls from source documents to accounting documents. The audit trail includes, but is not limited to:

31. The importer must demonstrate how the following CSA requirements will be met:

32. In Part II, the importer also identifies the CSA accounting option that the importer has selected and the account security number that is pledged. Where the account security number is assigned to a party other than the importer, a letter of authorization from that party must also be submitted as part of the application package. For more information on account security, please refer to paragraphs 144 - 146 of this memorandum.

33. The systems requirements to support CSA requirements do not have to be in place when Part II of the application is submitted, but must in place before the final authorization is granted. The details relating to the specific systems requirements and minimum audit trails are provided in Part II of the CSA application.

34. The evaluation of Part II of the application is performed by the CBSA officer who reviews the importer’s application against the CSA requirements. While the CBSA officer exercises due diligence in reviewing Part II, acceptance of the application does not signify certification of the importer’s business systems, or exempt the importer from being subject to any penalty assessed by the CBSA.

35. The CBSA will visit the importer’s premises to review information and systems descriptions provided in Part II of the application (e.g. tour of the premises, systems walk-through, report generation, etc.).

Multiple Part II Applications

36. While only one Part I application form is to be submitted by the legal entity, the various business divisions that wish to participate separately under the CSA program must each submit a Part II application. Once the legal entity is assessed as a low-risk importer under Part I, the individual divisions may become CSA participants based on their systems readiness or business needs.

37. By allowing more than one application under Part II, business divisions of the legal entity can join the CSA in a graduated manner. Operationally, this means that some divisions may have separate CSA clearance, accounting, revenue summary, remittance and adjustments. Accordingly, the divisions that submit a separate Part II application to be a CSA-approved importer must be clearly defined by a separate 15-digit Business Number (BN).

38. When several divisions submit a single Part II application (e.g. divisions A, B and C), one 15-digit BN/RM must be selected and consistently used to identify that group of divisions. The remaining RM accounts must be cancelled. The one 15-digit BN/RM selected to identify the multiple divisions is used on all clearance, accounting, payment and adjustment documents or transmissions. This also means that concurrent links and audit trails for these divisions must exist in the business books and records to produce a single monthly RSF.

Electronic Requirements

39. The authorized CSA importer is required to provide Form B3 data and X-type adjustments electronically from the importer’s business systems, either directly or through a service provider. Electronic transmission of the RSF is also required. Where the importer’s TCP list is greater than 25, changes to the list must also be transmitted electronically. For more information regarding TCPs, please refer to paragraphs 41 - 43 below.

40. To assist importers in understanding the electronic requirements of the CSA program, importers or service providers can obtain a copy of Chapter 17 of the CSA Electronic Commerce Client Requirement Document (ECCRD) by visiting the CBSA website: www.CBSA.gc.ca. The ECCRD gives an overview of the EDI environment at the CBSA, provides message maps (in Appendix B of the ECCRD), and the implementation methodology associated with the CSA program. The main purpose of the document is to assist CSA participants with their internal implementation.

41. The CBSA does not begin the testing phase of an importer’s electronic transmissions until the importer’s Part II submission is approved. Once the approval is provided, the CBSA officer will forward an EDI survey to the importer to initiate the testing process. The importer must complete the testing process with the CBSA before the final CSA authorization can be provided.

Trade Chain Partners (TCP) Lists

42. Importers who are authorized to participate in the CSA program are required to provide and electronically maintain lists of the following TCPs:

43. The requirement to provide the TCP lists supports ongoing risk assessment. TCP lists submitted by the CSA importer are captured in ACROSS for officers to evaluate the legitimacy of shipments reported under the CSA program; therefore, importers must ensure that the TCP lists remain current. Both additions and deletions must be provided to CBSA.

44. The CBSA reserves the right to conduct a documentation review at the time of report and may request the shipment’s delivery paperwork to compare the actual vendor and consignee with the importer’s TCP list.

Trade Chain Partners (TCP) Loads

45. During Part II of the application process, importers must submit an initial list of their TCPs, including the vendors in the US and Mexico and the consignees in Canada that receive direct-delivery of imported goods. The TCP list must be submitted electronically as per the specifications for the TCP load provided in Appendix C of this memorandum and in the ECCRD. The importer may submit a test file of the TCP list to the CBSA to ensure that the final product is readable.

46. Six weeks before the CSA start date, a complete TCP file must be submitted to the CSA office for loading to the CBSA system. Throughout their participation in the CSA program, the importer is required to ensure that the list is up-to-date by submitting both additions to and deletions from the list. Where there are more than 25 TCPs, the update must be transmitted electronically. The ability to add and delete records electronically from the TCP file is part of the importer’s electronic testing. Failure to provide and maintain the list of vendors and consignees may result in an action plan.

Part II Approval

47. The final approval for participation in the CSA program is obtained when the Technical Commercial Client Unit (TCCU) testing is successfully completed and all other requirements have been met. The importer will then be requested to sign the Summary of Program Requirements letter which is an agreement between the CBSA and the importer. This document summarizes the CSA requirements thereby confirming the importer’s obligations.

Part II Denial

48. Wherever possible, the CBSA will work with the importer to assist in meeting the CSA requirements. However, where it is evident that these requirements cannot be met, a decision may be made to deny the application. Importers who are not approved under Part II of the application are notified of the decision and the reasons for decision, in writing. The letter of notification will be sent to the attention of the authorized signing officer who signed Part II of the application.

In some circumstances, the basis on which the Part II application was not approved may be subject to corrective action on the part of the importer. In these instances, the CBSA may negotiate an action plan with the importer in order to address any issues or concerns relating to the CSA program requirements. Upon implementation of the action plan and once the program requirements have been met, the importer may be reconsidered under Part II. For additional information regarding action plans please refer to paragraphs 251 - 254 below.

49. An importer whose Part II application has been denied may request a review of the decision by submitting a written request, accompanied by any supporting documentation, to:

Attention: CSA Importer Program
Canada Border Services Agency
1980 Matheson Boulevard East
Mississauga ON L4W 5R7

Transfer of CSA Authorization

50. CSA membership can only be transferred after a comprehensive review by the CBSA. The subsequent decision to approve or deny the request will be made at the exclusive discretion of the Agency. Any decision made is final and not subject to appeal.

51. CSA applicants or members that have/will undergo corporate amalgamation or acquisition, will need to contact the CSA Program to have their new corporate structure and program eligibility reviewed in order to be considered for continued participation in the CSA program.

Transition

52. When the CSA importer obtains its CSA authorization, there will be transitional issues to be considered. These issues are summarized in Appendix C. The CBSA officer can also provide additional information.

Updating Importer information

53. CSA importers are required to inform the CBSA of corporate changes that may impact upon their CSA authorization. Details regarding what changes are to be communicated to the CBSA and the timeframe within which they are to be communicated can be found in the Withdrawal, Suspension, Cancellation and Appeals section of this memorandum.

Section 2 - Withdrawal, Suspension, Cancellation and Appeals

Withdrawal

54. Importers wishing to withdraw their application to or participation from the CSA program may do so at any time. To withdraw their application to or participation from the CSA program, importers must inform the CBSA officer assigned to the file, in writing, on business letterhead. The notice must be signed by the authorized signing officer. Once the importer has submitted their intention to withdraw, they will receive written confirmation of the effective date of their withdrawal from the CSA program.

55. An application or CSA authorization that has been withdrawn will not be reinstated and a full reapplication will be required in order to be reconsidered for a CSA authorization.

Suspension

56. The CBSA may suspend a CSA authorization of a CSA importer if:

57. In deciding whether to suspend a CSA authorization, the following factors will be considered:

58. If a decision has been made to suspend a CSA authorization, the importer will be given written notice of the decision and the reasons for the decision. The suspension is not effective until the earlier of either: the day on which the notice is received, or the 15th day after the date on which the notice was sent by mail or courier.

59. Suspension of a CSA authorization will result in an interruption of all program-related benefits including the use of CSA clearance, access to FAST-dedicated lanes, the CSA accounting option, revenue reporting and payment as well as participation in CSA - Platinum.

60. The importer will be given an opportunity to correct the matter that gave rise to the suspension within 30 days after the suspension has taken effect. If it is not possible for the importer to make the required correction within the 30 day period, the importer may make a written request within those 30 days for an extension of time, providing a justification for the extension request. In these instances, the CBSA officer may administer an Action Plan to formally document the matter giving rise to the suspension, recommend a resolution and follow-up until such situations are corrected. For additional information regarding action plans, please refer to paragraphs 251 - 254.

61. After the correction has been made, the CSA importer’s authorization may be reinstated.

Cancellation

62. The CBSA may cancel a CSA authorization of a CSA importer if:

63. In deciding whether to cancel a CSA authorization, the following factors will be considered:

64. Once a decision has been made to cancel a CSA authorization, the importer will be given written notice of the decision and the reasons for the decision. The cancellation is not effective until the earlier of: the day on which the notice is received, or the 15th day after the date on which the notice was sent by mail or courier.

65. Cancellation of a CSA authorization will result in a cessation of all program-related benefits including the use of CSA clearance, access to FAST-dedicated lanes, the CSA accounting option and revenue reporting as well as participation in CSA - Platinum. If the importer’s name appears on the CSA approved importers list on the CBSA’s website, it will be removed.

Appeals

66. An applicant or member that disagrees with a cancellation decision by the CBSA may submit an appeal electronically to: cbsa.trusted_trader-negociants_dignes.asfc@cbsa-asfc.gc.ca

67. In order to be considered, the written submissions must:

68. The importer’s ‘cancelled’ status will remain in effect throughout the duration of the appeal period. No further application processing or administration of the importer’s file will occur until a decision has been rendered.

69. If an appeal to cancel a CSA authorization is allowed, then either the authorization will be reinstated, or the importer will be placed under suspension for a specified duration pending corrective action. Conversely, if an appeal to cancel a CSA authorization is denied, then the cancellation of the CSA authorization will remain in effect. For information relating to the effect of a cancellation of a CSA authorization, please refer to paragraph 64.

70. The CBSA will render a decision and a letter of notification will be sent to the business within 30 business days of receipt of the appeal, not including any period of time in which the application is held in abeyance pending the receipt of requested additional information or response from the business. The letter will state the CBSA’s decision and specify an effective date. All appeal decisions rendered by the CBSA are final.

Reapplication following Denial or Cancellation

71. A moratorium on reapplication following a denial or cancellation decision may be imposed at the discretion of the CSA program depending on the reason(s) for denial or cancellation.

72. The CSA program reserves the right to specify reapplication timeframes on a case-by-case basis, and to disallow reapplication indefinitely when merited.

Section 3 - CSA Clearance

General Overview of CSA Clearance

73. While the obligation to report goods under section 12 of the Act is not altered under the CSA program, the related specific reporting requirements are changed to support the streamlined CSA clearance process. Under CSA clearance, commercial goods are reported to the CBSA at the first point of arrival, where they may be “authorized for delivery” by the CBSA. The CSA-authorized carrier who reports goods to the CBSA for authorization to deliver is liable for the payment of duties and taxes, with this liability transferring to the importer when they are received at the importer’s place of business, or delivered to the owner or consignee, including intermediary locations that have been designated by the importer. Release will occur at these locations and the release date will be the date the goods were received at these locations.

74. Where commercial goods are reported to the CBSA for authorization to deliver under the CSA clearance process the following conditions apply:

75. Under CSA clearance, the CSA carrier typically provides the following CSA data elements at the port of entry which are electronically verified by the CBSA at the Primary Inspection Line (PIL):

Note: Where this information is valid, the carrier may be authorized to deliver the CSA shipment.

