What is CARM?
CARM is a large multi-year project that began in 2016 with the implementation of the Accounts Receivable Ledger (ARL).
Once completely implemented CARM is intended to:
• Simplify the overall importing process
• Provide a modern interface for importing into Canada
• Give importers self-service access to their own information
• Improve consistency in trade rules and decisions
• Strengthen compliance verification and fraud detection
What changes under CARM?
The next phase of CARM will be the client portal. The initial version (Fall 2020) will offer basic functionality relating to account setup. Once the portal is fully operational (Spring 2021) importers will have access to the following:
• Accounting and payment of any applicable fees (i.e., duties/taxes) on imported goods
• Electronic submission of corrections and adjustments
• Available option to delegate third party service providers (e.g., customs brokers) to manage their import and clearance processes
• Applying for classification rulings
The biggest change for importers will be the requirement to post their own Release Prior to Payment (RPP) liability bond.
How does RPP impact you?
CARM will focus on shifting liability from the Customs Broker to the Importer. The impact will be as follows:
• All importers will be required to post their own security to participate in the RPP program.
• A commercial shipment will not be released prior to payment unless the importer has posted a surety or cash bond.
• CBSA recommends that the amount of RPP security an importer (resident or non-resident) posts should be based on their highest historic monthly accounts receivable over a 12 month period, inclusive of duties, taxes (GST), fees, and penalties.
• It is the importer’s responsibility to manage and maintain the appropriate amount of RPP security relative to their accounts receivable, inclusive of duties, taxes (GST), fees, and penalties.
• An importer will have the flexibility to make interim payment to reduce their RPP security utilization, and raise or lower their RPP security to account for seasonality or other fluctuations in their business.
CARM Implementation Phases
• Spring 2020: Complete movement of the existing ARL system from its existing data centre configuration to the cloud, with no changes in functionality for external users.
• Fall 2020: The first release of new functionality under CARM, will provide trade chain partners with new tools for managing their accounts with CBSA, including an online client self-service portal, and online invoicing and payments.
• Spring 2021: The second release will introduce additional functionality for trade chain partners such as registration, enrollment and electronic declarations with versioning.
How is my shipment released from customs?
The CARM Portal is not replacing the Single Window system. Release requests will still be sent to CBSA through Single Window and the Integrated Import Declaration (B3 data) which ultimately triggers the release of your goods. Once the Spring 2021 release is complete the current Customs Automated Data Exchange (CADEX) system will be decommissioned.
If you would like additional information about CARM please contact your Willson Service Team or visit the CBSA’s website.