At a CARM CSA importer engagement session with the CBSA on May 12th there was a lot of discussion on C Type CAD for purposes of obtaining release and accounting for goods and the submission of a V Type CAD. The CBSA is requesting comments from CSA importers as follows:
- Post CARM R2 implementation CSA importers should not use the C Type CAD for purposes of obtaining release and accounting for goods. This includes non-eligible CSA goods and hand-carried goods transported by an individual who is not a commercial carrier. Based on current CBSA data, the number of C Types used today by CSA Importers is extremely minimal. Moving forward, the CARM solution is not designed nor intended to post duties and taxes to a CSA Importer’s account based on a C Type CAD. Where a C type is currently being used, under CARM CSA importers should instead use a RMD for release and a TT Type CAD to account for goods. This includes hand carried goods.
Please provide any comments with respect to not being able to use the C type in a post CARM R2 environment. Please ensure to include what scenarios you currently use the C type for and what impact if any do you foresee by not being able to use the C Type, but rather the RMD process and TT type CAD instead?
- The submission of a V Type CAD accounts for and assesses duties and taxes on goods that have entered the Canadian economy without being released. Imported goods can be released by the CBSA under Customs Act Section 32(2)(a) (interim accounting, IID, PARS, RMD etc.); authorized for delivery under Section 32(2)(b) (CSA clearance); or via the CLVS stream. Where an importer has imported goods that have not been released per Section 31 of the Customs Act and accounted for using one of the options above, the V Type CAD is used. The V Type CAD is entered manually and submitted via the CCP. Unlike today, the V Type will not be presented in hardcopy at the CBSA office.
Please provide any comments with respect to using the V Type CAD as it relates to CSA processes today and the new process that will be implemented with CARM R2 for goods that have not been authorized for delivery nor released by the CBSA to [email protected].