76. Detailed information concerning the transportation and reporting of goods using CSA clearance is provided in Memorandum D23-2-1, Customs Self-Assessment Program for Carriers.

CSA-Eligible Goods

77. In the interests of health, safety and security, not all goods imported by a CSA importer are entitled to CSA clearance. CSA-eligible goods are defined under section 2 of the AIGPDR as:

“…commercial goods that have been shipped directly from the United States or Mexico and for which there is no requirement under any Act of Parliament or of the legislature of a province or any regulation made under such an Act that a permit, license or other similar document be provided to the Agency before the goods are released.”

78. CSA-eligible goods also qualify for access to the FAST dedicated lanes provided that both the importer and carrier are either members of PIP or both the CSA and PIP programs, and that the driver is FAST or CDRP-approved.

It is critical for importers to establish routine communication with their shippers and vendors to identify which products are eligible for CSA clearance. These instructions could be a standard part of foreign purchase agreements and contracts, or on a per shipment basis.

79. In turn, it is recommended that shippers and vendors relay this information to the carrier and driver to confirm which shipments qualify for CSA clearance.

80. CSA-eligible goods exclude goods that are a prohibited, controlled or regulated import into Canada, in accordance with the provisions of an Act of Parliament or of the legislature of a province, as well as the regulations made in accordance with any Act that prohibits, controls or regulates their importation, i.e. subject to regulation by OGDs.

81. While most OGD requirements must generally be met before the release of goods, the importer may enter into an agreement with an OGD that allows the importer to provide OGD requirements after importation. Where the CSA importer has made such an agreement, the related goods may qualify for CSA clearance. To obtain more information, importers should contact their CBSA officer.

Place of Shipment

82. To be eligible for CSA clearance, goods must be shipped directly to Canada from within the US or Mexico as noted on the carrier’s through bill of lading. For purposes of determining the eligibility of goods for CSA clearance, the “United States” means the 50 states of the United States, the District of Columbia and Puerto Rico.

83. Goods that enter a US FTZ are also eligible for CSA clearance as long as the goods coming from offshore, have either been stored (in the same condition) or processed in a FTZ. However, goods that simply transit through and are neither held in storage or have further processing are not eligible for CSA clearance.

Authorized to Deliver

84. Under CSA clearance, commercial goods are reported to the CBSA at the first point of arrival, where they may be “authorized for delivery” by the CBSA. A CSA clearance is used to request the “authority to deliver” eligible commercial goods that are imported by an importer who is authorized under the CSA program and are released at the place of business of the importer, owner or consignee of the goods. It is derived from the release prior to accounting provision under paragraph 32(2)(b) of the Act:

(2) In prescribed circumstances and under prescribed conditions, goods may be released prior to the accounting required under subsection (1) if

(b) the goods have been authorized by an officer or by any prescribed means for delivery to, and have been received at, the place of business of the importer, owner or consignee of the goods.

Intermediary locations, as designated by the CSA-approved importer, constitute a consignee. Release will occur at these locations and the release date will be the date the goods were received at the intermediary location.

Meaning of CSA “Release”

85. In the context of a CSA clearance, under section 2 of the Act “release” means;

“(b) in respect of goods to which paragraph 32(2)(b) applies, to receive the goods at the place of business of the importer, owner or consignee;”

This meaning applies to eligible goods that are authorized for delivery to, and have been received at, the place of business of the importer, owner or consignee. Thus, release occurs on the date received.

Interim Accounting Not Required

86. Under CSA clearance, interim accounting is not required. The accounting for goods imported by the CSA importer occurs after the goods are received at the place of business of the importer, owner or consignee. Therefore, the CSA importer is not required to provide a Form CI1, Canada Customs Invoice, or commercial invoice, or B3 referred to in Memorandum D1-4-1, CBSA Invoice Requirements, for clearance or final accounting, except when requested by a border services officer.

Carrier Liability

87. Where goods are reported under CSA clearance for authority to deliver, the carrier is liable for duties and taxes until the goods are  received at the place of business of the importer, owner or consignee, or otherwise discharged under the provisions of subsection 20(2.1) of the Act. Once the goods are received at the place of business of the importer, owner or consignee, liability transfers to the importer and the reporting carrier must ensure that proof of receipt is obtained and kept on hand for CBSA verification.

CSA Clearance Options

88. The service options available to report eligible goods under CSA clearance are:

Clearance Service Option Service Option No.
CSA Highway Paper 00497
CSA Non-highway Paper 00521
CSA EDI Highway Cargo 00984
CSA EDI LTL Conveyance 00976
CSA EDI Rail 00505
CSA EDI 00513
CSA EDI Highway Release 00612

Mandatory Harmonized System Codes (HS Code)

89. CSA importers are generally exempted from the requirement of reporting mandatory HS code, regardless of the clearance option that is used to report imported goods (i.e. CSA or non-CSA clearance). However, where the goods are reported under an electronic service option of other government departments (OGD), CSA importers are required to provide the HS code.

Hand-Carried Goods

90. “Hand-carried goods” (HCG) applicable in all modes is defined as: Goods that will be released after they have been accounted for and all duties with respect to them have been paid under subsection 32(1) of the Act if:

91. Hand-Carried Goods, being imported by or for a CSA importer may be released at the time of importation through presentation of a paper Release on Minimum Documentation (RMD) package provided the following conditions are met:

The requirement for a bar-coded Cargo Control Number (CCN) is not applicable for CSA importer shipments of HCG.

92. Upon presentation of the paper RMD package, the CBSA will assign and apply the required CCN at time of importation. This CCN applied by CBSA is for purposes of system processing only. This CCN will appear on the CBSA electronic notification of release to the CSA importer or customs broker. Please consult Memorandum D17-1-4, Release of Commercial Goods.

Border Verification

93. The CBSA continues to reserve the right to examine shipments and conveyances that enter Canada. Occasionally, the CBSA may refer a CSA shipment for verification activities such as:

Documentation Review

94. Where goods are reported for a CSA clearance, the report is made at the first point of entry into Canada and requires only the presentation of the driver’s CDRP or FAST driver card, and specific bar codes to identify the CSA-approved carrier and importer. Documentation reviews may be performed by the CBSA before CSA goods are authorized for delivery to verify the eligibility of the goods reported under a CSA clearance option. A documentation review is intended to verify whether the goods reported under the CSA program are prohibited, controlled or regulated, whether the goods were shipped to Canada from the United States or from Mexico, whether the goods are imported by an approved importer and are destined for an approved consignee location. Although the carrier is required to have the required commercial documents on hand (e.g. bill of lading, pro-bill), no documentation is presented to the CBSA at the time of report, unless requested by a CBSA officer.

Section 4 - Accounting

95. Under the CSA program, the requirement of sections 32 and 33 of the Act to account for and pay duties on imported goods is unchanged. For clarity, accounting refers to the submission of the Form B3. Where an authorized CSA importer imports commercial goods, the following accounting processes change:

96. All commercial goods imported into Canada by a CSA importer are subject to CSA post-importation processes, such as extended accounting time frames, summary reporting of revenue amounts, payment to a financial institution and automated adjustment, regardless of the clearance option used to report the goods to the CBSA.

97. A fundamental feature of the CSA program is that release records reported under the 15-digit BN/RM of the CSA importer and captured in ACROSS do not require a matching acquittal in the Customs Commercial System (CCS). The acquittal of a clearance transaction with an accounting transaction does not occur because:

Accounting Trigger

98. The term “accounting trigger” refers to the method used by a CSA importer to identify that accounting to the CBSA and payment of applicable duties and taxes are required. For example, non-CSA importers are generally told by the CBSA that goods have been released. This is the “trigger” that initiates the process for accounting and payment. However as the CBSA does not inform the CSA importer, an accounting must be triggered from the importer’s own business systems when imported goods are entered into the importer’s books and records.

99. The recommended method for CSA importers to trigger accounting is the reconciliation process used in business to authorize payment. Generally, payment is not authorized until the corresponding purchase order, receiving report and vendor’s commercial invoice are compared to verify which goods were received, the vendor’s identity, the price payable and the quantity received. A match of the details from these three files, with appropriate adjustments and allowances, results in the transaction being ready for payment.

100. Transmission of B3 accounting data by the CSA importer is expected to occur when the three-way match of the goods, the quantity received and the invoice value have been reconciled. The accounting time frames are extended for goods imported by a CSA importer to allow for this internal reconciliation process. Where a three-way match does not occur before accounting is due, a similar process, such as a two-way match of the purchase order and the receiving record, may be used; and adjustment filed, if required, when the invoice is received.

Systems Sweep

101. The business reconciliation process models a typical method from which accounting to the CBSA can be triggered. However, two considerations affect the reliability of this trigger:

102. CSA importers need to examine their systems and processes to ensure that all importations are accounted for to the CBSA in the required time period. A systems sweep should be developed for importers to identify unmatched orders, receipts, invoices and importations that could fall outside the reconciliation process. In performing the sweep, importers should also ensure that all the goods that have been imported have been accounted for to the CBSA and potential adjustments have been identified.

CSA Release Date

103. Under the CSA program, accounting and payment periods are determined by the release date. The meaning of release under section 2 of the Act in respect of goods to which paragraph 32(2)(b) applies, to receive the goods at the place of business of the importer, owner or consignee.

104. The date of release/receipt is used to establish the accounting and payment periods for all goods imported by the CSA importer. Goods not eligible for CSA clearance must be reported to the CBSA for a “release” decision, at which time liability for duties on the goods is transferred from the carrier to the importer. Goods eligible for CSA clearance are reported to the CBSA for an “authorization for delivery” to the place of business of the importer, owner or consignee; and when the goods are received, liability for duties on the goods is transferred from the carrier to the importer.

105. A key requirement for CSA importers is to ensure that their business systems can record and track the date on which imported goods are received. In addition, the date of release/receipt identified by importers from their business systems must not be later than the date that the imported goods are physically received at the place of business of the importer, owner or consignee.

Alternative Release Date

106. In some situations, such as goods shipped directly from the vendor to a Canadian consignee (direct shipment), the CSA importer may not know the date of physical receipt at the consignee’s place of business. To resolve such a situation, the importer may select an alternative date to identify the date of release. For example, if goods shipped directly by a specific vendor to a consignee in Canada are typically released by the CBSA four days after shipment, then the release date could be calculated as the shipping date plus four. In this example, if the vendor ships goods on April 25 the alternative release date calculated by the importer will be April 25 + 4 = April 29.

Note: The release date cannot be later than the transmission date of the B3.

107. The calculation and rationale of receipt date and/or alternative release date must be submitted by the importer with Part II of the CSA application and be approved by the CBSA. Given that the number of days between shipping and typical CBSA release could vary for different vendor-consignee contracts, the importer may have to provide a rationale for more than one receipt date or alternative release date for the CSA.

108. The release/receipt date applied to goods imported by the CSA importer is to mirror the date of a CBSA release decision.

109. The date of release/receipt or alternative date of release, identified by the CSA importer is the date used to determine the time frames for accounting to the CBSA and is transmitted by importers to the CBSA as the release date on their B3. Where importers choose to consolidate their accounting, the time frames for accounting to the CBSA will be based on the earliest release/receipt date in the consolidation.

