Link: https://www.cbsa-asfc.gc.ca/publications/cn-ad/cn25-16-eng.html
Ottawa, April 10, 2025
1. On February 26, 2025, the CBSA issued Customs Notice 25-08: Overdue Releases/Missing Final Accounting to remind trade chain partners (TCPs) of the requirement to submit their final accounting following release and that failure to do so may lead to the issuance of Late Accounting Penalties (LAPs) per individual overdue transaction.
2. Since the issuance of CN25-08, the CBSA has been sending overdue notices to brokers and importers. Many brokers and importers responded by submitting the Commercial Accounting Declarations (CAD).
3. In instances where it is clear that no action has been taken to submit CADs or to resolve any system issues via Client support contact form, the CBSA is issuing LAPs, followed by the assessment of duties, taxes and interest for transactions where the final accounting is missing. The specified interest rate is applicable.
4. Discussions with brokers highlighted some reasons why CADs are not submitted:
importer has not registered on the CARM Client Portal (CCP)
broker obtained release of imported goods but cannot submit final accounting as the importer has not completed a delegation of authority (DOA) in the CCP so that their broker can submit and view final accounting
5. Final accounting and payment of the duties and taxes, are the responsibility of the importer or owner of the goods. Subsection 2.2(1) of the Accounting for Imported Goods and Payment of Duties Regulations requires accounting by electronic means. Registering in the CCP allows the TCP to maintain the ability to import and pay duties and taxes owing by submitting their accounting or providing their broker with the DOA to be able to submit accounting on their behalf.
6. In order for a service provider such as a broker to transact on behalf of an importer, a business relationship must first be established.
7. An importer has the ability to delegate authority for various roles in the CCP. The user roles define which actions individual users can take within given business and program accounts, as well as their visibility attributes (what information each user can see). Refer to User guide: Delegation of Authority in the CARM Client Portal.
8. Registering in the CCP is an essential component to continuing to import goods into Canada. It is the same as signing-up for personal banking or accessing income taxes on the Canada Revenue Agency (CRA) portal. As well, all communications by the CBSA relating to assessment, adjustment, verification and collection will be communicated via the CCP. If you are not registered on the CCP, follow the User guide: First time set up – Register my business scenarios.
9. The CBSA will use the CCP to post duties, taxes and interest owing on overdue transactions that are missing the final accounting. Importers that are not registered on the CCP will not have access to their statement of account for payment. Unpaid accounts will be sent to the Canada Revenue Agency for collection activities.
10. Importers have until 3 am EDT on May 20, 2025, to post their financial security in the CARM system. Importers who do not post financial security in CARM by May 20, 2025, will no longer be able to benefit from Release Prior to Payment (RPP) which allows goods to be released electronically and before paying duties and taxes. Without RPP, importers will be required to be complete a C-Type CAD in the CCP and pay applicable duties and taxes before goods can be released. Registration to the CCP is required in order to complete the C-type CAD.
11. Be reminded that a CAD presented after the prescribed period to account and the payment due date will show up as overdue on the Statement of Account and subject to penalties (late accounting/late payment and any applicable interest). As such, an importer may find that their account is sent to CRA for collection when a CAD is accounted more than 31 days after the date of release.
Additional Information
12. For more information call the Border Information Service (BIS) at 1-800-461-9999 (toll-free in Canada and the USA). If calling outside Canada and the United States, call 1-204-983-3500 or 1-506-636-5064. Long distance charges will apply. Our automated telephony service provides general information in English and French on CBSA programs, services and initiatives through recorded scripts. Live agents are also available to assist you Monday to Friday 8 am to 4 pm local time, as per time zones in Canada and USA (closed on federal statutory holidays). TTY is also available within Canada: 1-866-335-3237. Alternatively, you may send your enquiries using our Client support contact form.
Related Links
Customs Act
Accounting for Imported Goods and Payment of Duties Regulations
Memorandum D17-1-5: Accounting for Commercial Goods
Memorandum D17-1-8: Release Prior to Payment Privilege