The Q&A lists questions arising from recent CARM delay, cutover & implementation in October 2024. If you don't find an answer to your question here, email us at [email protected].
Category | Question | Answer | Updated |
| Business number usage | Importer of Record Regulations – the CARM 12-month transition plan allows for the use of the brokers BN for twelve months from CARM R2 implementation. The IOR regulations are said to be coming in to force in January 2025. With the CARM R2 implementation being delayed until October, can you confirm that the IOR Regulations will not come into effect until at least October of 2025? | The section 17 amendments will remain inactive until a date is affixed by order of the Governor in Council. The requirement to have an order of the Governor in Council fixing the coming into force date is reflected in section 331 of Budget Implementation Act, 2022, No. 1. It remains the intention of the CBSA to provide a one-year transition period following the CARM external release before enforcing the updated liability provision. | June 6 |
| Business number usage | What is the difference between the “declarant” and “the use of broker BN15”? Which broker BN15 can be used for the one year transition time when we account for a transaction using our business number? Do we have to create new Broker BN15 for this transition plan accounting purpose or use our customs broker business number that was assigned when we registered in the CCP? | Brokers do not need to obtain a new BN15 for use to obtain release and account for goods during the transition period. They may continue to the same BN15 number to clear and account for these shipments as they do today. Of course, they will need to ensure that the specific BN15 has been registered in the CARM Client Portal. However, the RM that was created solely so that the broker can log into the CARM Client Portal as a broker should not be used for any transactions. If brokers need a new importer type RM(s) for the one-year transition (if they need a new one to track separately from their other importer RMs, for example), this would be their business decision. They should plan to close it when the transition year is up. | June 6 |
| Business number usage | Will a customs broker have liability if they use their BN during the 12 month transition period? | The Transitional Measures for the use of the Broker BN states that for a 12-month transition period, the use of broker BN15 will be allowed under specific scenarios. This will be communicated again in a revised Customs Notice to be distributed well in advance of our October external launch date. Additionally, CBSA has communicated that once importer of record comes into force it will not be applied retroactively. | July 19 |
| CSA | Should CSA clients continue to self-assess by by transmitting B3s, adjustments (x-types) and RSFs to the CBSA as per the current procedures? | Phasing in CARM for Customs Self-Assessment Importers | May 8 |
| CSA | Should CSA clients use its current Accounting Options, transmit the RSFs and make payments based on its current procedures. | Phasing in CARM for Customs Self-Assessment Importers | May 8 |
| CSA | Can CSA clients continue to account for releases from April 19 to May 18 by May 31, transmit the May RSF by May 31 and pay by May 31st? | Phasing in CARM for Customs Self-Assessment Importers | May 8 |
| CSA | Can CSA clients account for the entries of April 17 and April 18 by May 31 and include them on its May RSF. | Phasing in CARM for Customs Self-Assessment Importers | May 8 |
| CSA | Will Late Accounting Penalties automatically be waived for releases for the period April 1 to April 18 for CSA importers? | Phasing in CARM for Customs Self-Assessment Importers | May 8 |
| CLVS | CLVS Recap: What is needed, by whom (carrier vs broker), and how do we submit large files? | The CBSA has provided TCPs a draft RECAP sheet and is currently reviewing the comments received. The CBSA will communicate broadly with TCPs once a decision is finalized. | July 19 |
| Future enhancements | What activities does the CBSA intend to carry out between now and October 2024 to address deficiencies and gaps in policy and process to ensure a successful implementation as per the concerns of trade chain partners? Example temporary imports and one time bonds. | We will be engaging Trade Chain Partners further on this. | June 6 |
| Future enhancements | What “enhancements" will the CBSA now be able to accommodate for the October release? | The October release will include some repairs to critical impairments that will not require technical changes by Trade Chain Partners. | June 6 |