Accounting and Payment

110. “Accounting” is different from “payment”. Accounting is the provision of B3 data. The accounting options (Option 1 or Option 2) under the CSA define the accounting time frames. Regardless of the accounting option selected by the importer, the payment to the Receiver General for Canada is payable by the last business day of the month for all goods released/received between the 19th of one month and the 18th of the following month. While the accounting time frame can vary between CSA importers, the payment period is identical for all CSA importers (see below).

CSA Accounting Options – High Value Shipments (HVS)

111. In the CSA environment, all commercial goods with a value for duty exceeding $3,300 CAD are accounted for to the CBSA within one of two accounting time frames, regardless of the CSA clearance or release option that was used to report the goods. A table comparing the similarities and differences of the two CSA accounting options and the accounting requirements of a non-CSA importer is provided in Appendix D of this memorandum. The CSA accounting options are:

Note: Goods cannot be accounted for before the date of release/receipt.

112. CSA importers must select one of the two accounting options before their CSA start date and must not change the selected option during their participation in the CSA program.

CSA Accounting Options – Low Value Shipments (LVS)

113. Imported commercial goods that have a value for duty of $3,300 CAD or less must be accounted for by the 24th day of the month following the month in which the goods were released/received. Alternatively, CSA importers may choose to use the same accounting option selected for their high value shipments (i.e. Option 1 or Option 2). More details on accounting options for low value shipments can be found in Appendix E of this memorandum.

Note: Goods cannot be accounted for before the date of release/receipt.

114. In keeping with the Courier Imports Remission Order, commercial goods imported by a CSA importer with a value for duty not exceeding $20 CAD do not have to be accounted for to the CBSA. However, the importer must maintain documentation to support the applicability of the remission. Note the remission is not granted:

Payment Period

115. Duties owing on high value commercial goods released/received from the 19th of one month (month one) to the 18th of the following month (month two) must be paid no later than the last business day of month two.

Note: The payment period is the same regardless of the accounting option selected.

116. For commercial goods released/received in a particular month that have a value for duty of $3,300 CAD or less, duties must be paid by the last business day of the following month, regardless of the accounting option selected.

Interim Payment

117. An interim payment of duties may sometimes be required to avoid incurring late payment interest. This is due to the difference in the accounting and payment time frames. The actual amount of duties and taxes owing on imported goods is not known until they are accounted for to the CBSA. In situations where payment of duties and taxes is due before accounting is completed, an interim payment may be made to avoid late-payment interest. For example, a CSA importer may not know the actual amount of duties and taxes owing for some goods released/received during the payment period so the importer may choose to make an interim payment for those goods.

Late Accounting

118. In accordance with section 109.1 of the Act, where the importer fails to transmit accepted accounting data within the prescribed time limits, a late accounting penalty may apply. CSA importers are required to account for imported goods within the time limits of the CSA accounting option they select, or late accounting penalties may be assessed.

How to Identify if CSA Accounting is Late

119. When an error-free accounting transmission is received by the CBSA systems, an “entry acceptance date” message is returned to the importer or broker who has transmitted the information. Where the entry acceptance date occurs after the accounting due date (based on the accounting option selected), the accounting is late.

120. Under the CSA, the importer is not notified by the CBSA of late accounting through the outstanding Transaction Status Client Report or DN/SOA. Instead, the importer is notified of instances of late accounting by the issuance of a Notice of Penalty Assessment (NPA), from the Administrative Monetary Penalty System (AMPS).

121. Late accounting for goods imported by the CSA importer is determined by the accounting option they have selected.

CSA Late Accounting Penalties

122. There are two late accounting penalties that may apply to the CSA Importer: AMP C244 and C246.

123. AMP C244 is a zero-rated penalty that is used by the CBSA to monitor the total number of late HVS B3s that occurred in a calendar year ( to ). This penalty is generated by the system each time a HVS transaction is late. AMP C244 allows the CBSA to calculate the compliance rate in the calendar year. Should the CSA Importer fail to maintain a minimum compliance level of 95% in accounting for released goods in the prescribed manner or within the prescribed or time limit in a calendar year, the Importer will be assessed AMP C246.

124. AMP C246 is assessed for each HVS late transaction below the minimum compliance level of 95 percent, at the rate of $100 CAD per transaction. The transactions are monitored and the AMP is manually calculated by the importer’s assigned CBSA officer.

Systems Outages

125. CSA importers should notify their assigned CBSA officer should they experience difficulties in transmitting their RSF within the prescribed timeframes during an outage in order to waive any applicable penalties for late transmission of the RSF. For more information regarding systems outages, please refer to the CBSA website.

Records

126. The CSA importer is required to keep all records related to the commercial goods released/received for a period of six years (plus current) following importation of the goods, including information about:

CSA B3 Information

127. B3 information continues to be submitted to the CBSA by the authorized CSA importer. However, there are some changes to the accounting process under the CSA program, for example:

Transaction Number

128. There is no link between ACROSS release records and the CCS entry sub-system for a CSA importer’s goods. Release and clearance decisions concerning commercial goods reported under the 15-digit BN/RM of an approved CSA importer are automatically acquitted in ACROSS. The system does not require a matching accounting transaction through CCS.

129. Where a transaction number is required, it cannot be duplicated for seven years and three months.

130. Since the systems acquittal of clearance records with accounting transmissions is not required, the CSA importer must maintain appropriate audit trails between imported goods released/received and accounted for. Failure of the CSA importer to maintain the required audit trails may result in the assessment of a penalty.

B3 Coding Changes

131. Coding of the B3 fields is unchanged for CSA, except for:

132. CSA importers continue to use all existing B3 entry types to report accounting data to the CBSA. There is no unique B3 entry type for CSA importers, other than the X‑type, used for adjustments (see Section 6 of this memorandum).

133. When transmitting a multiple-line B3, the CSA importer does not have to provide a cross-reference between the invoice and the B3 line with the electronic CADEX or UN/EDIFACT accounting transmission. To comply with the CADEX message map, input page one, line one.

Statistics Canada Data Elements

134. Where the importer uses CSA clearance, a cargo control document is not required for the report of goods. Therefore, information such as the elements listed below may not be readily available to the CSA importer for the accounting of the goods. Collection of this data, however, remains a requirement to sustain Canada’s obligation under a Memorandum of Understanding with the US Census Bureau. Therefore, in the design of their business processes for CSA, importers need to establish a method to provide the following B3 data elements:

135. CSA importers can continue to transmit actual data in these fields. However, they may present this information in a similar fashion as freight charges (Field 19):

Consolidated B3

136. Under the CSA program, there is an opportunity to consolidate accounting data transmissions to a certain degree. Most B3 header, sub-header, and line information will be required as described in Memorandum D17‑1‑10, Coding of Customs Accounting Documents, but where fields such as the vendor name and classification number are the same, the importer can also choose to consolidate according to the following conditions:

137. Although the option to consolidate B3 data is available to CSA importers, they are not obligated to do this, and may continue to transmit on a shipment-by-shipment basis, for example, for importations of goods that are subject to “within access” commitment tariff items.

Changing the CSA Business Number

138. Where an incorrect BN is used to clear commercial goods and final accounting has not yet been accepted, the importer/broker is to request the BN change by submitting Form A48, R.M.D. Correction, to the office of release. In addition, the acquittal status of the transaction must be updated in ACROSS as follows:

Documentation Upon Request

139. A feature of the CSA program is to minimize requirements related to supporting documentation for reporting, accounting and adjustment of imported goods, except when requested by a CBSA officer. As discussed in Section 2 of this memorandum, the carrier may report goods for authorization to deliver by simply providing the required bar-code information. Further, given that the CSA importer is not required to provide interim accounting, the reporting and accounting for goods that are authorized for delivery could be paperless. Bar codes are presented to effect authorization for delivery and CADEX or UN/EDIFACT transmission is provided to account for the goods.

140. The CSA importer is not required to provide invoice information as described in Memorandum D1-4-1, CBSA Invoice Requirements, but must do so on the request of a CBSA officer. An AMP may be assessed when the importer fails to provide information requested by a CBSA officer. While the requirement to submit supporting documentation for report, accounting or adjustment is reduced, the CSA importer must have audit trails between source documents, the accounting for goods, adjustments to original accounting information and revenue amounts.

Role of the Agent

141. A broker or agent may transact business with the CBSA on behalf of an importer or owner, provided that the broker/agent has been authorized to do so. Additional information concerning the authority to act as an agent is provided in Memorandum D1-6-1, Authority to Act as Agent.

142. In the CSA environment, although it is the responsibility of the CSA importer to identify the requirement for accounting of imported goods to trigger accounting, the importer may appoint a broker/agent to complete and transmit the related accounting (B3) information to the CBSA. Further, where such services are offered, a broker/agent may be appointed on behalf of the CSA importer to prepare and transmit the RSF, TCP information and automated X-type adjustments. The CSA importer may also use a broker/agent to prepare and submit documents required at the time of report, for example, when a non-CSA service option is used (e.g. Pre-Arrival Release System (PARS) or RMD).

Account Security

143. Shipments imported into Canada by a CSA importer are subject to the security provisions described in section 35 of the Act for release before payment privileges. Where more than one account security number is used for release and accounting, the CSA importer must ensure that all corresponding revenue amounts are reported on a single monthly RSF (E648). Procedures for the importer or broker to post security are described in Memorandum D17-1-5, Registration, Accounting and Payment for Commercial Goods.

144. Where goods are released before payment under the provision of paragraph 32(2)(b) of the Act and authorized for delivery, the CSA importer becomes liable for payment of duties when the goods are received at the place of business of the CSA importer, owner or consignee.

145. The CSA importer pledges security on Part II of the application. Where the account security of a broker is pledged, written authorization from the broker must accompany Part II of the importer’s application. The pledged account security number may be changed only in consultation with the CBSA.

Section 5 - Revenue Reporting

Revenue Summary Form (RSF)

146. Authorized CSA importers are responsible for the self-assessment and reporting of most CBSA-related revenues. The DN and SOA are eliminated in the CSA environment. While the CSA importer continues to transmit B3 accounting data, the related revenue amounts are not generated on the DN and SOA. Instead, the CSA importer self-assesses and summarizes revenue amounts. The summarized amounts are reported by financial line object code on a single monthly report called an RSF. Line object codes may be found in Appendix E.

147. Although the RSF is transmitted electronically as outlined in the ECCRD, a sample of the RSF is available on the CBSA website.

148. The RSF is used to report revenue payable in respect of the importation of commercial goods by the CSA importer. This report includes the amounts related to the accounting for goods, adjustments, refunds, drawback, interest, penalties and other CBSA assessments. Importers should ensure that all transactions have been accepted by the CBSA before including corresponding revenue amounts on the RSF. The RSF is used to report both:

149. Both the importer name and 15-digit BN/RM are completed on the RSF to identify the specific CSA importer for which revenue amounts are being reported. Where a business division or a group of divisions have submitted separate Part II applications to participate in the CSA program, separate RSFs are prepared using the 15-digit BN/RM.

150. Only one monthly RSF is prepared for the CSA importer. Therefore, where more than one account security number has been used for release and accounting purposes, the importer must ensure that the related revenue amounts are included on the single monthly RSF.

151. The CSA importer must submit an RSF to the CBSA each calendar month and make payment of the respective amount reported on the RSF at a financial institution. Both the RSF transmitted to the CBSA and remittance at the financial institution, are required on or before the last business day of the month. The RSF month is the month in which the respective payment is made. For example, amounts reported on the “June RSF” must be paid by the last business day of June. Total amounts paid at the importer’s financial institution during a month must agree with the total payment amount reported on that month’s RSF.

