April 19, 2024 | Circular No. 11661

Dear Member,

Further to our previous communications on this subject, this is a reminder that CBSA’s new electronic assessment and revenue management system (also known as CARM) will come into effect on May 13, 2024.

As of that date, CARM will become the official system of record that importers and other trade chain partners will have to use to account for imported goods and pay the related duties and taxes. Additionally, the CARM client portal will become CBSA’s centralized system of record for trade chain partners to register their CBSA account and enroll in various CBSA programs, including the “release prior to payment” (RPP) program.  As relates to the RPP program specifically, once CARM comes into effect, importers will no longer be able to use a broker’s  security to obtain the release of imported goods before paying duties, and will have to post their own financial security through the CARM client portal if they want their goods to be released before the payment of duties.

Please refer to Customs Notice 24-15 for additional details on the above, including the transitional measures that CBSA has developed to ensure continued border fluidity and timely submission of accounting and payment of duties after May 13.

CARM Impacts on Marine Carriers

Although most of CBSA’s outreach on CARM has been focused on ensuring that importers and their brokers fully understand the new requirements, CARM will also have implications for marine carriers and agents.

More specifically, if a marine carrier performs the functions of an importer (i.e. they are listed as the “importer of record” on the shipping documentation), they MUST register for the CARM portal and obtain their own business number and bond, as the carrier will no longer be able to use their broker’s business number or bond for such activities.  As an example, if a ship is carrying spare vessel parts for import, it is the carrier who will have to register in the CARM portal in order to arrange for the payment of duties and taxes, and obtain release of those goods.

Given the above, we strongly encourage any member who anticipates they will be importing goods in the next several months to take the necessary steps to register in the CARM portal at the earliest opportunity.  Detailed registration instructions can be found at this LINK (but please note that the CARM portal will not available from April 26 to May 13 as it will be undergoing final system updates).

Another important point to note is that CARM will ultimately become the centralized portal through which stakeholders will register in various CBSA programs, submit applications, and settle invoices, including those related to penalties. Although it is our understanding that the current paper process for issuing notices of penalty assessment and collecting payment will remain in place for the time being, these functions will eventually migrate to the CARM portal.  Similarly, CARM will ultimately become the portal through which carriers will have to apply for a carrier code (as the current paper-based process will eventually be phased out) – although we are still awaiting clarification regarding the timing of when this will occur.

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We will continue to provide updates on the implementation of CARM as new information becomes available, particularly as relates to potential impacts or changes to marine carrier operations. In the meantime, members with questions regarding any of the above should contact the undersigned.

Sincerely,

Karen Kancens
Vice President