| Future enhancements | Will the CBSA entertain changes to the registration process now that there is additional time before go-live, and to encourage importers to register? | There are currently no projected changes to the registration process. We currently have well over 80,000 TCPs registered on the CARM Client Portal, and support mechanisms are still in place to ensure that clients continue to register if they are experiencing any issues. | June 6 |
| Future enhancements | Will there be additional functionality available in the CCP between now and the October implementation? | There will be no additional functionality available in the CARM Client Portal between now and the October implementation. | June 6 |
| Future enhancements | Can you confirm that the planned enhancement for complex Mass Adjustments will be available in the CARM Client Portal as of R2 in October 2024? | The planned enhancement for complex Mass Adjustments will not be available in October. | June 20 |
| Implementation | Is there a new timeline for the closure of the CRA BN support desk? | I do not have information beyond what is in CN24-18: Customs Notice 24-18: CARM: Changes to the Registration and Maintenance of Program Accounts for Importers and Exporters (RM). | June 6 |
| Implementation | Will the CRA continue assisting customs brokers with account-based questions between May and the October 2024 CARM implementation? | The Canada Revenue Agency will continue to address BN questions. The CBSA will address RM program questions. Please refer to the revised Customs Notice 24-18: CARM: Changes to the Registration and Maintenance of Program Accounts for Importers and Exporters (RM). Please note that RM inquiries should be sent to: [email protected]. | June 6 |
| Implementation | Can a new commercial importer apply for a business number in the CARM Portal starting May 13th or will they follow the current methods (such as having their customs broker fax or call the CRA Business Tax center) | New commercial importers should refer to Customs Notice 24-18: CARM: Changes to the Registration and Maintenance of Program Accounts for Importers and Exporters (RM). | June 6 |
| Implementation | What is the actual date of implementation in October? | The external launch of CARM will be on October 21st, 2024 | June 6 |
| Implementation | Will there be a cutover (blackout period) in October or before as was planned for the May 13th implementation? If so, will it be of the same duration of time? | Yes, there will be a cutover over period. More information on this will be communicated at a later date. | June 6 |
| Implementation | Will CBSA still require the black-out period from April 26th to May 13th for them to launch CARM internally? | No | Apr. 25 |
| Implementation | Is the CBSA going to send an email to all importers currently registered on the CARM portal advising them of the delay in implementation so there is no confusion and duplicate payments to the RG at the end of May. | The CBSA had sent Trade Chain Partners emails, via our engagement distribution lists, about the Customs Notices issued since the announcement about the external release on April 19th:
| June 6 |
| Implementation | Will Customs Notices CN 24-14 (Preparing for CARM Release 2 Implementation, Transition Measures) and CN 24-15 (Preparing for CARM Release 2 Implementation, Cutover Period) that have been cancelled be re-published with updated information in ample time for planning for the October 2024 go live? | Yes. The cutover (blackout) period will be formalized or communicated through a Customs Notice (CN) that will be published sometime the week of August 26th. As with other CNs that are being published, we will share an advanced copy with our (small) TCP working group. | Aug. 20 |
| Implementation | CBSA advised that they will launch CARM 2 internally on May 13, 2024. What exactly is being launched and what does it entail? | This information is explained in CBSA’s April 19th News Release (toward the bottom of the news release): CBSA phasing in CARM: launching internally for CBSA use as planned in May and later in the fall for trade chain partners - Canada.ca | June 6 |
| Implementation | Will the CBSA provide a complete transition plan to TCPs 90 days before the implementation date? | A transition plan will be shared shortly, the principles continue to be free flow of goods and not penalizing clients for the CARM implementation. | July 19 |
| Other | Will the CBSA be issuing notice of exception to the due dates for payment for the remaining months between May and October 2024? | Yes Payment date exceptions for 2024 | Apr. 25 |
| Other | Can we have an Exchange API available before going live so we can compare it to the current Cadex file and get confident on the tool before we can use it exclusively when Cadex is shut down. Exchange rate is on the CAD - not duty rate or GST. | An Exchange Rate API is available https://www.cbsa-asfc.gc.ca/eservices/api/er-tc-api-eng.html | July 19 |