152. The period start and end dates should reflect activity captured on that month’s RSF. The period start and end dates reported on the RSF may change from month to month to accommodate the business cycles of the CSA importer. The period end date reported on the current month RSF should reflect the last day that B3 records, for which the respective revenue amounts are reported on that RSF, are transmitted to the CBSA and received in accepted status.

153. However, the period start date of one RSF cannot be earlier than the period end date of the previous RSF. Therefore, the CSA importer may choose to default to the start and end dates of the payment period in these fields (see “Payment Period” in paragraphs 116-117 for more details).

154. If the first RSF the Importer transmits in the CSA environment is NIL, the period dates of that first NIL RSF must be earlier than the CSA participation start date. See “Reporting a NIL/Credit RSF” below in paragraph 184 for more details. Note the period start date of the first RSF with data (i.e. not nil) must not be earlier than the CSA participation start date.

155. The value for duty (VFD) of current-month transactions includes both original and adjusted B3 accounting data for which related revenue amounts are included on that RSF. The VFD in the RSF includes both B3 and X type revenue. This amount in the header of the RSF is to be rounded to the nearest dollar, without cents or decimals.

156. A field on the RSF described as “Filing ID” is used when a third party prepares the RSF on behalf of the CSA importer and is completed with the five-digit account security number of that third party.

Submitting the RSF

157. A single monthly RSF is prepared for each CSA importer and must be provided to the CBSA, in electronic format, on or before the last business day of the month.

158. Where a complete and error-free RSF is not received by the last business day of the month, a penalty will be assessed against the importer for failure to provide the RSF to the CBSA within the prescribed time. Note that the penalty assessed for failure to provide an RSF within the specified time frame is unique to the CSA and is separate from late accounting and late payment penalties.

Amounts Reported on the RSF

159. The CSA importer is generally responsible for self-assessing and calculating amounts for reporting on the RSF. Amounts owing to the CBSA are reported on the RSF as debits and amounts due to the importer are reported as credits. The credit amounts offset the debit amounts and the remaining balance is payable at a financial institution.

RSF (CAD)
Debits Credits
$10  
$100 $60
$40  
Total payable   $90

160. Subsection 74(8) of the Act allows CSA importers to apply, within four years from the date of accounting, the amount of a refund to which they are entitled, to the payment of an amount for which they are liable under the Act. This provision provides for the self-assessment of refund amounts on the RSF and, as a result, the CBSA does not issue refund cheques to CSA importers.

161. Unlike the DN/SOA, individual transaction numbers transmitted to the CBSA during the RSF period are not reported on the RSF. Instead, revenue amounts are totaled and reported on the RSF by line object code. For example, all duty payable for the accounting of goods during the RSF period is added and reported as a single amount. Similarly, other revenue amounts, both debits and credits, are added by line object code.

162. While transaction numbers are not listed on the RSF, the CSA importer must have the internal controls and audit trails in place for audit purposes to retain the details of the transaction number, dates, VFD and corresponding revenue amounts electronically. Audit trails must also include source documents in relation to the receipt and payment for the goods, CBSA accounting, adjustments, revenue reporting and payment of duties and taxes.

163. In accordance with provisions of the Customs Act, the Excise Tax Act and the Customs Tariff, amounts paid as goods and services tax (GST) at the time of accounting are generally not refunded. These amounts are recovered through an importer’s GST input tax credit. Accordingly, GST amounts are not included as a credit on the RSF.

164. An exception to reporting GST as a credit on the RSF is where a clerical error related to the amount of GST reported on a B3 is corrected within the same RSF month. In this situation, the importer transmits an X-type adjustment within the same period to adjust the GST. When the adjustment is accepted, the amount of GST may be reported as a credit on the RSF against line object code 49129 (GST – credit for current month corrections only). The amount of GST reported on the original B3 is also reported on the debit side of the same RSF against line object code 49121.

Other Assessments – Customs Assessments

165. In addition to amounts self-assessed by the CSA importer, the RSF is used to report revenue amounts assessed by the CBSA, such as the following:

166. The customs assessment section on the RSF is used to report the amount assessed, assessment type, corresponding reference number and port code of the CBSA office that issued the assessment.

167. While most CBSA assessment amounts are reported in the customs assessments section on the RSF, an exception is the report of amounts assessed on a CBSA-initiated adjustment (form B2-1). In this case, the revenue is reported in the following manner:

Other Assessments – Interim Payments

168. Where the CSA importer chooses to make an interim payment of duties and taxes to avoid late-payment interest, the interim payment is reported on the RSF. The interim payment, an estimate of duties and taxes owing, is reported month one. The actual amount, once calculated, is reported the following month.

169. To avoid possible double payment, the interim payment is reported as a debit in the first month in the Interim Payments section of the RSF, and is reported as a credit in the “credits” section of the RSF in the second month. The credit amount of the second month cancels out the debit amount from the first month (the credit amount in the second month must exactly match the debit amount from the first month). Actual amounts payable are then reported as part of the regular duty and taxes owing in the “debits” section of the second month.

170. GST is not refunded by the CBSA. The report of a GST interim payment as a “credit” on the second month RSF is permitted only because the amount does not represent a refund, but is an offset against the actual amount paid on the same RSF. This situation applies only to the interim payment.

171. The examples below are provided to show reporting of interim and actual amounts on the RSF.

Example 1The interim and actual amounts are equal. Interim duty and GST are reported as a debit on the May RSF and the same amount is reported as a credit on the RSF for the second month (i.e. June). The actual amount of duty and GST calculated is reported in June in the respective fields for duty and taxes payable.

Example 2The interim amount is overestimated. Interim duty and GST are reported as a debit on the May RSF and the same amount is reported as a credit on the RSF for the second month (i.e. June). The actual amount of duty and GST calculated is reported in June in the respective fields for duty and taxes.

Note: credit interest is not calculated on duties and taxes overestimated.

Example 3The interim amount is underestimated. Interim duty and GST are reported as a debit on the May RSF and the same amount is reported as a credit on the RSF for the second month (i.e. June). The actual amount of duty and GST calculated is reported in June in the respective fields for duty and taxes. In addition, interest payable on the amounts of the duty and GST underestimated is reported as a debit on the June RSF. In this example, interest is payable on $300 CAD ($100 CAD duty and $200 CAD GST) which represents the amount underestimated in the interim payment.

Interest

172. In most situations, interest payable to, or owed by, the CSA importer under provisions of the Customs Act, Customs Tariff, Special Import Measures Act (SIMA) and regulations made under those acts, is self-assessed, calculated by the CSA importer and reported on the RSF. Situations where interest may apply include interest on the reconciled interim payment, late transaction payment interest, interest on adjustments, and interest for late payment of the RSF. Generally, interest is payable beginning the first day after the person becomes liable to pay the amount and ends on the day the amount is paid in full. For information about the application and calculation of interest, refer to the following memoranda:

Interest is calculated on a compounded daily basis. There are two interest rates applied in accordance with the Customs Act and the Customs Tariff, depending on the nature of the situation:

Interest rates can be found on the CSBA website.

173. To calculate interest, the date of payment or duty paid date is the date of remittance to a financial institution, not the date on which the related RSF is transmitted to the CBSA.

174. Interest resulting from the underpayment of an interim payment, late transaction payment and late payment of the RSF is calculated at the specified rate. Interest on adjustments is calculated at the prescribed rate.

Interest on Adjustments

175. Interest payable to or owed by the CSA importer that results from an adjustment is reported on the RSF as a credit or debit. This includes interest related to self-adjustments, re-determinations, further re-determinations, and duties relief provisions.

176. Where the adjustment to an original accounting declaration of the CSA importer is submitted using the X‑type automated entry, the decision date is the date of the respective entry-acceptance message. Where the adjustment is submitted on Form B2, the decision date is the date of the respective DAS.

177. Section 80 of the Act stipulates that interest granted as the result of a refund applies only on the 91st day after the day an application for the refund is received by the CBSA. However, for a CSA importer, this should rarely occur because the importer does not have to wait for a cheque to be issued from the CBSA. Instead, the importer reports the refund amount on the RSF in the same month that the X‑type entry is accepted in CCS.

Late Payment Interest Amounts

178. In accordance with subsection 33.4(1) of the Act, late-payment interest is payable when duties and taxes are not paid by the due date. Late-payment interest will not be automatically calculated by the CBSA. Where a payment of duties and taxes is late, the respective interest amount is to be self-assessed and reported on the importer’s RSF.

179. The amount of late-payment interest assessed by the CSA importer is calculated using the specified rate, on the amount of the outstanding balance, for the period beginning on the date after payment was due to the date payment is made. The date of payment is identified by the date on which the importer’s designated financial institution received the related CSA remittance.

180. The due date for payment of duties by the CSA importer is determined by the date the imported goods are released/received at the place of business of the importer, owner or consignee. Payment of duties and taxes for high value shipments released/ received by a CSA importer between the 19th of one month and the 18th of the next month is due on the last business day of that second month.

Waiver of Interest

181. In the following circumstances, the interest amount related to goods imported by the CSA importer may be waived and does not have to be reported on the RSF.

Note:  All calculations that relate to the interest amount must be made to determine if the waiver applies. The importer is to retain records to support the calculation.

Exceptions to RSF Reporting

182. Generally, the CSA importer reports all CBSA-related revenue amounts on their monthly RSF. The exception to reporting CBSA assessments on the RSF is where payment must be made without delay rather than at month end. The following exceptions must be paid at a local CBSA office without delay:

Reporting a NIL/Credit RSF

183. The requirement to submit or transmit a monthly RSF is mandatory even in circumstances where the net amount is zero or there is a credit amount due to the importer. A NIL report for the section called “Debits” is accomplished by reporting “0” for VFD current month transactions, Duty‑49010 (original transactions) and GST-49121 (original transactions). The other RSF sections remain optional if the “Debits” section is NIL. A credit amount may be carried over to the RSF of the following month.

Changes to the RSF

184. Only one RSF for each CSA importer (as identified on Part II of the CSA application) is to be on file with the CBSA for any given month. Once sent, an RSF cannot be deleted, rather, it can only be changed. Where a change is required to RSF information previously submitted to the CBSA, a replacement RSF, complete with all applicable data elements, must be presented or transmitted.

185. Where changes are made to revenue amounts reported on the original RSF, importers must adjust their payments appropriately and notify their assigned CBSA officer. A fundamental rule in the change process is that the amount payable reported on the RSF must match the total amount of payments remitted for the same RSF period.

Payments at Financial Institution Prior to Due Date

186. The CSA importer is allowed only one RSF on file with the CBSA for each calendar month. The RSF amount must be paid at a financial institution on or before the last business day of the same month. Where CSA importers might incur additional interest charges on amounts owing before the RSF is submitted and paid, they may make supplementary payments at their financial institution before month end. Where more than one payment is made toward an RSF, the sum of the payments is expected to equal the final RSF total, and must be received at the financial institution by the last business day of the month.

RSF Total Payment = Total Remittance(s) to Financial Institution

187. In some instances, clerical or calculation errors might result in an amount payable reported on the monthly RSF that is different from the actual amount paid at a financial institution. In these instances the CSA importer should contact their assigned CBSA officer for guidance on how to correct the error.

