CARM | CBSA Assessment & Revenue Management What is CARM? | CBSA Assessment and Revenue Management CARM (or CBSA Assessment and Revenue Management) is a project by the Government of Canada aiming to simplify and streamline the process of importing commercial goods into Canada. Through CARM, the Canada Border Services Agency (CBSA) intends to modernize their accounting and data management systems to: Simplify the importing process Allow importers to manage their own trade activity Improve compliance with trade rules and regulations Increase border security CARM will affect everyone in the trade community – from importers and customs brokers to freight forwarders and carriers. Below we provide an overview of CARM, how it will affect your imported shipments, and how you can prepare for the changes. CARM Project Overview The CARM project is being implemented through two phases. The first phase, the Accounts Receivable Ledger (ARL), was implemented in January 2016. Phase 2 – the introduction of the CARM Client Portal – was scheduled to be completed by Summer 2021. However, due to the COVID-19 pandemic, the CBSA has announced that completion of Phase 2 will be delayed. Phase 1: Accounts Receivable Ledger (ARL) Implemented on January 25, 2016, CBSA’s accounting and payment system, the Accounts Receivable Ledger (ARL), introduced several important changes to payment processes, including: Replacing K84 reports with Daily Notices (DN) and Statements of Account (SOA). These daily and monthly summary statements provide details on your import activity, such as payments made, interest owing, refunds issued, etc. The ability for importers to receive DN and SOA statements electronically from the CBSA, either directly or through your Customs Broker. The ability for importers with a BN15 (Import/Export RM account) to make payments through online banking. Phase 2: Introduction of the CARM Client Portal Phase 2 of the CARM project will introduce an online self-service portal for importers and will be rolled out through three releases: Release 0 Release 0 will have no impact on importers. During this release, CBSA will migrate the existing ARL system into the CARM software. Release 1 Additional features will be added to the CARM system, including the introduction of the CARM Client Portal. In order to import, all businesses must obtain an Import/Export account. Once you obtain your BN account you may then access the portal. The Client Portal will offer online self-service tools, allowing importers to manage their own accounts, access their Daily Notices and Statements of Account, view their amounts owing, and make online payments to CBSA. Release 2 Registration to the CARM Client Portal will be extended to all trade community members. New functions and tools will be added, including an electronic Commercial Accounting Declaration (CAD) to replace the current B3-3 Canada Customs Coding Form and B2 Canada Customs Adjustment Request Form. Added features for invoicing and payments will allow importers to make corrections and adjustments to their import accounts. Once fully functional, the CARM Client Portal will give importers the ability to: Manage their own import account View Daily Notices and monthly Statements of Account Delegate service providers (e.g. PF Collins) to conduct import transactions on their behalf Pay duties, taxes, and fees directly to CBSA File corrections or adjustments Apply for temporary import permits and advance rulings Prepare and submit Commercial Accounting Declarations (CAD) How Will CARM Affect Importers? CARM will present significant changes for businesses importing commercial goods into Canada. Once the CARM Client Portal is released, it will be mandatory for all importers to register their business number and set up an account. Importers must delegate access to their Customs Broker and all other service providers. The level of access is determined by the importer within the portal. Importers must delegate internal profiles and levels of accessibility. All importers must secure their own duty & GST customs bond. If an importer does not secure a duty bond, payment of the duties & taxes must be received prior to release of the shipment. An importer will no longer be able to use their Customs Broker’s bond. Under CARM, the liability and financial risk for duty and tax payments will transfer to the Importer of Record. CARM will also present changes in the ways in which accounting data is submitted. The new Commercial Accounting Declaration (CAD) will require systems changes for importers who transmit data using their own customs software. For importers using a Customs Broker to obtain release and declare the accounting information, no customs software is required. As part of Phase 2, CBSA plans to introduce new billing cycles for the payment of duties, taxes, and fees. Changes to payment due dates and data submission deadlines will require changes to the importer’s internal accounting processes and/or other procedures. For these reasons, we recommend understanding the requirements of CARM and taking the following steps to make the transition easier and avoid delays with your shipments. Preparing for CARM 1. Obtain a Customs Bond A customs bond is required by CBSA to cover all duties, taxes, and fees owing on goods imported into Canada. The bond amount must cover the full duties/taxes payable within the highest month. The importer cannot exceed the amount of their bond without increasing their bond amount. Without providing financial security through a customs bond, duties and taxes must be paid prior to clearance. Customs bonds may be purchased from a surety company or arranged through your Customs Broker. Under CARM, it is expected that the required bond amount will be based on the importer’s highest historic monthly total of duties, taxes, and fees. This amount can be estimated based on your previous 6 month import period. When registering your bond within the CARM portal, CBSA will notify you if the bond amount is not sufficient. If you need assistance in applying for a customs bond, please contact our Customs Consulting Department at (709) 726-7596 or [email protected]. 2. Register for the CARM Client Portal CBSA has advised that a CARM Client Portal account is required for all importers and failure to register and provide security by way of a customs bond or deposit will result in shipments being denied entry at the border. While the CARM project is experiencing delays due to the COVID-19 pandemic, the CARM Client Portal is tentatively scheduled to go live in early 2021. We highly recommend registering for your account as soon as it becomes available to avoid potential backlogs when large numbers of importers begin to register. We will provide an update once the portal becomes available for registration. You may also subscribe to receive CARM information directly from the CBSA by emailing CARM Engagement at [email protected]. 3. Delegate Authority to Your Customs Broker Once registered to the CARM Client Portal, you will have the ability to provide access to your Customs Broker and other service providers (e.g. couriers) to manage your import activity on your behalf. This will require some planning as to what activities you will delegate to each service provider and what features they will have access to. If you require assistance in determining what import activities we conduct on your behalf, please contact our Import Department at (709) 726-7596 or [email protected]. 4. Review Your Business Processes With responsibility for managing the import account moving to importers, CARM will not only change the way you manage your imports but will also require planning as to changes that need to be made to your business processes and/or employees assigned to those processes. Questions to consider include: Who will manage the CARM Client Portal? Is your bank setup to receive and transmit payments to CBSA? Who will be reviewing your Daily Notices and Statements of Account? What changes will need to be made to your accounting practices to meet CBSA payment deadlines? For More Information We will continue to monitor CARM’s release status and provide updates as they become available. In the meantime, please visit CBSA’s CARM website for more information or subscribe to the CARM Engagement newsletter.