| Other | Can voluntary entries continue to be submitted paper between now and October 2024 when CARM R2 is implemented? | Yes | Apr. 25 |
| Other | Will TCP meetings that were occurring before the delay in external CARM R2 announcement recommence in the near future? | We are in the midst of evolving our engagement approach. We will be in touch with our TCP community soon to share more information. | June 6 |
| Other | When CARM R3 is implemented will a customs broker be able to use their transaction number on a C Type? | The CBSA is aware of the issue and is looking to address, however until resolved, the transaction number of c-type CADs on the portal will need to be left blank and a system generated number will be created. | July 19 |
| Other | Can an importer retrieve a CAD if the customs broker sent it to the CBSA via API? | CADs will be available to the importer via their portal account, irrespective of who submitted it and how. | July 19 |
| Other | When brokers do mass adjustments or voluntaries on the IOR portal, even if broker does it, they don't get the transactions on their SOA. Can there be a broker identifier on TCP SOA? | CARM moves to an importer account based model and moves away from tagged transactions. Brokers will receive the Customs Broker Summary Statement with their client details. | July 19 |
| Other | CARM’s Books and Records (B&R) Requirement will stop shipments at the border, is the CBSA willing to make changes to avoid this? | This is a policy question - however not a new requirement either, CARM just brings rigour. | July 19 |
| Other | Will importers be supported at the border when they arrive and are required to do a Type C in the CCP? Will they be required to do Type C in the portal or will a manual Type C be accepted? | Ports of Entry employees will be trained to ensure that Type C entries are processed at the border. Paper type C's will be accepted under exceptional circumstances. | July 19 |
| Other | How will CBSA handle the increase in volume of Help Desk requests after R3? CBSA needs to create two lanes for the CCSH. One for brokers/service providers and one for importers. TCPs shouldn’t have to wait weeks for urgent issues to be resolved. | The CBSA has a 10 day service level standard, and the CBSA routinely meets it. More complex cases may require more time to resolve. | July 19 |
| Payment | For importers who make payment with PAD withdrawal, what date will the April SOA be withdrawn on? | April 30th, 2024 | Apr. 25 |
| Payment | Can you confirm if the May SOA’s will be importer tagged? | It will not be importer tagged until the October SOA | May 8 |
| Payment | Can CBSA confirm what Importers are to do that have already set up CARM PAD to take effect in May via the Portal? Do they have to go into their portal account and terminate those PAD agreements, or will they simply not be triggered? | If they are set up a PAD in the CARM Client Portal to take effect in May the importer must make a change of the effective date or else the PAD will be triggered for the May date if that is how it was set up. | May 8 |
| Payment | When an importer uses multiple brokers, will the TCP know how to find what is owing, will they have the back up to pay? | Importers (including SMEs) should review their SOA and account balances on their CARM Client Portal Account to confirm what they owe to the CBSA, and talk to to their brokers about their payment option to ensure that they are paying the correct amount, and they are not paying twice. Similar messaging is also provided on our website, and further information on making payments here: https://www.cbsa-asfc.gc.ca/prog/arl-glcc/pay-paie-eng.html#t2023 | July 19 |
| Payment | Will the CBSA expand NRI payment options? The recent removal of Visa / Mastercard debit as a payment option further limits NRI’s | NRIs are advised to contact the CARM Financial Services team to discuss payment options, as well as suggest additional banks to be added to accepted banks. The request can be submitted using the client support contact form. | July 19 |
| Refunds, Blankets, Drawbacks, V Types | Will CN 24-10 (Termination of the temporary electronic procedures for Canada Border Services Agency's Trade Programs (COVID-19) – GTA Pilot) be reinstated with the announcement of the delay of CARM R2 until October 2024? | The pilot was implemented to facilitate the receipt of paper B2s during the pandemic. Pandemic restrictions have been lifted so GTA is back to pre-pandemic paper processing. B2s can be submitted in accordance with the Customs Memorandum D17-2-1, The Coding, Submission and Processing of Form B2 Canada Customs Adjustment Request (Paragraphs 15 and 16 relate to submission of B2s). The CBSA has advised us that the pilot project will not be re-opened. | May 9 |
