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CARM Q&As

(Questions arising from CARM delays, cutover & implementation in October 2024)

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Question

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Updated

Business number usageImporter 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?We do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
Business number usageWhat 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?We do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
CSAShould 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 ImportersMay 8
CSAShould 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 ImportersMay 8
CSACan 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 ImportersMay 8
CSACan 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 ImportersMay 8
CSAWill 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 ImportersMay 8
Future enhancementsWhat 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 do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
Future enhancementsWhat “enhancements" will the CBSA now be able to accommodate for the October release?We do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
Future enhancementsWill the CBSA entertain changes to the registration process now that there is additional time before go-live, and to encourage importers to register?We do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
Future enhancementsWill there be additional functionality available in the CCP between now and the October implementation?We do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
ImplementationIs there a new timeline for the closure of the CRA BN support desk?We do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
ImplementationWill the CRA continue assisting customs brokers with account-based questions between May and the October 2024 CARM implementation?We do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
ImplementationCan 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) Business Numbers can continue to be requested from Canada Revenue Agency. Work is underway on developing a CBSA administered process for the registration and maintenance of program (RM) accounts for importers and exporters. Details will be published on the CBSA website.May 8
ImplementationWhat is the actual date of implementation in October?We do not have the date and will update you as soon as we have the information from the CBSA.Apr. 25
ImplementationWill 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?We do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
ImplementationWill CBSA still require the black-out period from April 26th to May 13th for them to launch CARM internally?NoApr. 25
ImplementationIs 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.We do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
ImplementationWill 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?YesApr. 25
ImplementationCBSA advised that they will launch CARM 2 internally on May 13, 2024. What exactly is being launched and what does it entail?We do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
OtherWill 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 2024Apr. 25
OtherCan voluntary entries continue to be submitted paper between now and October 2024 when CARM R2 is implemented?Yes  Apr. 25
PaymentFor importers who make payment with PAD withdrawal, what date will the April SOA be withdrawn on?April 30th, 2024Apr. 25
PaymentCan you confirm if the May SOA’s will be importer tagged?It will not be importer tagged until the October SOAMay 8
PaymentCan 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
Refunds, Blankets, Drawbacks, V TypesWill 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 TypesWith 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
RegistrationAfter what period of time does a CARM account get suspended for inactivity?We do not believe that the CCP will get suspended for inactivity but we have requested validation from the CBSA. The GC Key does get revoked for inactivity after 24 months of inactivity.May 8
RegistrationHow will the CBSA address the delegation issues that may result from the additional delay (i.e. outdated BAMs; people changing firms, etc)We do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
RegistrationAfter what period of time does a GC Key get revoked for inactivity? After 24 months of inactivityApr. 25
Financial SecurityFor 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 SecurityWhen 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 SecurityWill 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 SecurityIn 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 SecurityIn 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?We do not have this information and will update you as soon as we have the information from the CBSA.Apr. 25
Financial SecurityWill 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 SecurityIf paper bonds still need to be submitted, will Direct Security Letters still be required?YesApr. 25
Financial SecurityDoes 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 SecurityWill 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/CertificationCan CBSA confirm if there will be another round of CARM CES testing that will be opened to NEW participants?The CBSA has advised that CES testing will terminate on May 31st, 2024.  We have asked if there will be other CES activity after this time that could include NEW participants and we will advise once we receive an answer from the CBSA.May 8
Testing/CertificationWill 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/CertificationWill 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