CBSA Assessment and Revenue Management (CARM)

All companies must be registered with CARM to import products into Canada on or before the Release 2 roll-out, set for October 2024.

All trade chain partners that conduct commercial business with the CBSA will be required to register and link their business on the CARM Client Portal by Release 2.

CARM will offer many efficiencies to importers, including automating processes and providing greater visibility into systems. Additional online tools for the classification of goods, electronic filing of ruling applications and making adjustment requests will also be available via the CARM Client Portal.

CARM will allow the trade community to:

• Submit online electronic declarations
• Access tools to classify goods and calculate duties and taxes
• Make payments and view up to date account information
• Become paperless by default

Release 0: Nothing. Release 0 has no direct impact to importers.

Release 1

Importers will need to create a user account and set up their business on the CARM Client Portal to take advantage of the new self-service tools the portal offers. At present, you may also:

• Delegate authority to your customs brokers and other service providers to conduct business on your behalf.
• Post financial security directly on your accounts to take advantage of Release Prior to Payment (RPP) privileges. Starting after Release 2, brokers will no longer be able to secure client accounts with their security. To facilitate this, various options will be available, including posting a cash or electronic bond.

Release 2

This is the final release for the implementation of CARM. Once launched, all further import processes will be handled in the CARM Client Portal. At present, you will:

• Begin using the new electronic form called the Commercial Accounting Declaration (CAD). This will replace the existing customs coding (B3) and adjustment request (B2) forms.
• Expect a new billing cycle to harmonise payment due dates for all transactions and simplify the ways accounting information can be corrected and adjusted.

The CBSA has the most thorough information about upcoming CARM changes available on their website.

• CBSA Portal Link: CBSA CARM Client Portal
• CBSA Video: CBSA CARM Introduction Video

The CARM Client Portal will provide two levels of administrative access:

• Business Account Manager (BAM) - primary
• Programme Account Manager (PAM) - secondary admin

Business Account Managers have the responsibility of approving and setting up employee access to the business and programme accounts. Before access to the business or programme account is granted, each employee must first set up their own personal user account in the portal and request access to be added to the business account.

With the CARM Client Portal, the log in has changed from broker to importer RM extension.

Both BAM and PAM users have the administrative authority to manage business relationships and add brokers and consultants.

Note that delegation within the CARM Client Portal does not negate the need to maintain a General Agency Agreement with your customs broker.

The process for accounting for imported goods into Canada will change when CARM introduces the Commercial Accounting Declaration (CAD) with Release 2. The CAD is a digital document that will replace the existing Canada Customs Coding Form (B3) and Canada Customs Adjustment Request (B2) documents.

This shift will adopt a World Customs Organisation (WCO) compliant data model and will help with version control as changes occur to better retain an accurate historical record. Version management in the CAD creates a single accounting declaration of record, eliminating the requirement to account for submissions and changes on separate document types.

Corrections may be made up until the payment due date, after which time any changes or corrections made to the CAD will be considered as adjustments.

Mass adjustments can be used to bundle two (2) or more changes to information.

In Release 1 of CARM scheduled for May 2021, the CBSA will introduce a case management functionality for rulings. Rulings can be applied for online.

Details on filing a CAD for drawback purposes are limited at present. It’s understood that a drawback will be considered as a mass adjustment. Further details and clarity on drawbacks will be available soon.

At Release 1, the CBSA will enable electronic payment options to include:

• EDI transmission
• Pre-authorized debit (PAD)
• Debit/credit card payments, up to the defined limits
• Cheque or money order made out to the Receiver General of Canada
• Cash

At Release 2, CARM billing cycle changes come into effect. The introduction of new billing cycles and an alignment of payment due dates will address current complexities concerning debt management for businesses and ease the administrative burden of managing this process.

The following billing cycles will be affected by CARM:

• High value deliveries (HVS)/Low value deliveries (LVS)
• LVS goods released in the regular commercial stream will follow the standard HVS billing cycle
• Courier low value deliveries (CLVS)
• Continuous transmission commodities (CTC)
• Customs self-assessment (CSA) programme

Also upon Release 2, financial statements will be issued via the CARM Client Portal and to EDI certified account holders and customs brokers via EDI in XML format.

The customs broker and importer will receive daily notices via the CARM Client Portal and/or EDI for the transactions they have accounted for on behalf of their clients. The customs broker can view their client’s transaction information in the portal only if delegated to do so by their client.

Starting with Release 2 of CARM, statements of account will be issued to all trade chain partners that have incurred a financial transaction with the CBSA on their own account. With the implementation of CARM, the statement of account will no longer be transaction-based and will instead be account-based to provide a summary of all transactions recorded in the billing period.

The SOA will be issued at either the Programme Account (BN15) or legal entity/Business Account (BN9) levels, depending on the offsetting option.

• Programme account offsetting: One statement of account per BN15 (one per programme account). Credits within a programme account can only offset debits on the same programme account.
• Programme type/intra-programme offsetting: One statement of account per programme type (i.e., can group many BN15s).
• Legal entity/inter-programme offsetting: One statement of account per BN9 (one per legal entity).

Security may be posted in the form of a cash bond, a (continual) surety bond or a one-time single-entry bond. Without RPP security, you will be required to pay in advance on the CARM Client Portal.

The posted financial security will secure all accounts payable, including duties and taxes (GST), as well as interest, adjustments, ascertained forfeitures and SIMA fees. The bond will secure any penalty fees.

The amount of the security required for non-cash bonds must be equal to or greater than 50% of the importer’s highest monthly accounts payable to the CBSA within the most recent 12-month period. The bond amount is also subject to a $25K minimum and $10M maximum.

Release Prior to Payment (RPP) financial security will be set at the importer level as of CARM Release 2.

The release prior to payment programme allows participants to obtain the release of goods from CBSA before the final accounting and payment of duties and taxes. If the Importer of Record (IOR) has not posted security in the RPP programme, you must pay cash per delivery at the port of clearance the deliveries will arrive at.

There are three options to post security:

1. Purchase a continual bond through a surety company or through your customs broker.
2. Post a deposit of cash in the CARM Client Portal (CCP) account. Posting a cash deposit is not possible until CARM Release 2 goes live.
3. Purchase a time-limited bond through a surety company or through your customs broker.

A continual bond guarantees payment and allows the goods to be released from customs control prior to the payment of duties and taxes.

The RPP bond must be obtained from a surety company or through your customs broker. To get assistance with purchasing a bond, contact us.

To calculate the value of the surety bond CBSA will use 50% or more of your highest monthly accounts payable to the CBSA within the most recent 12-month period. The bond is subject to a minimum of $25,000 per RM account and a $10 million maximum. There is an annual cost to the bond.

The value of the cash deposit is equal or greater than 100% of your highest monthly accounts payable to the CBSA within the most recent 12-month period.

This money is not to be used to pay down your monthly debt to CBSA. It is a deposit to provide security to your CARM account and will only be refunded upon request. CBSA will review and if there is no debt owed to your CARM account after a couple of months, CBSA will refund the money. Posting a cash deposit is not possible until CARM Release 2 goes live.

With CARM Release 2, you will no longer be able to use your customs broker's RPP security to clear deliveries before paying duties and taxes. Importers that want to participate in the RPP programme will be required to post their own financial security.