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].
Last Update on: December 20, 2024
Category | Question | Answer | New? |
| 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. | |
| 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. | |
| 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. | NEW! |
| Business number usage | Can any BN/RM be used to release and/or account for goods? | No, effective October 21, 2024, CBSA commercial processing systems will not accept Exporter RM program accounts to obtain release of imported goods. Additionally, the CARM system will not accept a Commercial Accounting Declaration (CAD) quoting an exporter BN15. Only those BN15s that are set up with an importer or importer/exporter “RM” account profile will be able to obtain release and account for goods. | NEW! |
| Business number usage | Which BN should a customs broker use, if they choose to use their own BN to release and/or account for their client's shipments? | That is a business decision, the customs broker will decide which RM they use for this purpose. The only limitations are that the RM must be set up as an importer account and the RM must not be the customs broker BN/RM that the CBSA assigned to the broker when they registered for CARM, as a customs broker. | |
| 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 | |
| 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 | |
| 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 | |
| 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 | |
| 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 | |
| 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. | |
| 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. | |
| 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. | |
| 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. | |
| 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 | |
| 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. | |
| Payment | Do you have a list of Canadian banks which are currently able to do online banking with the CARM client portal? | Canadian banks current as of December 2024: Meridian | NEW! |
| Payment | Do you have a list of US banks which are currently able to do online banking with the CARM client portal? | US banks current as of December 2024: Meridian Credit Union | NEW! |
| 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. | |
| Registration | After what period of time does a GC Key get revoked for inactivity? | After 24 months of inactivity | |
| 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. | |
| 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. | |
| 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. | |
| 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. | |
| 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. | |
| 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. | |
| 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. |