Navigating Import Challenges: A Summary Update for Canadian Importers

As global trade dynamics evolve, Canadian importers face a myriad of challenges related to regulations, compliance, and fair competition. While the Canada Border Services Agency’s (CBSA) Assessment & Revenue Management (CARM) mandate is looming, additional challenges and changes are in the minds of many Canadian importers.

Valuation for duty regulations amendments “last sale”

The CBSA is proposing significant changes to the valuation for duty regulations. These amendments aim to enhance the statutory and regulatory frameworks governing the valuation of imported goods. Comments from the trade community were received in record numbers. The CBSA acknowledged the potential impact and will respond after their final review.

AMPS valuation priorities & CBSA trade modernization framework

Administrative Monetary Penalty System (AMPS) is the CBSA’s robust enforcement mechanism. It holds importers accountable for compliance with customs regulations. As the CBSA has modernized their approach to auditing and targeting of non-compliance, importers will want to continue improving their import processes to ensure compliance is well-managed.

Enforcing prohibition on forced labor imports

The CBSA is committed to enforcing Canada’s prohibition on importing goods produced with forced labor. Traders should familiarize themselves with their reporting obligations under Bill S-211. The Act came into effect on January 1, 2024. Affected businesses must report specific steps taken to help reduce forced labor by May 31, 2024.

Safe Food for Canadians (SFC) license

Many foods imported commercially require a valid SFC license, including manufactured food sector products (e.g., confectionery, snacks, non-alcoholic beverages, grain-based foods). The SFC license ensures compliance with food safety regulations. Importers must obtain an SFC license before presenting shipments at the border. Since February 12, 2024, SFC licenses are automatically checked for imports of manufactured foods. Refer to the Canadian Food Inspection Agency (CFIA) for assistance with food commodities.

CARM final implementation dates set

CARM is a digital initiative by the CBSA that aims to modernize and streamline the import process. The transition to CARM will mean significant changes in how importers assess and pay duties and taxes on commercial goods imported into Canada. Importers must take certain steps to be in compliance with CARM Release 2 requirements, which come into effect May 13, 2024:

  • Register business with CARM before blackout dates start on April 26, 2024
  • Delegate authority to customs brokers in the CARM Client Portal (CCP)
  • Apply for a bond and establish security 

Seize the opportunity these changes bring

When navigating these and other challenges, staying informed, collaborating with industry experts, and maintaining a proactive approach are keys to your success. Remember, compliance isn’t just a legal requirement—it could become your strategic advantage in fostering sustainable growth and ethical business practices. By understanding the nuances of trade regulations, valuation changes, and compliance, Canadian importers can thrive in an ever-evolving global marketplace. 

Stay informed

Developments in customs and trade continue to evolve—stay informed to be prepared:

Brad Hogeterp
Brad Hogeterp
Product Development Manager (Canada)
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