During the transition from September 1 to October 20, 2024, customs adjustments may face delays, and electronic submissions via CARM are recommended for faster processing.
The Canada Border Services Agency (CBSA) has announced significant changes to how importers and other trade chain partners submit and process customs adjustments through its Customs Notice 24-25.
Key changes to the customs adjustments process
The following changes will apply to the customs adjustments process as of October:
- CARM the official platform: Starting October 21, 2024, the CBSA Assessment and Revenue Management (CARM) system will become the official platform for managing commercial imports, duties, and taxes.
- Phasing out Form B2: Form B2, currently used for declaring customs adjustments, will be replaced by the new Commercial Accounting Declaration (CAD) in the CARM system.
- Submission period notice: From September 1 to October 20, 2024, single B2 adjustments, blanket B2 adjustments, or voluntary disclosure requests submitted will likely not be processed before CARM’s launch. During this period, blanket requests must include both the authorization application and a completed Form B2.
- Manual processing transition: Any B2s not processed before October 21 will be manually entered into CARM, potentially causing delays. To minimize interest accrual, importers are encouraged to submit B2s with payments for amounts owed. Payments processed after the transition will be posted to the importer’s account rather than allocated to the specific adjustment.
- Electronic submissions encouraged: To avoid delays, importers and trade partners should refrain from submitting customs adjustments and disclosure requests between September 1 and October 20, 2024, and instead use CARM for faster electronic processing starting October 21.
- Service standard maintenance: The CBSA’s standard of 90 days to process adjustments remains unchanged.
- Post-CARM adjustment submission: After October 21, customs adjustments must be submitted according to Memorandum D17-2-4. Form B2 will no longer be accepted.
- Duties Relief Program (DRP) reporting: At CARM Release 3 (R3), importers and trade chain partners can report Duties Relief Program (DRP) Diversions using the pre-CARM blanket process in D17-2-4.
- Penalty discretion: The CBSA will use discretion in applying penalties for customs adjustments due between September 1 and October 20, 2024, considering the guidance from this notice.
Exceptions to customs adjustments and voluntary disclosures
The changes to customs adjustments and voluntary disclosures do not apply to appeal submissions under section 60 of the Customs Act. The rule states that if a person receives a notice under subsection 59(2) regarding goods, they can request a re-determination or further re-determination of the origin, tariff classification, value for duty, or marking within ninety days of receiving the notice.
The changes also do not apply to cases where a transaction is within two months of expiry. Customs adjustments should still be submitted following the existing procedures outlined below:
- For requirements on submitting Form B2, see Memorandum D17-2-1: The Coding, Submission, and Processing of Form B2 Canada Customs Adjustment Request.
- For Blanket B2 Adjustment requests, refer to Memorandum D17-2-4: Preparation and Presentation of Blanket B2 Adjustment Requests.
- For the Voluntary Disclosure program, see Memorandum D11-6-4: Relief of Interest and/or Penalties Including Voluntary Disclosure.
- For Duties Relief Program and Duty Drawback Program requirements, refer to Memorandum D7-4-1: Duties Relief Program and Memorandum D7-4-2: Duty Drawback Program.
- For guidance on Re-determinations and Appeals Under SIMA, see Memorandum D14-1-3: Re-determinations and Appeals Under the Special Import Measures Act.
If an importer or other trade chain partner fails to make a submission by the four-year legislative deadline, their time limit will not be protected.
For more information about these changes and to ensure your full compliance, please reach out to one of our trade professionals.