Remittance at a Financial Institution

188. Under the CSA program, revenue amounts owing to or by the CSA importer are reported to the CBSA once a month on the RSF and the total amount payable reported on the RSF is remitted at a financial institution. The date of remittance at the financial institution is the duty-paid date for the goods. The financial institutions where the RSF amount may be paid are described in section 3.5 of the Act, which provides authorization for payment at:

189. Payment of the total amount payable reported on the RSF shall be made at a financial institution operating in Canada, by using form BSF645, Customs Self-Assessment – Remittance Voucher - CSA. The vouchers are printed by the CBSA with the importer’s BN and address. These vouchers can be obtained through the importer’s assigned CBSA officer.

Note:  The original vouchers provided by the CBSA officer must be used because the ink or toner must be magnetized. Specifications for electronic transmission of the remittance are negotiated between importers and their financial institutions.

ePayment

190. ePayment will provide an alternative to in-person payments at the bank. CSA importers are able to make electronic payments via EDI or online banking through participating Canadian financial institutions. For more information regarding ePayment, please contact your CBSA officer.

Summary of CSA Revenue Reporting and Remittance Process

191. To summarize the CSA revenue reporting and remittance process:

192. In some situations, importers may make more than one CSA remittance at their designated financial institutions during a single RSF period. Multiple remittances are not to be made for day-to-day payment of duties and taxes. The intent of permitting more than one remittance is to offer the importer a way of paying amounts that are subject to interest and have a due date before the RSF payment is made at a financial institution. Examples of such situations are payment of a penalty or a Detailed Adjustment Statement (DAS) that is issued by the CBSA. While multiple remittances may be made at the importer’s financial institution, only one RSF can be on record with the CBSA for the month.

193. The total amount of the remittances made at a financial institution must equal the “Total Payment” amount reported on the RSF. When more than one remittance is made during the month, the amounts of the multiple remittances paid during the RSF period must add up to the total payment amount that is reported on the RSF.

194. A CSA importer may choose to submit the RSF and payment before the last business day of the month, depending on the importer’s business cycle. In addition, the importer may choose to prepare and submit the RSF before making the payment. For example, the importer may submit the RSF on June 25 but make the payment on June 30. An importer who discovers that the amount reported on the June 25 RSF is incorrect before making the June 30 payment must provide a corrected RSF to the CBSA by June 30 to replace the June 25 RSF.

CSA Accounting and Payment Periods

195. The following are the accounting and payment periods for a CSA importer:

Section 6 – Adjustments

General Process Requirements

196. Corrections to original accounting declarations using the X-type entry are to be transmitted using existing CADEX records. Detailed information about the X-type B3, electronic formats are located in Appendix C of the CSA ECCRD.

197. Where a correction is made to an original accounting declaration, the importer is required to maintain an audit trail among the adjustment, source documents and the commercial books and records related to the importation.

X-type Adjustment Methods

198. The X-type entry can be used to correct original accounting information using either one of two methods:

Note:  The X-type transaction will never appear in the paper format. Negative values, along with all the other numbered fields, are actually transmitted, using specific CADEX record types that are provided in the CSA importer ECCRD.

Amounts, including interest, owed to or by the CSA importer as the result of an adjustment, are reported on the importer’s RSF. Duties, GST and interest due to the CBSA are reported as a debit against the respective line object code. Duties and interest due to the importer are reported on the RSF as a credit against the respective line object code.

Automated “X” Type Adjustment

199. In the CSA environment, self-adjustments to original accounting information and refund claims are submitted to the CBSA electronically. The format of the automated self-adjustment is similar to a B3 and is identified as an X-type.

200. Transmission of the X-type adjustment to the CBSA is through CADEX or UN/EDIFACT version 99B and is supported through CCS. Requirements of the electronic transmission of the X-type entry are detailed in the CSA ECCRD.

201. In the X-type transmission, negative values are used to remove original accounting information; positive values are used to replace the information. Changes may be made on a net basis, i.e. only adjusting the incorrect portion. Alternatively, changes can be made by removing the entire line that was in error, and replacing it with the correct data; either method is equally valid. The term “negative value” and the negative sign are used only to illustrate the concept of the X-type adjustment. When these values are actually transmitted to the CBSA, the appropriate coding specified in the ECCRD is used.

202. The X-type entry is used to self-adjust both corrections submitted under Section 32.2 of the Act and applications for refund submitted under subsection 74(1) of the Act. However, adjustments under Section 32.2 must not be combined with adjustments under Section 74(1) on the same X-type, i.e. adjustments resulting in a refund cannot be combined with adjustments resulting in an amount payable to the CBSA. For more information on adjustments, see Memorandum D11-6-6, “Reason to Believe” and Self-Adjustments to Declarations of Origin, Tariff Classification, and Value for Duty. The X-type adjustment may also be used to self-assess and account for SIMA duties.

203. Exceptions to the electronic submission process (X‑type entry) are:

204. The use of the automated X-type entry to transmit an adjustment of accounting information does not change legislative provisions that relate to the requirement to correct accounting information, or the authorities for and time limits of self-adjustments, re-determinations, further re-determinations, and refunds. Like non-CSA importers, CSA importers are expected to submit corrections, regardless of the value for duty. However, there are some changes in the CSA adjustment process, such as:

Revenue Impact Reported on RSF

205. The CSA importer reports all revenue impacts that result from the filing of an adjustment on the RSF regardless of the manner of or reason for filing – X-type entry or paper B2. Additional duties, taxes and interest owing to the CBSA are reported as a debit on the RSF and payment is remitted at a financial institution. Duties payable to the importer are reported as a credit on the RSF and CBSA will normally not issue cheques for amounts owing to the CSA importer. Given that GST is excluded from refunds made under CBSA legislation, GST amounts are not recorded as a credit. Importers who are eligible for a refund of GST should contact the Canada Revenue Agency tax services office nearest them for information about benefits available under the input tax credit system.

206. The amounts of additional duties and taxes owing or duties refunded are not to be reported on the RSF until the importer receives the notice of re-determination in keeping with the following guidelines:

207. In accordance with the Customs Accounting Document Error Remission Order, remission is granted when the amount of a bona fide error on any one CBSA accounting document results in an underpayment of an amount not more than $7.50 CAD. When an adjustment of a single accounting document results in an amount owing of $7.50 CAD or less, the CSA importer may take consideration of this remission and need not report the amount as a debit on the RSF. As with other revenue amounts substantiation of the amount is to be retained by the importer. Information about the Customs Accounting Document Error Remission Order is provided in Memorandum D17-1-9, Remission of Underpayment Due to Customs Entry Error.

208. In accordance with subsection 3.3(1) of the Act and section 125 of the Customs Tariff, where the importer submits an adjustment and interest on the duties and taxes, and penalties are less than $5 CAD, the interest is waived. In this case, the CSA importer is not required to report the interest waived on the RSF. However, all calculations that relate to the interest amount must be made to determine if the waiver applies. The importer is to retain records to support the calculation.

Notice of Decision

209. During traditional B2 adjustment processing, an automated DAS is generated as notice to the importer of the CBSA’s decision and to inform the importer of the right to appeal. However, where an X-type automated adjustment is processed, a DAS is not generated. Instead, the entry-acceptance message generated by CCS provides the notice of decision required by subsection 59(2) of the Act or section 60.1 of SIMA.

210. Where the CSA importer transmits an X-type adjustment, the date of the entry-acceptance message shall be used:

Completion of the “X” Type Entry

211. While the X-type automated adjustment is similar to a B3 transmission, there are some significant differences, as described in the CSA ECCRD, including the transmission of negative amounts and the completion of certain fields. The following codes are unique to the X- type entry transmission to accommodate the automated adjustment process:

212. The CSA importer is required to maintain the appropriate records and audit trails that relate to the accounting and subsequent adjustment of goods, revenue reporting and payment.

Supporting Documentation

213. It is not necessary to provide supporting documentation at the time of the automated adjustment. However, in accordance with section 40 of the Act, the importer is required to maintain the appropriate records on file and make them available to the CBSA when requested.

214. CSA participants are required to maintain audit trails from the adjustment transaction to the source document that triggered the need for the change and from the adjustment transaction to the RSF that included the adjusted revenue.

215. Where the CSA importer fails to make information relating to imported goods available to the CBSA when requested, a penalty may be assessed. In addition, there is a specific SIMA-related penalty that may be assessed when the CSA importer fails to provide the detailed product description for a particular import when requested. A contravention may be assessed where the importer fails to respond to a written request.

Consolidated Adjustments

216. An automated X-type adjustment may be submitted to adjust a single transaction or, alternatively, to adjust several transactions as a consolidated adjustment. Consolidated adjustments are those adjustments that cover more than one shipment.

217. Where a consolidated X-type adjustment transmission is used, the adjustment does not have to be directly associated with specific CBSA accounting transactions; however, the goods related to the adjustment must have been accounted to the CBSA and duty paid within the same calendar year (i.e., from January 1 to December 31). The X-type adjustment is not necessarily adjusting individual B3 information, but may be used to adjust blocks of accounting data, within legislated time frames. For example, where a correction to the tariff classification of goods imported within the year is required, each individual B3 does not have to be corrected. Instead, one X-type may be transmitted to deduct the total value of goods from the incorrect classification number and that value of goods added to the correct classification.

218. While the consolidated adjustment may be used to adjust accounting information over a period of up to one year, the CSA importer is still required to file a self-adjustment, request for re-determination, further re-determination or refund within the legislated time limits. For example, in accordance with section 32.2 of the Act, the CSA importer is required to correct a declaration of origin, tariff classification, and value for duty within 90 days of the date the importer has reason to believe that the original declaration is incorrect.

219. The following provides an illustration of the automated adjustment process for a consolidated adjustment transmission:

B3 Number Tariff Classification Value for Duty (CAD)
1 1234.56.78.90 $1,000
2 1234.56.78.90 $5,000
3 1234.56.78.90 $3,000

220. A consolidated X-type B3 should cover exactly the same issue (e.g. re-determination of tariff classification, re-determination of origin or re-appraisal of value for duty), or exactly the same commodity.

221. Several commodities may be adjusted on a single X‑type if the issue is the same. For example, an importer can change the tariff classification of shoes, purses and boots all on one X-type.

222. Several issues may be adjusted on a single X-type. However, in this case, each individual commodity must be submitted under a separate X-type. For example, one X-type can be used to change the tariff classification, tariff treatment and value for duty of shoes alone on one X-type, while separate X-types would be required for similar adjustments to boots and purses).

GST Credits

223. Only adjustments that are transmitted in the same or current RSF month due to clerical errors can be used to recover GST. The GST cannot be credited by the CBSA outside the current month. Instead, any credit of GST is claimed directly from the importer’s Input Tax Credit.

224. CSA importers can combine more than one adjustment, each of which can be more than one line, on a single X-type entry (i.e. a “multiple-line”). However, adjustments under section 32.2 of the Act must not be combined with adjustments under section 74(1) of the Act on the same X-type, i.e. refunds cannot be combined with amounts payable to the CBSA. Consider the following example:

Self-Assessment of Drawbacks

225. Information on drawbacks can be found in Memorandum D7-4-3, NAFTA Requirements for the Duty Drawback and Duties Relief Programs. There are some differences with drawback activity under the CSA program.

226. Drawback activity is not processed as an automated X‑type entry. For CSA importers, the drawback program remains essentially unchanged, except that individual drawback claims (K32 or K32-1) are not submitted to the CBSA. In lieu of submitting individual claims, the CSA importer submits a new form called a Summary of Drawback Activity (SDA), Form CBSA130.