| Refunds, Blankets, Drawbacks, V Types | With the cancellation of CN 24-11 is it business as usual when it comes to the submission of Refunds, Blankets, Drawbacks and Voluntary disclosures? | Current state processes remain in effect. The GTA pilot project will not be re-opened as the CBSA focuses on CARM activities. | May 9 |
| Refunds, Blankets, Drawbacks, V Types | Mass Adjustments: There is no interim solution from now until R3 in October 2024. The current proposed workaround of individual CAD versions will require increased staffing and significant additional cost to industry. TCP’s require details to plan accordingly. There is an interim solution, but it is limited to 100 transactions. We have requested that CBSA change that criteria to 100 commodity lines, because we have 5000 line entries that cannot be adjusted in the portal. Has the CBSA made a decision on this? | The CBSA is currently reviewing the criteria for mass adjustments and the multiple suggestions proposed by numerous stakeholders. The CBSA will communicate broadly with TCPs once a solution is finalized. | July 19 |
| Registration | After what period of time does a CARM account get suspended for inactivity? | Accounts do not get suspended after 180 days anymore. Clients can be locked out of the CARM Client Portal if during registration they answer the questions wrong 10 times. Also, clients who have registered over 2 years ago, and not signed in to their accounts since, have had their GC key expired because it’s been over 24 months since they last signed in. There is no way to recover it and they have to create a new one. | June 6 |
| Registration | How will the CBSA address the delegation issues that may result from the additional delay (i.e. outdated BAMs; people changing firms, etc) | Businesses should continue to keep their Delegation of Authority updated. | July 19 |
| Registration | After what period of time does a GC Key get revoked for inactivity? | After 24 months of inactivity | Apr. 25 |
| Registration | Will the CBSA explore allowing customs brokers to contact the CCSHD on behalf of the importer to seek assistance with registering with the appropriate authorization that can be agreed upon between CBSA and customs brokers? | Please stay tuned for a response on this. | June 6 |
| Registration | How is the CBSA addressing portal access requirement for multiple emails and GC Keys for multiple BN9 accounts? | This is a known concern, however is not a simple fix and represents a significant effort/redesign. This, as well as other industry requests will be reviewed for prioritization as future enhancements. | July 19 |
| Registration | Language barriers and time zones differences will drive delays and raise costs during onboarding and registration. Will the CBSA develop multi-language CARM communications for top 10 countries by import volume. | We are exploring this suggestion with our communications division. | July 19 |
| Registration | Trade would like the ability to API the status of Registration, RPP and DOA for all importers to keep commercial shipments moving and avoid inefficiency, the Express Carriers require the Importer’s CARM status prior to release, via API. Will this request be implemented? | This is a known concern. This, as well as other industry requests, will need to be reviewed by industry for prioritization. | July 19 |
| Registration | To file an entry in the portal, custom broker associates are required to either have BAM access to the broker BN, or the broker needs to individually add each associate to each client BN separately for them to be able to file anything under that BN. This can be an internal compliance issue as customs brokers may not want to provide every associate with access to an importer portal. Is there a solution for this? | This question involves a number of factors. For access for employees to multiple clients, please consider the client group functionality of the portal, this will avoid individual steps for each employee and client account. The CBSA is able to review audit logs of users, and if there is an issue, the company can work with CBSA to gain access to this level of information on a case by case basis. | July 19 |
| Financial Security | For importers who have existing RPP bonds; how and when will they be notified to increase their bonds? Does this fall under the 180 grace period? | The highest monthly amount of duty and taxes from the previous 12 months will display in the CARM Client Portal when the importer logs in to the portal in CARM R2. If the importer is required to increase their bond they will have the 180 day grace period to do so. | May 8 |
