CBSA Assessment and Revenue Management
Why do I care?
1) You likely rely on a customs broker to pay your duties and tax - that ability is going away
2) Your goods will not clear customs unless you have set up a form of payment direct with CBSA - costly delays when the time comes
Your broker will soon only still submit a declaration for you on your behalf to clear the goods, and then have to transfer the accounting of funds over to you as the importer.
They will also need to know which method you are using to set up payment so they know what to indicate when your declaration is submitted.
When this comes into force a declaration can't be submitted top CBSA without importer direct payment arrangement indicators, meaning shipments will stop!
Importers can choose a surety bond, cash, debit or credit card to manage payments in your online CARM account.
All Importers will be required to post security to participate in the Release Prior to Payment (RPP) program. They will no longer be able to use their customs broker’s RPP security to clear shipments and receive release prior to payment privileges.
As of Release 2, an importer must post security using one of the following two options to be eligible for RPP:
a surety bond for 50% of their highest monthly accounts receivable with a minimum bond of $25,000; or
a cash security for 100% of their highest monthly accounts receivable
Highest monthly accounts receivable period is the 12-month period between July 25 of the previous year to July 24 of the current year. An estimate will be permitted for importers who wish to post a bond, but do not have a 12-month history of accounts receivable
Once implemented in 2023, CARM will provide importers with access to their trade information and account balances, direct payment solutions, and a myriad of trade tools that simplify their importing processes.
Tools already available in the Client Portal:
View transaction history and statement of account
Request a binding ruling
Classification of goods
Tools coming soon:
Register for a BN business number and enroll in CBSA programs
Obtain statements of account in real time, and pay customs direct
Submit appeals and track their progress
Sign up and delegate access to your Customs broker!
In order for your broker to in any way continue to assist you with payment of duties and tax, delegation of authority at the highest level in your account is critical for the broker to obtain in order to execute payment functions on your behalf.
We recommend using a Customs broker's trade advisory services to assist you with your CARM adoption, compliance and experience, so the transition is as seamless for your supply chain as possible. If not done right, this could potentially hold up shipments in the clearance process.
Create an account and link to your business account
Assign a Business Account Manager and delegate roles (include your broker!)
We recommend that you designate at least 2 people within your organization:
A person responsible for your payments to CBSA
A person responsible for your customs processes
Any other necessary staff, and at what authority level
Delegate Authority to your Customs Broker(s)
Establish how you will pay your account:
Apply for a D120 Import Bond (recommended through your insurance provider): A bond provides importers with cash-management and convenience of paying monthly in your online portal
Other methods of payment. Choosing any of the following options means you must pre-arrange the payment of each import in your portal, ahead of the shipment arrival in Canada:
Post a cash bond
Pay via credit card
Changes to the existing RPP program will impact multiple groups:
• Importers – must secure their own duties and taxes; enroll in RPP and advise their customs brokers when they have done so;
• Security Providers – must set up business processes for issuing financial security agreements (bonds), enroll in CBSA third party program (CCP) and develop and test the electronic communication of financial security agreements with the CBSA;
• Customs Brokers – must be aware of their client’s RPP status to determine the type of declaration required for release of goods processes E.g. Can goods be released on minimum documentation (RPP Importer) or is final accounting required (pay-as-they go Importer).
How Can Importers Get Ready Before CARM R2?
1. Activate your business account on the CCP, manage your employees and delegate authority to your customs brokers (if applicable):
• Identify Business account manager(s)
• Activate your business on the CCP
• Assign roles to your employees
• Delegate authority to customs brokers
2. Determine the amount of security and the type of security your business will require:
• Estimate your financial security amount
• Research security providers to determine costing (financial security agreement)
• Determine the security option that will best suite your business, e.g. a security deposit (Cash Security) or a security agreement (Customs Bond).
Need Help Managing Your CARM Portal?
CARM Management services - Let us manage these requirements for you.
CBSA is aware of the significant investment that Release 2 represents for industry, as well as the impact that COVID-19 has had on many businesses. With the goal of shared success, and in consideration of other Release 2 pressures, the CBSA is carefully reviewing the appropriate timing for Release 2 implementation.
The release date for CARM Release 2 has therefore been moved to October 2023.