CBSA Reveals Transition Update for CARM Release 2 Implementation

If you’re a Canadian importer, the CARM Release 2 transition might affect your business. Read on to learn more.

In preparation for Release 2 of the CBSA Assessment and Revenue Management (CARM) system, the Canada Border Services Agency (CBSA) has issued Customs Notice 24-15 outlining critical changeover measures. These measures aim to ensure a seamless transition for Canadian importers and customs brokers.

Starting May 13, 2024, Canadian importers and trade chain partners must use the CARM system as the official platform for declaring imported goods and paying applicable duties. Moreover, the CARM Client Portal (CCP) will be the central system for registering CBSA accounts and enrolling in different CBSA programs.

The CBSA is committed to minimizing disruptions to trade operations while introducing CARM Release 2. To achieve this, the agency has implemented transition measures, which Canadian importers and customs brokers are advised to note. 

It is important to familiarize yourself with these measures and take the necessary steps to adapt to the changes that will occur in the importation process. If you need help, please reach out to one of our trade professionals.

Introducing a 180-day transition period

The CBSA will introduce a 180-day transition period after implementing CARM’s second release to make the transition smoother for Canadian importers. 

During this time, all commercial importers with a history of accounting for goods using their importer business number within the past four years will automatically benefit from the Release Prior to Payment (RPP) program. 

New importers who are interested in enrolling in the RPP program throughout this transition period can do so through the CCP. During the enrollment process, they can choose to request a lower-than-recommended financial security amount. Once this request is made, CBSA will review the case and apply the RPP indicator.

One of the major changes introduced by CARM is related to the RPP process. Previously, importers could use a broker's RPP security to release their imported goods before paying the duty. This will no longer be possible. Instead, as a Canadian importer, you must now provide your own financial security through the CCP to release your imported goods.

The need for a Business Number (BN15)

After the implementation of CARM, the use of a broker Business Number (BN15) will be allowed for commercial goods in certain situations for a period of 12 months. This will be beneficial for scenarios involving new importers and first-time commercial importers, as broker BN15 will help in the release and accounting of goods.

If an importer already has a BN15 or has not yet obtained one, using a broker BN15 at the time of release is only allowed in the following cases:

• For first-time commercial importers (including NRIs), Canadian importers must register with the CCP and obtain a BN15 immediately prior to submitting the release. If this is not feasible or would delay the release of goods upon arrival, the CBSA will allow, for a period of up to 12 months post CARM implementation, the use of a broker BN15 to obtain the release and account for commercial goods.
  
  
• For one-time commercial importers, the CBSA will allow, for a period of up to 12 months post CARM implementation, the use of a broker BN15 for the purpose of obtaining the release and to account for commercial goods.
  
  
• For a 12-month transition period, the CBSA will allow the continued use of a broker BN15 to account for commercial goods in the CLVS stream when the importer, including NRIs, has not registered to the CCP.
  
  
• For a 12-month transition period following the CARM implementation, a broker BN15 may be used if it is determined, post-release and delivery, that goods did not qualify for CLVS clearance (e.g., HVS, OGD regulated, etc.).

While legislative amendments to Section 17 of the Customs Act are pending enforcement, the CBSA emphasizes the importance of compliance once these amendments come into force.

Don’t get caught behind

All Canadian importers are required to register on the CARM Client Portal (CCP) before May 2024. If you still haven’t, please contact one of our trade professionals. They will be happy to guide you through the registration process and ensure you’re on track ahead of the implementation of CARM Release 2.