| Financial Security | When an importer logs into the portal on day 1 of Release 2 in October and sees the highest amount of their duties and taxes of the previous year, will the period of the calculation be that of October 2023 - October 2024? | Yes that will be the period of calculation that they see. Going forward from that date when an importer registers in the CARM Client Portal the prior 12 months will be the calculation period. For example if an importer registers in the CCP in December 2024 the calculation period will be December 2023 – December 2024. | May 8 |
| Financial Security | Will the current regulations remain in place with regard to the amount of RPP Financial Security that a customs broker must have secured? | Yes, until CARM R2 is implemented in October 2024. | May 8 |
| Financial Security | In preparation of CARM R2 which was supposed to be implemented in May 2024, transactions that were released on April 18th and April 19th may have been transmitted to the CBSA with an I indicator to ensure that the payable from the importer was to the Receiver General in May and not to the customs broker. Will this cause any problems? | The CSCB has informed the CBSA of these occurrences and will advise if there is further communication from the CBSA. | May 8 |
| Financial Security | In the interim period until CARM is fully operational in October 2024 – will the CBSA consider allowing B3 transactions to be submitted with an I even if the importer does not have a RPP surety bond in place to help transition importers to the importer tagged SOA? | The CBSA will not consider allowing the use of the ‘I’ indicator for any importer other than those with valid financial security. The existing requirements of the Release Prior to Payment (RPP) program and the conditions for use of the Importer Direct Security option remain in effect until CARM becomes the official system of record for accounting and payment of duties and taxes on imported goods. Following the implementation of CARM in October 2024, importers will benefit from a transition period of up to 180 days to make their own financial security arrangements. | June 6 |
| Financial Security | Will surety companies be able to transmit RPP bond data by API prior to October or will paper bonds still need to be submitted to the CBSA. | Surety companies cannot submit RPP bond data by API prior to the implementation of CARM Release 2 in October. Yes, paper bonds will still be accepted until a cutoff date is announced closer to the October 2024 implementation date. | May 8 |
| Financial Security | If paper bonds still need to be submitted, will Direct Security Letters still be required? | Yes | Apr. 25 |
| Financial Security | Does the CBSA recommend submitting paper bonds between now and October? | The CBSA continues to recommend that brokers and importers alike wait until the CARM Client Portal is fully functional and submit financial security through it at that time. | Apr. 25 |
| Financial Security | Will customs brokers who lowered their RPP security in anticipation of CARM in May need to increase it again? | Customs Brokers Release Prior to Payment bonds are lowered upon CBSA audit and when a customs broker can substantiate the need for lowering the bond such as additional importers on the Direct Security Program. Any requests to lower bond amounts between now and October 2024 must be sent to the CBSA as is the usual practice. Until October implementation the current regulations for bond amounts remain in place. | May 8 |
| Testing/Certification | Can CBSA confirm if there will be another round of CARM CES testing that will be opened to NEW participants? | CARM Experience Simulation (CES) 2.0 activities ended in March 2024 and the CBSA does not plan to have additional CES activities prior to our CARM external launch date in October 2024. The CARM testing environment will continue to be available to service providers and software developers for their testing and certification activities after May 31st. | June 6 |
| Testing/Certification | Will the test system go down between now and October 2024 or can this time be used to continue certification/testing? | The CARM testing environment will be supported and available to TCPs to continue their testing and certification activities until May 31, 2024. | May 8 |
| Testing/Certification | Will the testing/certification process be supported by the CBSA? What will your priorities be? | The CARM testing environment will be supported and available to TCPs to continue their testing and certification activities until May 31, 2024. | May 8 |