What is CARM?

The CBSA Assessment and Revenue Management (CARM) digital initiative will change how the Canada Border Services Agency (CBSA) will assess and collect customs duties, Import-GST, and other levies payable on commercial goods imported into Canada.

On May 13, 2024, CARM will become the official system of record that importers and customs brokers will use to process customs clearance transactions and pay duties and taxes.

What are the importer’s new obligations under CARM?

Existing importers:

• Each importer who imports commercial goods into Canada must register its business on the CARM Client Portal (CCP) – NO LATER THAN APRIL 25, 2024
• Once the business is registered on the CCP, use your portal account to “delegate” authority to W2C Customs Trade Management (W2C) – NO LATER THAN APRIL 25, 2024

New importers (starting May 2024):

• In addition to the requirement of possessing a valid Business Number – Importer Account issued by the Canada Revenue Agency (with RM account identifier), as well as nominating W2C as customs broker through our usual onboarding processes for new customers, any new importer must also register on the CARM Client Portal and delegate authority to W2C (via the portal) before the first customs transaction can be processed.

What happens in May 2024?

If an importer has not registered on the CARM Client Portal (CCP) and/or has not delegated authority to W2C before May 13, 2024:

• The importer’s customs declarations will not get processed by CBSA until the importer is registered on the CCP.
• To represent and file customs declarations on an importer’s behalf, W2C must have received an “approved” delegation of authority from each importer via the CCP.
• If W2C’s request for delegation of authority has not been approved by the importer-client, via the CCP, then W2C will not be able to account for customs declarations on the importer’s behalf.

Note: The foregoing CARM obligations apply to ALL importers of commercial goods, whether big or small, whether existing or new importers, as well as to resident and non-resident importers alike. As of May 2024, if you import commercially into Canada, it is obligatory to be registered on the CARM Client Portal and to have delegated authority to W2C to act as your customs broker.

What about the Customs Bond?

• Technically speaking, starting May 2024, importers of commercial goods can no longer rely on W2C’s broker bond to benefit from Release Prior to Payment (RPP) privileges.
• As of May 2024, to obtain the customs release of new import shipments, benefit from the 5-day deferred accounting period to acquit customs declaration and then for the importer to make payment to CBSA at the end of a monthly billing cycle, each importer must post its own financial security instrument with CBSA in the form of a Customs Bond or a cash deposit through the portal.
• Financial security, whether cash or bond, must be determined according to CBSA guidelines and the security must be linked to the importer’s account on the CCP.
• There are few exceptions to the financial security obligation. Almost all importers will need to post security with CBSA to continue to benefit from RPP privileges.
• The consequence for importers that don’t post security when so required by CBSA, will be that each individual customs entry must be accounted and the payment of all duties and taxes owed on that transaction must be received and registered by CBSA before customs release of the import shipment will be granted. All this will lead to clearance holds at the border, or potential storage, demurrage and detention costs at air and ocean ports due to customs clearance delays.

IMPORTANT: Importers who register their business on the CCP before May 2024 are entitled to a 6-month grace period (e.g. up to November 2024) to post their financial security instrument (cash or bond) and link it to their portal account. Importers that fail to register on the CCP prior to May 2024 will not be entitled to this 6-month grace period. Once the May 2024 deadline has passed, late registrants will be required to either post security immediately to continue to receive RPP privileges or until adequate security is posted; the importer will be forced to pay duties and taxes before the customs release of each import shipment.

How will my duties and taxes get paid to CBSA?

• Starting in May 2024, the existing options of GST Direct and Importer Direct Security are expected to be repealed by CBSA.
• CARM will become the only system of record for all commercial importations into Canada.
• While most importers will continue to engage the services of customs brokers for the processing of customs clearance transactions and the filing of Customs Accounting Declarations (CADs will replace B3s), the whole architecture of CARM is designed for importers to pay all applicable duties, taxes, and other import levies directly to CBSA.
• Through its CCP dashboard and monthly statements posted by CBSA to an importer’s portal account, the importer can monitor the daily and monthly accruals of all duties and taxes payable to CBSA for a given period.
• In addition to its bills for customs brokerage services rendered, W2C is expected to be sending duty and tax statements to customers to facilitate reconciliation of amounts payable to CBSA. However, importer-clients are expected to rely on their CARM portal to monitor and manage payments of duties and taxes. Post-CARM, importers are expected to make payment directly to CBSA using either online banking options or by linking their financial institution (i.e. pre-authorized debit) or a credit card to their CCP account and then use the built-in payment functionalities of the portal.

Note: W2C can still arrange to pay CBSA on an importer’s behalf. However, such arrangements will be subject to W2C’s credit and risk assessment, as well as administrative or funds advance fees to be negotiated between the parties.

What do I do now?

Immediate steps:

1. Register your business on the CARM Client Portal as soon as possible, but no later than April 25, 2024.
2. Once registered on the CARM Client Portal, ensure that you approve the delegation request sent to you by W2C no later than April 25, 2024.
3. Upon registering to the CCP, if you have not received a delegation request from W2C, please contact your W2C representative immediately.

Future steps:

4. Discuss financial security options (e.g. Customs Bond) with W2C and when is the best time to purchase your Customs Bond and link it to you your CCP account.
5. Discuss payment options of duties and taxes (post-CARM) with your W2C representative.

W2C Resources:

CARM FAQ
CARM Glossary
CARM Webinars

CBSA Resources

CARM Registration
CARM User Guides
CARM Release Schedule
CARM – Changes to RPP privilege
CARM Client Portal Page
CARM Video Library
CARM FAQ (CBSA)

W2C can help!

W2C offers various services related to CARM:

• Information webinars
• Online assistance for portal registration
• Generating transactional history to answer portal security questions

If you need assistance understanding information about CARM, please contact the W2C customs brokerage experts.