227. The SDA summarizes details such as the claim number, authority and amount claimed for the RSF period. The SDA also identifies claims affected by the limitations imposed by Article 303 of the NAFTA and where this is identified, “satisfactory evidence” must be submitted with the SDA. A sample of the SDA and instructions on its completion are provided on our website.

228. The total drawback claimed, as listed on the SDA, is included on the RSF of the CSA importer. The amount claimed on the RSF must match the amount calculated on the SDA for that RSF period. Filing time limits are linked to the RSF period in which the relevant drawback is claimed.

229. Although individual drawback claims are not submitted to the CBSA, CSA importers must continue to prepare their claims. The claims, as well as supporting documentation, certificates and schedules are to be retained by the importer and must be made available to the CBSA upon request, for verification.

230. Where a drawback repayment is necessary, the details will be included on the SDA and the amount of repayment is deducted from other drawback amounts claimed on that SDA. If the repayment exceeds the amount claimed, a negative will result. This negative amount is listed as a debit on the RSF, using the applicable drawback coding (e.g. 49019). Interest must be applied at the specified rate from the date of the credit of original SDA to the date of the repayment RSF. The CSA importer must retain appropriate records for verification.

231. When goods no longer qualify for relief under the Duties Relief Program and repayment of duties is required, the repayment must be included on the RSF. This will be listed as a debit on the RSF using the “duty on adjustments” coding (49010). Appropriate records are to be retained by the CSA importer for verification. Interest is applicable at the specified rate.

Self-Adjustment under SIMA or Surtax

232. The X-type automated adjustment process may be used by the CSA importer to submit a voluntary amendment to pay additional anti-dumping, countervailing duties or provisional duties, in accordance with sections 3, 4, 5, 6, 7, or 8 of SIMA or surtax, in accordance with an Order in Council. In addition, the X-type entry may be used to correct clerical errors that have no revenue impact. As with other X-type automated adjustments, the entry-acceptance message generated by CCS will provide the notice of decision.

233. Code E, “Other Adjustments”, is completed in Field 6 (Payment Code) of the X-type transmission.

234. Requests for downward adjustment of anti-dumping or countervailing duties continue to be submitted to the CSBA on Form B2. For additional information, please refer to Memorandum D14-1-3, Re-determinations and Appeals Under the Special Import Measures Act.

235. The applicable revenue owing as a result of a voluntary amendment are reported on the RSF as a debit against line object code 49011. Refunds of SIMA duties that are the result of a re-determination submitted on Form B2 are reported on the RSF as a credit against line object code 49018.

Self-Adjustment of Preferential Tariff Treatment

236. The automated X-type adjustment is used to transmit a correction related to a preferential tariff treatment. In these cases, adjustments must relate the original accounting transaction and line number of the importations involved. The original accounting transaction number is required in Field 24 (previous transaction number) and in Field 25 (previous transaction line) of both line one and line two. For consolidated adjustments that relate to a preferential tariff treatment, the original transaction number and line number of the earliest transaction being adjusted is used to complete Fields 24 and 25.

237. The RSF revenue reporting and remittance process for origin is the same as other automated self-adjustments. Supporting documentation such as a certificate of origin is required, but does not need to be submitted with the X-type adjustment unless requested by a border services officer.

Tariff Rate Quotas

238. To ensure that imports of a TRQ “within access commitment tariff item” are classified correctly, adjustments relating to TRQ products require individual review by the CBSA. These adjustments must continue to be submitted to the CBSA on Form B2, Canada Customs – Adjustment Request, with supporting documentation.

Section 7 - Compliance

Obligations

239. Based on CSA requirements found in the Part II application:

First Validation and Subsequent Revalidation

240. The first validation review will usually be initiated within 12 months of the CSA importer having begun operations within the CSA environment. It is necessary for the CBSA to validate the importer’s application details and to verify that the approved CSA importer is knowledgeable about the operational requirements of the program.

241. To ensure that a CSA participant maintains good standing in the CSA importer program, a CBSA officer will validate the participant regularly. This process will validate that the CSA-approved importer is fulfilling all CSA obligations and that the client remains low risk. If areas of non-compliance are identified, the CBSA officer will determine if an action plan is required.

242. Subsequent re-validations will usually be initiated 4 years from the date the final validation report is sent to the client. In the event the CBSA officer has any concerns or if there are any major changes to client activity (i.e. new service provider, new operating systems), a revalidation will be considered prior to the four year requirement and will be initiated within 12 months of the changes having taken effect.

The re- validation process will ensure program compliance by:

Monitoring

243. After an importer has been issued a CSA authorization and begins to operate within the CSA environment, periodic monitoring may be conducted by the CBSA. This process will help maintain the general level of compliance of CSA importers with the CBSA’s program legislation and related requirements.

Post Incident Analysis (PIA)

244. The CBSA may conduct a Post-Incident Analysis (PIA) following an incident that may affect a member’s program eligibility (as listed in Paragraph 55-60). A letter of notification will be sent to the program member when a PIA has been initiated. The letter will state the reason for the PIA and request the member’s participation.

245. The purpose of a PIA is to assess compliance with program eligibility requirements following an incident. A PIA will not be conducted at the request of another program or agency without grounds directly rooted in CSA program policy.

The PIA will seek to: 

246. Incidents that require a PIA may be brought to the attention of the CBSA by means of:

247. At the discretion of the CBSA, membership benefits, including access to FAST lanes entering Canada, may be maintained or suspended throughout the duration of a PIA depending on the severity of the incident.

248. The outcome of a PIA may consist of:

If the program member gives an unsatisfactory explanation as to the possible cause(s) of the incident, fails to respond effectively to the incident, and/or is unwilling or unable to participate in a PIA, then program membership may be suspended or cancelled at the discretion of the CBSA.

249. A letter will be sent to the program member when a PIA has been concluded. The letter will state the outcome of the PIA and will provide an effective date for the CBSA’s decision. A CBSA decision to cancel CSA program membership as a result of a PIA is subject to appeal.

Action Plans

250. An Action Plan constitutes a mutual agreement between the importer and the CBSA. Action Plans are administered to resolve specific incidents of non-compliance and do not necessarily result in an automatic suspension or cancellation of a CSA authorization. Action plans are created to formally document identified compliance issue(s), provide a means by which to resolve the issue(s) as well as provide support until such situations are corrected.

251. Action Plans may be created for issues of non-compliance which fall under either section 10.6(1) (suspension from the program) or 10.6(2) (cancellation/removal from the program) of the AIGPDR.  Alternatively, a CBSA officer may create an action plan to assist the importer applicant in meeting the requirements necessary for the issuance of a CSA authorization.

252. An Action Plan may be instituted for a period of up to six months, however should the importer feel they require additional time within which to address or correct the issue(s) they may make a written request for an extension of time.

253. Should an importer feel that an Action Plan is not warranted, the importer should contact the Manager of the CSA Importer Program. It is important to note that an action plan cannot be appealed as it is an interim measure to aid a client with compliance issues. If a client does not follow through with the required corrective actions their CSA authorization may be suspended or cancelled. Extension requests and action plan inquiries can be made to the following:

Customs Self-Assessment
Attention: Manager, CSA Importer Program
Canada Border Services Agency
P.O. Box 7000, Station A
Mississauga ON       
L5A 3A4

Penalties

254. Importers who do not comply with the requirements of the CSA program may be subject to penalties under the Administrative Monetary Penalty System (AMPS). CSA importers are not exempt from other non-CSA penalties that may also apply. More information on AMPS is available in Memorandum D22-1-1, Administrative Monetary Penalty System.

Additional Information

For more information, call the CBSA Border Information Service (BIS):

Calls within Canada & the United States (toll free): 1-800-461-9999
Calls outside Canada & the United States (long distance charges apply): 1-204-983-3500 or 1-506-636-5064

TTY: 1-866-335-3237
Email: contact@cbsa-asfc.gc.ca
Contact Us at the CBSA website may also be accessed for information.




Appendix A - Customs Self-Assessment Offices

Importers

Courier or in Person
Customs Self-Assessment
Canada Border Services Agency
1980 Matheson Boulevard East
Mississauga ON
L4W 5R7

Carriers

Customs Self-Assessment/FAST Carrier Compliance
Canada Border Services Agency
55 Bay Street North, 6th Floor
Hamilton ON, L8R 3P7

Appendix B - Load Specifications for Vendors and Consignees

As part of the CSA application and approval process, importers must submit an inventory of their trade chain partners to CBSA, as follows:

A list of all United States and Mexico vendors and domestic direct ship consignees must be submitted to the CBSA with the Part II, Books and Records, of the application process. If significant volumes are to be submitted, it is recommended that a test file be forwarded to check for file layout accuracy, before submitting the entire file.

A complete file must be submitted to the CBSA and approved at least six weeks before the CSA start date.

The TCP list must be submitted on a CD-ROM or USB key and must follow the specifications below.

Media Specifications

It is important that the media submitted conform to the media specifications outlined below. Submissions that do not conform to the specifications cannot be uploaded to CBSA systems and will be returned to the applicant. This may lead to delays in the application and approval process.

If a CD-ROM or USB key is being submitted, please indicate in writing on the CD-ROM or USB key the name of your business, and the name/source of the file.

Also, the CD-ROM or USB key must:

  • be compact disk recordable, CD-R (i.e. write once);
  • have a disk density of either 640 MB or 700 MB; and,
  • be properly closed.

Flat File Specifications

It is important that the information provided on CD-ROM or USB key conform to the flat file specifications outlined below. Only flat files in fixed length records with a .txt extension can be accepted by the CBSA and uploaded into CBSA systems. Submissions that do not conform to the specifications and cannot be uploaded to CBSA systems will be returned to the applicant. This will lead to delays in the application and approval process.

CBSA will not manipulate submissions to conform to the flat-file specifications. Should corrections or updates to submissions be required, the CBSA cannot accept them by e-mail.

Specifications

Flat files consist of the following:

  • a header record;
  • data records; and,
  • a trailer record.
  • All fields must be left aligned.

Header Record

The file must begin with a header record, which must be 450 bytes (i.e. 450 characters, including spaces). All the fields listed below are mandatory at the specified length. Complete the header record with a hard return (i.e. press ‘enter’).

Field Data Element Length Specifications
1 Record Identifier 2 numeric Must be ‘00’
2 Business Number 9 numeric The 9-digit business number of the CSA importer.
3 Filler 439 spaces 439 blank spaces

Example: The header record should begin like this: 00123456789 and be followed by 439 blank spaces. Do not fill with zeroes.

Data Records

Vendor and Direct-Shipped Consignee

Each line (i.e. each vendor or consignee record) must contain 450 bytes (i.e. 450 characters, including spaces). All the fields listed below are mandatory at the set length specified. Any unused characters must be spaces. (Do not input “0”s) At the end of each line, include a hard return (i.e. press ‘enter’).

