CARM is a digital multi-year initiative that transforms how the CBSA manages the collection of duties and taxes for commercial imported goods into Canada.
After its full implementation, scheduled for March 13, 2024, CARM will help ensure full compliance with the import rules, track import activity, and pay the appropriate duties and taxes.
CARM will provide access to importers’ trade information, direct payment of duties and taxes, submit and adjust a Commercial and Accounting Declaration that will replace the current Customs Coding Form (B3) and Adjustment Form (B2), post and monitor security to participate in the Release Before Payment (RPP) program as an importer.
All commercial importers importing to Canada are required to participate in the CARM initiative. Otherwise, it will impact the ability to import goods into Canada.
Registration must be completed on the CARM Client Portal before the Release 2 date to ensure timely access to the system during the importing goods process; if you aren’t registered, you will experience delays once Release 2 opens.
CARM Client Portal (CPP) is the central future of the CARM initiative, and it has the following timeline releases:
- Release 0, released in January 2021, moved the existing Accounts Receivable Ledger (ARL) data system to a more reliable SAP S4/HANA system in preparation for the new revenue and cash management system.
- Release 1, released in May 2021, allows users to view transactions posted to their accounts, make payments by credit card or online banking or set up pre-authorized debit, request and track the progress of rulings electronically, classify goods, and estimate duties and taxes.
- Release 2 is coming in May 2024, and the Release Before Payment (RPP) program will change. It will introduce electronic Commercial Accounting Declarations with the ability to correct and adjust, harmonized billing cycles, new offsetting options, electronic management of appeals and compliance actions, registration for a Business Number (BN9), and enrolment in various CBSA commercial programs.
As of May 2024, registering for an importer or exporter account (RM) will only be available via the CARM Client Portal. The Canada Revenue Agency will no longer be providing this service.
Changes to the Release Prior to Payment (RPP) program allow participants to obtain the Release of goods from the CBSA before the final accounting and payment of duties and taxes. Importers will no longer be able to use their customs broker’s RPP security to clear shipments before paying duties and taxes. Instead, importers who want to participate in the RPP program will be required to post their own financial security.
- Option 1: a financial security instrument for 50% of their highest monthly accounts receivable (inclusive of GST) with a minimum financial security of $25,000 per import program (RM).
- Option 2: cash deposit for 100% of their highest monthly accounts receivable (inclusive of GST).
The Canada Border Services Agency (CBSA) has created a transition plan to assist importers as the new Release Prior to Payment requirements come into effect in May 2024. Upon the official implementation of CARM as the system of record, importers will be given 180 calendar days to arrange their own financial security.
To log into the CARM Client Portal, you will able to select GCkey or Sign-in Partner. If it is the first login, the profile creation will begin automatically, and the following information will be needed to complete this process:
- The BN9 of the company (The unique business number issued by the Canada Revenue Agency)
- The import/export program account (RM extension)
- Registered name and address associated with the business number (inclusive of any punctuation or abbreviations)
Before registering, please ensure that your legal information is on file with the CBSA. Your legal name, address, and contact information should be current and exactly match the CBSA records, including any punctuation or abbreviation.
By default, the first individual to link their account to the business is the Business Account Manager (BAM). This account has the highest access in the CCP and manages all other accounts. The account owner can delegate different rights, internal to the employees and external to third parties (e.g. customs brokers). It is recommended to create two accounts with the BAM rights. You can also change such permissions.
After BAM, the next level of internal delegation is the Program Account Manager (PAM), who acts as editor or reader.
After you have determined your internal BAM and PAM and assigned your employees the necessary access levels, the next step is to consider granting external access (such as to customs brokers, consultants, etc.). These external parties will need access to the import/export programs within the CCP.
There are two levels of access to service providers:
- Business Management Relationship – this would delegate access to all program accounts, including future programs.
- Program Management Relationship that delegates access only to selected programs.
Neither of these access levels share sensitive information such as bank accounts, business relationships or user profiles.
After delegating the level of access to the third party, the BAM also needs to delegate the authority level as the proxy business account manager or program account manager.
pBAM – Proxy Business Account Manager can perform operational activities such as request rulings, make payments, view statements of account, invoices and payments made)
The pBAM role gives nearly complete access to all CARM CPP functionality except for access to sensitive information, employee accounts, and business relationships.
pPAM – Program Account Manager can access a specific program without the business profile.
pBAM or pPAM will assign their employees user roles to determine their access (pPAM, pEditor or pReader).
Helpful links:
CARM: The new way to assess and pay duties and taxes on imported commercial goods – https://www.cbsa-asfc.gc.ca/services/carm-gcra/menu-eng.html
CARM Client Portal – https://ccp-pcc.cbsa-asfc.cloud-nuage.canada.ca/en/homepage
User guide and onboarding documentation – https://ccp-pcc.cbsa-asfc.cloud-nuage.canada.ca/en/onboarding-documentation
CARM Videos – https://www.cbsa-asfc.gc.ca/media/video-eng.html#_a5
For more information, please contact us at our email address: info@scintegrators.ca