SIMA Update: CBSA Adopts CARM as the Official System of Record for Re-determinations

Importers must now use the CARM Client Portal to submit re-determination requests for antidumping or countervailing duties within the 90-day deadline and provide the required supporting documentation.

On September 19, 2025, the Canada Border Services Agency (CBSA) released a SIMA update through Memorandum D14-1-3.

The revision reflects the adoption of CARM as the official system of record for collecting duties and taxes and confirms that requests for re-determinations and appeals under SIMA must now be filed through the CARM Client Portal (CCP).

The Special Import Measures Act (SIMA) sets out the process for re-determinations and appeals following an assessment of anti-dumping or countervailing duties. 

What changed

The updated memorandum highlights the following key changes:

• The adoption of CARM as the official system of record for the collection of duties and taxes
• An exporter identification number (ID) is now required for SIMA filings

Re-determinations under SIMA

Re-determinations are the first step for importers who want to challenge CBSA’s assessment of anti-dumping or countervailing duties.

According to the memorandum, a re-determination request may cover the normal value of the goods, the export price, the amount of subsidy, the amount of the export subsidy, or whether the goods are of the same description as those set out in an order or finding of the Canadian International Trade Tribunal (CITT) or in an order of the Governor in Council. 

Re-determination requests must now:

• Be submitted within 90 days of the CBSA’s decision
• Be filed through the CCP
• Include supporting documentation

Filing a request for re-determination

The memorandum specifies that requests can be filed by the importer, their agent, or a licensed customs broker.

Before a request can be accepted, all duties owing on the goods must be paid. Otherwise, the CCP will automatically reject the filing.

To be considered complete, the following must be attached to the request:

• A statement explaining the grounds for the request,
• The facts supporting those grounds, and
• Evidence to substantiate the facts.

Additionally, importers should provide detailed information to help CBSA assess the request.

These include identifying the original CAD number and line, listing the fields and values to be corrected, and attaching the relevant invoice(s), cargo control documents, bills of lading, and permits or certificates where required.

Importers are encouraged to include contact information, cover letters, purchase records, or product samples to help clarify the case, or to provide them when requested by CBSA.

Appeal options

If CBSA issues a re-determination and the importer disagrees with the outcome, the memorandum confirms the following appeal options available:

• Appeals may be filed with the CITT
• For imports from CUSMA countries, appeals may proceed to a binational panel review

Next steps for Canadian importers

To ensure compliance, we recommend that you:

• Register and maintain your CCP account to manage filings under SIMA
• Ensure you meet the 90-day filing deadline for re-determinations
• Work with your customs broker to review documentation, ensure filings meet CBSA requirements, and support compliance within CARM

How Cole International can help

At Cole International, we provide customs and compliance consulting and customs brokerage services to help you navigate changing regulations and streamline the importing of goods into Canada.

Our team can help you with reviewing CBSA assessments, preparing the documentation required for re-determinations, and ensuring your filings are accurate and compliant. 

To discuss how we can help with SIMA re-determinations and appeals, or to confirm your readiness in CARM, please reach out to one of our trade professionals.