Field Data Element Length Specifications Example
1 Record Identifier 2
numeric
Must be ‘02’ for consignee records
Must be ‘03’ for vendor records
02
03
2 Business Number 15
alphanumeric
BN must be a recognized division of a CSA applicant. Must be nine digits, the identifier RM followed by four digits 123456789RM0001
3 TCP Type Code 2
numeric
Must be one of the following:
01 – Dunn and Bradstreet
02 – internal
03 – business number (CDN registered companies)
04 – internal revenue service United States
05 – SCAC #
06 – other
03
4 TCP Identifier 15
alphanumeric
Must be 15 characters (including spaces)
Will accept number or letters. This must be unique and not duplicated.
12345 67890abcd
5 Address Line 1 30
characters
Must have at least two characters; At least one character must be numeric.
Will accept punctuation and symbols. Must fill with spaces to equal 30 characters.
128th St.
6 Address Line 2 30
characters
Will accept punctuation and symbols. Must fill with spaces to equal 30 characters. Unit 88
7 City 30
characters
Must have at least two characters. Will accept punctuation and symbols. (e.g. St. John’s) Must fill with spaces to equal 30 characters. New York
8 Province/State Code 2
alpha
For consignee records:
A valid province is mandatory.
For Vendor Records:
If country code is “United States”, a valid state code is mandatory; If country code is not “United States” a two-character province/state code can be entered, otherwise it must be filled with two blank spaces.
AB
NY
9 Country Code 2
 alpha
For consignee records:
Must = “CA”
For Vendor Records:
Cannot = “CA”
CA
United States
10 Postal/Zip Code or other country postal code 10
alphanumeric
For consignee records:
Must be valid postal code (no space in the middle)
For Vendor Records:
If country code is “United States” then a valid ZIP code is required. A five-digit ZIP code must be followed by five spaces and a nine-digit ZIP code cannot have the hyphen and must be followed by one space. If country code is not “United States”, another country postal code can be entered, otherwise it must be filled with 10 spaces.
N9D7H4
12345
123456789
A1A1A1B
11 Business Name 175 alphanumeric Must be at least two alphanumeric; Will accept punctuation and symbols. Must fill with spaces to equal 175 characters. ABC Importing
12 Filler 137
spaces
Must fill with 137 spaces. 137 spaces

The total record must be comprised of 450 characters- including spaces.

Trailer Record

The file must end with a trailer record, which must be 450 bytes (i.e. 450 characters, including spaces). All the fields listed below are mandatory at the specified length. Any unused characters must be spaces. Do not include a hard return at the end of the trailer record (i.e. do not press ‘enter’).

Field Data Element Length Specifications
1 Record Identifier 2 numeric Must be ‘99’
2 Number of Records 9 numeric The number of records in the file, including the header and trailer records. This number must have preceding zeros (e.g. 000000076)
3 Filler 439 spaces 439 blank spaces

Example: If you had 74 vendors and consignees in the file and, remembered to add the header and trailer records, the trailer would be 99000000076 followed by 439 spaces. Do not fill with zeros.

Reasons for Rejection of Flat File Submissions

Submissions will be rejected if:

  • The header record does not exist, is duplicated, or is found elsewhere in the file;
  • The header record does not begin with ‘00’;
  • The nine-digit BN is not valid with the CBSA, or is not a valid CSA importer;
  • The header or trailer record does not have exactly 450 characters, including spaces;
  • No vendor or consignee records exist (i.e. no data records were provided);
  • The vendor/consignee records are not maximized to exactly 450 characters;
  • The TCP identifier (Field 4) is duplicated;
  • The postal code includes a space or is not a valid postal code;
  • The data in each field are not left aligned;
  • The trailer record does not begin with ‘99’;
  • The total record count does not equal the count in the trailer record, including the header and trailer records;
  • The record count field is not nine digits (e.g. ‘000000076’); and/or
  • There is a hard return after the trailer.

Appendix C - Transition

1. The transition of an importer from traditional CBSA processes to the CSA environment is critical, and requires careful coordination between the CBSA officer, the importer, the service providers and the CBSA. In particular, the implications of the importer’s CSA “start date” need to be clearly understood and applied. On the importer’s CSA start date, transactions submitted to the CBSA with the 15-digit BN/RM of the CSA-approved importer are processed using CSA procedures and the processing of records in ACROSS and CCS will change. These changes include:

  • (a) Release records are de-linked from accounting records for importers to trigger accounting from their internal business systems.
  • (b) The five-day time frame for the accounting of commercial goods is discontinued and the CSA importer is to account within the time frames of CSA accounting option selected. An overdue release report is not generated for releases after the start date.
  • (c) Accounting transmissions continue to be captured in CCS, but are not required to use the same transaction number as that used to effect release. Some accounting information may be consolidated.
  • (d) The DN and SOA are not generated by the CBSA for goods accounted to the CBSA on or after the CSA start date. Revenue amounts related to goods accounted to the CBSA on or after the CSA start date are self-assessed by the importer and reported on the RSF, even if the goods were released before the start date.
  • (e) Payment is not made to a CBSA office for goods accounted to the CBSA on or after the CSA start date, but is remitted through a financial institution specified by the CSA importer. Given that a SOA is generated for goods accounted to the CBSA before the CSA start date, payment of the final SOA is made separately to the CBSA using one of the payment methods listed in Memorandum D17-1-5, Registration, Accounting and Payment for Commercial Goods. (This should occur only during the first month of transition to the CSA.)
  • (f) Debit adjustments submitted before the CSA start date will be paid using one of the payment methods listed in Memorandum D17-1-5, while credit Adjustments will be refunded by offsetting the client account. If a residual credit remains after offsetting, a refund cheque will be issued to the importer. After the CSA start date, requests for self-adjustments and refund applications are submitted to the CBSA electronically by X-type adjustment. A DAS is not issued for X-type adjustments. The X-type entry-acceptance message represents a notice of decision. In situations where the importer is required to submit a B2, an ACOR DAS is issued to provide a notice of decision. Where an amount is owing to the CBSA, it is reported as a debit on the RSF. Where an amount is due to the importer, the amount is reported as a credit on the RSF and a cheque is not issued by the CBSA.
  • (g) Any B2-1s in process at the time of CSA conversion must continue to be paid using one of the payment methods listed in Memorandum D17-1-5 or by offsetting the client account. If a residual credit remains after offsetting, a refund cheque will be issued to the importer, even after the CSA start date. They cannot be paid or offset on the RSF. The comments section of the B2-1 will indicate whether or not it should be paid or offset on the RSF. If the reference to recording the B2-1 on the RSF does not appear in the comments section, the B2-1 cannot be paid or offset on the RSF.
  • (h) After CSA conversion, any new B2-1 amount must be recorded under the debits or credits section of the RSF, under the appropriate line object codes. Similar to (g) above, if the comments section of the B2-1 states that the amount must be reflected on the RSF, the amount shown must be paid or offset on the RSF unless the B2-1 is non-revenue or subject to the Customs Accounting Document Error Remission Order.

2. It is important to note that while most elements of the CSA importer’s business with the CBSA will transfer to CSA processing on the start date, there could be some business activities that may require completion under pre-CSA processing. The following table is provided as a guideline to determine if a CBSA process is completed using a CSA or pre-CSA procedure. To determine the process environment that will apply, there are two key steps:

  • (a) Identify the CBSA process, for example cargo reporting; release, accounting and payment, or adjustment.
  • (b) Identify at what point during the specific process the importer’s CSA start date occurred.
Customs Element Status on CSA Start Date Transition process
Cargo Reporting Cargo not acquitted on or after the importer’s start date. Overdue cargo report is generated but tracers not issued. To avoid liability, carriers should obtain proof of delivery from the CSA importer during and after transition period.

Release

Release decision or request date is on or after CSA start date. CSA process applies; i.e. date of release is the date the shipment is physically received at the importer/owner/consignee’s place of business. ACROSS will not search for acquittal of release decision from CCS. Extended accounting time frames apply.
Release decision is made before the CSA start date and release is not accounted for by the start date Overdue release report will be generated but manually acquitted by the CBSA. Importer is to use CSA processes; i.e. account for, report revenue on RSF and pay through a financial institution.
Note that these goods may have been physically received by the importer/owner/consignee before the start date and could fall outside the importer’s business accounting trigger. Importer/ service provider is to ensure that these non-acquitted shipments transfer to the RSF remittance procedures.

Accounting

The B3 is in entry-acceptance status 250 before the CSA start date. Pre-CSA process will occur and B3 will appear on a DN.
Payment made using one of the payment methods listed in Memorandum D17-1-5.
The B3 has not reached entry acceptance status 250 on or after the CSA start date. CSA processing is to be used, i.e. The B3 will not appear on a DN. Related revenue amounts are reported on RSF and payment made through a financial institution.

Adjustment

Hard-copy B2 is submitted to the CBSA and inventoried before the CSA start date. Pre-CSA processing is to be used; i.e. DAS will be issued, and payment made using one of the payment methods listed in Memorandum D17-1-5 (amount owing by importer) or by offsetting the client account. If a residual credit remains after offsetting, a refund cheque will be issued to the importer (amount due to importer).
Hard-copy B2 submitted to the CBSA is inventoried on or after the CSA start date. The B2 will be keyed into CCS but as an ACOR. DAS will be issued but related revenue amounts are to be reported by the importer on the RSF. Amounts owing to the CBSA are reported as a debit on the RSF and paid at a financial institution; amounts due to the importer are credited on the RSF.
Automated adjustment (X-type B3) transmitted on or after the CSA start date CSA processing will apply, i.e. no DAS issued, revenue amounts reported on RSF. Amounts owing to the CBSA are reported as a debit on the RSF paid at a financial institution; amounts due to the importer are credited on the RSF.

Appendix D - CSA Accounting Options

Accounting and Payment – High Value Shipments (exceeding $3,300 CAD)

