CBSA Announces CARM Requirements for Customs Bonded Warehouse TCPs
The new requirements will improve the efficiency and compliance of Trade Chain Partners (TCPs), specifically Customs Bonded Warehouse (CBW) licensees, including operators, importers, and brokers.
The Canada Border Services Agency (CBSA) has announced through Customs Notice 24-23 that all Customs Bonded Warehouse (CBW) TCPs must enrol in the CARM Client Portal (CCP) and submit a one-time baseline inventory count of goods in their warehouses before the CCP's official launch.
The new requirements are part of the CBSA Assessment and Revenue Management System (CARM) program, whereby the CCP will become the official platform for collecting duties and taxes on goods imported into Canada on October 21, 2024.
The CCP will provide enhanced mechanisms for Customs Bonded Warehouse TCPs to improve communication and securely submit the necessary documentation to the CBSA electronically. This will facilitate compliance and enhance the traceability requirements of various CBSA trade programs.
CBWs are facilities licensed and regulated by the CBSA and operated by the private sector. These warehouses allow for the complete deferral of customs duties, anti-dumping and countervailing duties, excise duties, and taxes on imported goods until they are released for Canadian domestic consumption or exported.
CBWs may consist of:
As per the Customs Bonded Warehouses Regulations, CBWs can perform specific activities that do not materially alter the goods, such as disassembling, displaying, inspecting, marking, packing, and storing. Goods may also undergo cleaning, diluting, maintenance, and sorting. However, goods in a CBW must not be further manufactured.
To prepare for CARM’s full implementation, Customs Bonded Warehouse TCPs must:
The CBSA emphasizes that the inventory information provided will be considered a legal declaration. Inaccuracies or omissions may result in Administrative Monetary Penalties (AMPs), and all inventory declarations will be subject to post-compliance verification.
The CBSA recommends transmitting inventory counts using the Application Programming Interface (API) or Electronic Data Interchange (EDI). These methods ensure efficient and accurate data capture for individual transactions. You can find more information about submitting through EDI or API in Chapter 26: Commercial Accounting Declaration (CAD).
TCPs without access to API or EDI must submit a Type 10 Commercial Accounting Declaration (CAD) via the CCP within the first two weeks of CARM becoming the system of record. This manual submission will reflect their current warehouse inventory.
For CBWs unable to use the recommended electronic methods, the CBSA will offer a one-time file-upload option before the cutover period. Participants must submit their inventory using a CBSA-provided spreadsheet template and undergo a manual review by CBSA officers.
Participants opting for this method must notify the CBSA by August 1, 2024, submit a sample inventory by August 16, 2024, and complete their inventory submission by the first day of the cutover period.
Despite the transition to electronic submissions, TCPs are still required to maintain hard copies of all electronically submitted applications and supporting documentation, as mandated by the Customs Act and Imported Goods Records Regulations. These records must be readily available to the CBSA upon request.
The CBSA will release further details regarding the transition measures and cutover period at a later date.
Please reach out to one of our trade professionals for more information on these requirements and how they might affect your import business.