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Mandatory System for Canadian Importation Delayed

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Urvesh Patel

Corporate and International Tax Manager

The CBSA is in the process of introducing the CBSA Assessment and Revenue Management (CARM) system as the mandatory system of record for interacting with the CBSA for commercial import shipments into Canada. To learn more about the CARM system and its potential implications for middle-market businesses, see below “New Mandatory System for Canadian Importation.”

Originally slated to enter into use on May 13th, the CBSA has announced that the mandatory adoption of CARM for importers and other trade chain partners will be delayed until October 2024. The CBSA cited the potential impact on their operations should members of the Public Service Alliance of Canada (which represents over 9,000 CBSA employees) choose to strike. The Public Service Alliance of Canada launched a strike vote on April 10th.

While the delay provides importers additional time to register for a CARM Client Portal (CCP) account and make related procedural changes, it is clear that the CBSA intends to proceed with implementing CARM as the mandatory system of record. Those who import commercial goods into Canada should register their businesses in the CCP and delegate necessary authorities as soon as possible to avoid any potential delays and registration issues in October. Importers looking to use the Release Prior to Payment program should also ensure they are positioned to post the necessary security. For additional assistance with navigating the transition to CARM, please contact your RSM Canada trade advisory team.

New Mandatory System for Canadian Importation

Executive Summary

The CBSA Assessment and Revenue Management (CARM) system is set to enter into use on May 13th, 2024. CARM will be the system of record for interacting with the CBSA for commercial import shipments into Canada. Proactively ensuring necessary registrations and other requirements are met before May 13th will prevent interruptions in importing and doing business with the CBSA.

Introduction of the CARM System

The Canada Border Services Agency (CBSA) has announced that the CBSA Assessment and Revenue Management (CARM) system will become mandatory on May 13th, 2024 (Release 2). CARM will serve as the system of record for commercial import shipments into Canada, introducing significant procedural changes for importers. Ensuring necessary registrations and other requirements are met well before the implementation date will help prevent interruptions in importing and doing business with the CBSA.

The CBSA has recently revised its mandatory CCP registration requirement to allow for a limited transition period. However, importers trying to import commercial goods on or after May 13th without a CARM Client Portal (CCP) account may face challenges in accounting for goods released using release prior to payment privileges and could incur penalties if the goods are not accounted for by the due date. More details from the CBSA will likely follow on this important policy change. It remains best practice to register for the CCP well before May 13th to avoid confusion, disruption, and potential penalties.

Some importers may not be prepared for CARM by May 13th, potentially causing congestion and supply chain disruptions. Importers should therefore consider increasing critical imports into Canada before May 13th to plan accordingly.

Registration

Importers will need to register for a CCP account to continue importing activities. To complete the CCP registration process, businesses will need the following information:

  • A GCKey or the ability to use a sign-on partner (a financial institution linked to the CBSA systems)
  • Business Number (BN 9)
  • Import/Export Program account (RM)
  • Statement of Account and/or Daily Notice
  • Individuals at the business requiring CCP access will need their own personal CARM profile. The level of access and authorization each individual will have to the business’ account can be controlled. The individual who initially registers the business will typically be the business account manager and have the highest level of access and authorization.

 

Delegation of Authority

Importers can delegate their customs broker the authority to act on their behalf in the CCP. To ensure a smooth transition to the new system, importers should ensure this authority is delegated in CARM well before May 13th.

If you have any questions or need further assistance navigating these new regulations, please do not hesitate to contact our firm. Our team of experts is here to help you understand the impact on your import activities and ensure compliance with all applicable rules.

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