  Regular Commercial Stream (Non-CSA Importer) CSA Option 1 CSA Option 2
Release Period N/A In the context of providing B3 trade data, 1st to 31st day of Month One. In the context of providing B3 trade data, 19th day of Month One to 18th of Month Two.
Trade Data Reporting (B3) B3 is due within five business days of release (individually). B3s for receipts/releases from 1st to 31st day of Month One, are due by 18th of Month Two. B3s for receipts/releases from 19th day of Month One to 18th day of Month Two, are due by last business day (LBD) of Month Two.
Trade Data Reporting Trigger B3 provided is based on the CBSA release date. Three-way match between purchase order, receipt and invoice, or equivalent, in books and records. At least two monthly “sweeps” are recommended to account for goods not yet matched:
a) by the 18th day of the month (for trade data reporting); and
b) before the cut-off date (to ensure records within the payment time frame are included on the RSF). Same for LVS.
Other processes are accepted where books and records cannot trigger; however, audit trails must be in place.
Three-way match between purchase order, receipt and invoice, or equivalent, in books and records. At least one “sweep” is recommended before the last business day of the month to ensure both trade data and payment are included on the RSF. Same for LVS.
Other processes are accepted where books and records cannot trigger; however, audit trails must be in place.
Time to submit B3 Within five business days after release. Min: 18 days or 12 business days
Max: 49 days.
Min: 10 days or 8 business days.
Max: 43 days
Payment Period and Monthly Payment B3s accepted between 25th of Month One and 24th of Month Two are paid LBD of Month Two. Receipts/releases from 19th of Month One to the 18th day of Month Two must be paid by LBD of Month Two. Receipts/releases from 19th day of Month One to 18th day of Month Two must be paid by LBD of Month Two.
Billing Statement Bill (SOA) is issued by the CBSA on 25th of Month Two for B3s accepted between 25th day of Month One and 24th day of Month Two. Importer prepares billing statement (Revenue Summary Form - RSF) detailing duty and tax breakouts for all the B3 and adjustment data accepted between the importer’s “period start” and “period end” dates. Submitted by LBD of the month in which the payment period ends. Importer prepares RSF detailing duty and tax breakouts for all the B3 and adjustment data accepted between the importer’s “period start” and “period end” dates. Submitted by LBD of the month in which the payment period ends.
Interim Payment N/A Optional - Duty and tax estimates on goods that were received/ released but were not accounted for before the submission of the RSF. Optional - Duty and tax estimates on goods that were received/ released but were not accounted for before the submission of the RSF.
Interim Payment Reconciliation N/A Interim payment is credited the following month. Actuals reported on RSF. This results in an offset. If actuals are greater than interim payment, difference is paid; if actuals are less than interim payment difference is credited. Interim payment is credited the following month. Actuals reported on RSF. This results in an offset. If actuals are greater than interim payment, difference is paid; if actuals are less than interim payment difference is credited.
Interim Payment Interest N/A Difference noted above is subject to interest calculations (debit or credit). Interest is self-assessed by the importer and recorded on RSF. Difference noted above is subject to interest calculations (debit or credit). Interest is self-assessed by the importer and recorded on RSF.
Late Accounting (B3) Penalty HVS Transactions for goods (exceeding $2,500) CAD, must be accepted by the CBSA within five business days after their release, or a penalty of $100 CAD for each late transaction is assessed (Contravention C288). HVS transactions from Month One, that are accounted for after the 18th of Month Two, will incur a late-accounting penalty (Contravention C244). Where compliance falls below 95 percent in a calendar year, the penalty is $100 CAD per transaction below the compliance level (Contravention C246).  During the calendar year, nil-rated warning notices will be automatically issued to establish the compliance rate. The penalty for late accounting that falls below the compliance level will be assessed and billed by the CBSA, and paid on the next RSF. HVS transaction from the 19th of Month One to the 18th of Month Two, that are accounted after the LBD of Month Two, will incur a late-accounting penalty (Contravention C244). Where compliance falls below 95 percent on a calendar year basis the penalty is $100 CAD per transaction below the compliance level (Contravention C246). During the calendar year, nil-rated warning notices will be automatically issued to establish the compliance rate. The penalty for late accounting that falls below the compliance level will be assessed and billed by the CBSA, and paid on the next RSF.
Late Transaction (B3) Payment Interest Late-payment interest applies to B3 transaction amounts that are late and not paid by the SOA monthly payment due date, i.e. the last business day of the month. Any goods received/released between the 19th day of Month One to the 18th day of Month Two not duty-paid by the LBD of Month Two will incur late transaction payment interest. This will be self-assessed by the importer and added to the next applicable RSF. Any goods received/released between the 19th day of Month One to the 18th day of Month Two not duty-paid by the LBD of Month Two will incur late transaction payment interest. This will be self-assessed by the importer and added to the next applicable RSF.
Remittance at a Financial Institution N/A – (Payment for SOA issued the 25th day of Month Two is made directly to the CBSA cashier by LBD of Month Two.) Same for LVS. Payment for RSF is required to be made directly at financial institution by LBD of the Month in which the related RSF is due. Same for LVS. Payment for RSF is required to be made directly at financial institution by LBD of the Month in which the related RSF is due. Same for LVS.
Late-payment Interest Late payment of the DN/SOA is assigned late-payment interest by the Customs Commercial System (CCS). It will automatically appear on the DN/SOA for the following month. Same for LVS. If remittance for the RSF is made late by the importer, the importer will self-assess late payment interest. Same for LVS. If remittance for the RSF is made late by the importer, the importer will self-assess late payment interest. Same for LVS.

Appendix E - Accounting and Payment – Low Value Shipments ($3,300 CAD or less)

  Regular LVS Commercial Stream (Non-CSA Importer) CSA Option 1 CSA Option 2
Release Period 1st to 31st of Month One 1st to 31st of Month One (Same as HVS Option 1). 19th day of Month One to 18th of Month Two. (Same as HVS Option 2).
Trade Data Reporting (B3) B3s for releases from 1st to 31st of Month One due by 24th day of Month Two. Same as HVS Option 1.
B3s for receipts/releases from 1st to 31st day of Month One, are due by 18th of Month Two.
Same as HVS Option 2.
B3s for receipts/releases from 19th day of Month One to 18th day of Month Two, are due by last business day (LBD) of Month Two.
Time to submit B3 24 days or 17 business days. Same as HVS Option 1.
Min: 18 days or 12 business days
Max: 49 days
Same as HVS Option 2.
Min: 10 days or eight business days
Max: 43 days
Payment Period and Monthly Payment B3s accepted between 25th day of Month One and 24th of Month Two are paid LBD of Month Two. Receipts/releases from the 19th of Month one to the 18th of Month Two, must be paid by LBD of Month Two. Receipts/releases from the 19th of Month one to the 18th of Month Two, must be paid by LBD of Month Two.
Billing Statement Bill (SOA) is issued by the CBSA on 25th day of Month Two for B3s accepted between 25th day of Month One and 24th day of Month Two. Importer prepares billing statement (Revenue Summary Form - RSF) detailing duty and tax breakouts for all the B3 and adjustment data transmitted between the importer’s “period start” and “period end” dates. Submitted by LBD of the month in which the payment period ends. (Combined with RSF for HVS.) Importer prepares billing statement (Revenue Summary Form - RSF) detailing duty and tax breakouts for all the B3 and adjustment data transmitted between the importer’s “period start” and “period end” dates. Submitted by LBD of the month in which the payment period ends. (Combined with RSF for HVS.)
Late-accounting (B3) Penalty Any LVS transaction from Month One not accounted for by the 24th day of Month Two, is manually issued a late accounting penalty by the CBSA office on the 25th day of Month Two (Contravention C292). ANY LVS transactions accounted for after the 18th of month two, may incur a late accounting penalty. This will be assessed by the CBSA during verification and billed to the importer.  ANY LVS transactions accounted for after the LBD of month two, may incur a late accounting penalty. This will be assessed by the CBSA during verification and billed to the importer. 
Late-transaction  Payment Interest Where a payment of duties is late (after the 24th day of month two), Late-payment interest is manually calculated and issued by the CBSA office. Where a payment of duties is late (after the LBD of month two), the respective interest amount is to be self-assessed and reported on the next RSF. Where a payment of duties is late (after the LBD of month two), the respective interest amount is to be self-assessed and reported on the next RSF.

Appendix F - Line Object Codes for RSF

Code English description Description française
49010 Import Duties Droits d’importation
49011 Special Assessment Cotisation spéciale
49017 Refund of Import Duties Remboursement des droits d’importation
49018 Refund of Anti-dumping Duty (HQ) Remboursement du droit antidumping (AC)
49019 Drawback of Import Duties Drawbacks des droits d’importation
49020 Drawback of Anti-dumping Duty Drawbacks du droit sur l’antidumping
49021 Drawback of Countervailing Duty Drawbacks du droit compensatoire
49121 Goods and Services Tax/Harmonized Sales Tax – Revenue Taxe sur les produits et services/Taxe de vente harmonisée — Revenu
49129 GST/HST – Credit for Current Month Corrections on Forms E648 TPS/TVH – Crédit pour les corrections au mois courant sur les formulaires E648
49177 Refund of Sales Tax on Importation Remboursement de la taxe de vente sur les importations
49179 Drawbacks on Importation Drawbacks sur les importations
49407 All Refunds on Importation Excise Tax Tous les remboursements sur la taxe d’accise à l’importation
49409 All Drawbacks on Importation Excise Tax Except Gasoline Tous les drawbacks sur la taxe d’accise à l’importation, à l’exception de l’essence
49412 Cigars Cigares
49413 Cigarettes Cigarettes
49414 Tobacco Tabac
49416 Jewellery Bijoux
49418 Lighters Briquets
49420 Automobiles Automobiles
49425 Automotive Air Conditioners Conditionneurs d’air d’automoteur
49435 Vaping Products Produits de vapotage
49437 Excise Tax – Interest Payable on Refund and Drawback Claims (Importations) Taxe d’accise — Intérêts à payer se rapportant aux remboursements et drawbacks (Importations)
49438 Wines – Less Than 7% Vins – Moins de 7 %
49439 Penalty Amount Refunded Remboursement sur les amendes
49441 Penalty for Late Accounting Amendes pour déclaration en détail tardive
49442 Interest on Late Payment of Revenue Summary Form Intérêt pour les paiements en retard des sommaires des recettes
49443 Interest on Late Payment of Individual Transactions Intérêt pour les paiements en retard des transactions individuelles
49450 Wines - More Than 7% Vins – Plus de 7 %
49452 Excise Tax Penalty - Importation Amendes sur taxe d’accise – Importation
49453 Excise Tax - Importations Misc Divers
49454 Excise Tax Interest - Importation Intérêt sur taxe d’accise – Importation
49460 Excise Tax on Gasoline Taxe d’accise sur l’essence
49475 Excise Tax - Casual Importations Taxe d’accise – Importations occasionnelles
49555 Interest on Various Adjustments; Diversions, Quantity, Price, Retroactive, etc. Intérêts sur divers rajustements; réaffectations, quantité; prix, rétroactivité etc.
49745 Special Services Fees Droits de services spéciaux
49764 Port Seizures Saisies dans les ports
49766 Customs Penalties Amendes douanières
49768 Miscellaneous Divers
49874 Int. Pd on Late Pym of Pen AMPS Int payé sur paiement tardif de sanctions RSAP
49875 AMPS – Customs RSAP – douanes
49876 Rfd AMPS Pen & Int Remboursement sanction et intérêts RSAP
49878 Int Rfd of AMPS Intérêt remboursementRSAP
49530 Beer – Not More Than 1.2% Bière - pas plus de 1,2 %
49531 Beer – Not More Than 2.5% Bière - pas plus de 2,5 %
49532 Beer – More Than 2.5% Bière plus que 2,5 %
49540 Matured Spirits Alcool à point
49541 Unmatured Spirits Alcool non à point
49542 Spirit Coolers Boissons rafraîchissantes alcoolisées
49613 MB – Prov. Alcohol Levies Impôt prov. boiss. alcoolisées - MB
49673 MB – Prov. Sales Tax Taxe de vente provinciale - MB

Appendix G - Letter of Authorization

Letter of Authorization

Sample Only

Business Letter Head

Date

To: Canada Border Services Agency

Subject: Letter of Authorization

This is to advise you that:

Name of representative:
Address:
City/Province/State:
Postal/Zip-code:

Is authorized by:

Name of business:
Address:
City/Province/State:
Postal/Zip-code:

To provide information to the Canada Border Services Agency (CBSA) on behalf of the business as required in relation to the Customs Self-Assessment Program (CSA).

(Business Name) acknowledges that by authorizing the above noted representative, it assumes full liability for all information provided to the CBSA by their representative.

This authorization is valid until further notice.

Authorized Signature:

Title:

Telephone Number:

References

Issuing office:
Trusted Trader Programs Unit
Trusted Trader Programs Division
Commercial  Program Directorate
Canada Border Services Agency
Headquarters file:
 
Legislative references:
Customs Act, section 32(2)(b)
Excise Tax Act
Special Import Measures Act
Privacy Act
Accounting of Imported Goods and Payment of Duties Regulations
Reporting of Imported Goods Regulations
Customs Tariff
Other references:
D1-4-1, D1-6-1, D7-4-3, D11-6-5, D11-6-6, D11-6-7, D14-1-3, D17-1-4, D17-1-5, D17-1-8, D17-1-9, D17-1-10, D17-2-3, D18-3-2, D22-1-1, D23-2-1, Electronic Commerce Client Requirement Document (ECCRD)
Superseded memorandum D:
D23-3-1, dated December 18, 2020
Date modified: