Notes from National: CARM R3 goes live on Monday

Transcript

Good Day and welcome to our CARM audio, I am Melanie Bedard, Project Manager for CARM at the CSCB.  I cannot believe that CARM will finally be implemented on Monday. The Road to CARM has not been easy with so many stops and starts, unpaved roads, construction zones and detours along the way. The CSCB has been sitting at the Trade Chain Partner table since the first meeting and has represented and advocated for you, our members, since the beginning. We have brought you tools such as the Road to CARM, Road Maps and numerous webinars and in person sessions along the way.  We have filtered questions and asked them of the CBSA.  Many have been answered and believe it or not some remain unanswered at this late hour. Through it all, we have worked through the preparation and preparedness together with all of your individual questions helping the greater good.  On Monday, October 21st at 3:00 a.m. the new road will open and the CARM Client Portal will become available. CAD’s will be submitted and adjustments and corrections will become the new way forward.  Ready or not, here we come.

In the last few weeks we have been inundated with questions on important matters such as Temporary Admission Permits and the need for a separate surety bond for them, an understanding of what the SOA will look like on October 25th, who is accountable for the SOA,  and what happens when an importer does not Delegate Authority to a Customs Broker, just to name a few.

Let’s talk about a few of these matters starting with the Temporary Admission Permits. After many discussions on this matter over the course of the last few years, the CBSA has recently advised in writing that if the importer is required to provide a financial security for temporary importation it must be different that the one for RPP. Both bonds have different purposes and different legislative authorities.  The 180 day grace period is for financial security relating to release prior to payment (RPP) privileges. There is no such grace period for financial security bonds that are required to secure Commercial Temporary Importations under Tariff Item No. 9993.00.00.  At a CBSA webinar earlier this week they advised that there is no exception if a CAD is used rather than a BSF865. How will this work practically? If the CAD is submitted with tariff item No 9993.00.00 and the importer has a RPP indicator will the shipment be released even though a separate bond MAY be required depending on the circumstances? The CARM system is designed for the shipment to be released based on the RPP indicator. The CBSA does not foresee shipments being held in those circumstance, at least at the onset of CARM.

The SOA will be issued on October 25th and will include transactions released during the blackout period that will be entered between October 21st and October 24th in the new environment of CARM R3. Therefore, they will be subject to the new clearing rules; where no transactions will be tagged, i.e. all transactions from system perspective will show under the importer accountability. This transition will require an effective communication between yourselves and your importers to avoid missing or duplicating payments.  The CBSA will not be issuing late payment penalties and late payment interest for a period of 90 calendar days following the October 21, 2024 implementation. However, in case of non-payment and the collection activities reach the level of claiming on the bond, the CBSA may submit a claim against the bond that was covering the non-paid transactions.  It is important to note that the CBSA may issue late accounting penalties, late payment penalties, and/or late payment interest in cases where it is determined that the transition to the CARM system was not a factor.

What will happen if a broker releases goods under the Importer BN, and this importer is not registered in CARM, or is registered and has not delegated authority to the customs broker and the broker chooses not to submit the confirming entry under their Broker BN as they are allowed to do during the transition period of one year following CARM implementation?  The CBSA has advised that under the Customs Act, the importer or the owner of the goods is liable for assessment of duties and taxes.

This question and many others were covered by the CBSA during this week’s webinar. The CSCB has posted the slide deck and the recording of the webinar. We will host a webinar next week allowing you to ask questions that you may have on the slide deck. The details of the webinar will be available shortly.

Keep calm and CARM on, we will see you on the other side and will be available and ready to help you navigate through implementation and advocacy on future enhancements.