As we have previously written about here and here, the Canada Border Services Agency (“CBSA”) has been in the process of rolling out their “CBSA Assessment and Revenue Management” (CARM) project. 

Despite recent concerns over more delays, the scheduled CARM cutover period is now underway and the full functionality of the CARM Client Portal is set to be released on October 21, 2024.

Background

CARM is set to become the official system of record for imposing and levying duties and taxes on imports into Canada.  The system is designed to allow importers and Trade Chain Partners (TCPs) to interact with CBSA electronically — submitting documents, tracking payments, and ensuring compliance — all through the CARM Client Portal (the “CCP”).

The CCP was first released in May 2021 (Release 1), but the addition of features to make CARM the “official system of record” have been repeatedly delayed.  The October 2023 launch date became a “soft launch” for select industry partners to test the system. The rescheduled May 2024 launch date then became an “internal launch” (Release 2) while an “external launch” was delayed until October 21, 2024 (now called Release 3, or “CARM R3”).  A motion to recommend a further delay was discussed but voted down in a CIIT Committee Meeting on October 2, 2024. 

The Cutout Period

From October 4, 2024 to October 21, 2024, the CCP is temporarily unavailable as CBSA migrates its systems and functionality.  The “cutout period”, is also marked by the following:

1. Accounting Customs Commercial System (“CCS”) and Customs Automated Data Exchange (“CADEX”) systems are retired;
2. Payments made by brokers must now be directed to the importers’ accounts (RM15) for the payment to be transferred on October 21; and
3. Pre-Authorized Debits for September statements of account (“SOAs”) will be processed on October 21 (importers should ensure sufficient funds are available for that date).

CARM R3 Changes

The following are some of the changes that will take effect once CARM Release 3 launches on October 21, 2024 at 3:00 am ET:

1. Broker’s Security – Payments on the Broker’s account will no longer clear Importers’ debts;
2. BN & RM – Non-residents needing a Business Number (“BN”) must follow the CRA’s BN registration process, and then obtain an importer program (“RM”) account through CCP (others should obtain their BN via the CCP);
3. Accounting Documents – Electronic Accounting Documents (B3) must be submitted in the new Commercial Accounting Declaration (“CAD”) format through the CCP initially according to a set schedule;
4. Pre-Authorized Debits – Pre-authorized debits will be initiated for all existing registrants on October 31, 2024; and
5. Interest & Penalties – CBSA will not issue late accounting penalties, late payment penalties and late payment interest for 90 days following release (although CRA collection measures may apply to unpaid SOAs).

Takeaways

Importers and TCPs should be sure to prepare for upcoming changes associated with the implementation of CARM R3.  More information can be found in Customs Notice 24-29.

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