The timing of the three releases of the new CBSA Assessment and Revenue Management (CARM) initiative are changing due to COVID-19. Please refer to our CARM webpages and to CBSA’s pages for the most current information.
One of the main changes as a result of this new program is how importers will work with their Customs brokers.
Right now, Customs brokers do much of their work independently, serving importers to ensure efficient clearance of goods at the border. With CARM, the assumptions and dynamics of the importer-broker relationship change.
For Release 0, which is ongoing, there is no change to any of the CBSA’s processes—so there’s no change to how you’re working with your broker. The CBSA is moving their current accounting system to the new cloud-based platform.
Register and revise your process
Release 1 (projected for January 2021) is the beginning of changes in how you will likely work with your broker and how you’ll work internally.
Once the new online CARM Client Portal (CCP) is activated, importers will need to:
- Register on the new system
- Get familiar with the payment and bonding system
- Revise your payable processes to meet the new requirements
These changes must happen before Release 2 potentially in late 2021. The main thrust of your efforts once the portal is live is to get your processes in place. This will take time. And it needs to happen by the time Release 2 comes out—if it doesn’t, you may not be able to import into Canada.
So how does Release 1 impact how you’ll work with your broker?
Every importer will need to have a surety bond in place in advance of CARM going fully live, potentially in later 2021.
We’ve written about this process in detail and advise you to get your bond in place as early as possible.
Currently, your broker handles paying the daily notices and statements of account with CBSA.
With CARM, you will be responsible for both. So, you’ll either need to:
- Get training from your broker to do it yourself, or
- Give your broker portal access to manage them for you.
Your broker/s may or may not offer this as an additional service, so be sure to start these clarifying conversations well in advance. Please note that if you give your broker access to manage your daily notices and statements of account, you will still need to make your month end payments electronically directly to CBSA.
The CCP features the ability to file customs rulings electronically.
You’ll need to consider in advance whether you want to handle rulings yourself or give your customs broker access to the portal to do it for you.
HS tariff selection tool
Release 1 features an HS tariff tool to help understand what the duty rates would be on products coming in. However, tariff classification requires technical expertise, tool or no.
- Getting tariff classification wrong will cost you money in compliance penalties. Classification should be done by highly trained professionals.
- If you want to move this process internally, you may need training from your broker, or decide to leave that to them as part of the normal customs entry process.
- Please note that classifications found using the CBSA tool are not considered binding on the Agency.
Revising internal processes
CARM places much of the account management process back on the importer’s shoulders.
So, much of your preparation will be in analyzing your current processes and making critical decisions about how you’ll manage your day-to-day CBSA account.
If you handle it yourself:
You will need training. Your broker can potentially provide this training, but the question is: Is learning these processes core to your business? Do you want that knowledge internally? If so, it’s worth it to get trained or recruit.
If you delegate to your broker:
Your broker will require specific access and permissions. Talk through the entire process with your internal teams and your broker. Decide which processes to delegate to your broker, and get clear on changes that need to be made in your internal processes.
What should you do now?
When CARM’s Release 1 goes live, 280-300,000 importers and trade chain partners will all need to be registered in the CCP. Obtaining surety bonds will likely take 3-6 weeks to process. These steps should be handled early—the perfect time is between Releases 1 and 2.
Between now and Release 1’s launch in early 2021? Think about it. Talk to your broker. Work through the processes and potential issues. Work through the process release by release and take your time—don’t leave it to the last minute.
Our Customs team here at Cole is ready to help.
Explaining CARM. It's what we do.
More of our CARM series: