Ottawa, December 17, 2010
This memorandum explains the policies and procedures relating to the accounting, revenue reporting, payment of duties and adjustment of goods imported into Canada by an importer authorized under the Customs Self Assessment (CSA) program. The memorandum also provides information about how to apply for authorization under the program, and a general overview of the CSA clearance process. A glossary of terms used in this document is included in Appendix A of this memorandum. For detailed information about CSA transportation and reporting requirements, refer to Memorandum D3-1-7, Customs Self Assessment Program for Carriers.
The Free and Secure Trade (FAST) initiative, a joint initiative by Canada and the United States, builds on the principles of the CSA. For additional information about FAST, please see the CBSA Web site at www.cbsa.gc.ca.
1. Customs Self Assessment (CSA) is a Canada Border Services Agency (CBSA) program designed to streamline the import process for authorized low-risk importers, who have the systems capability to self assess the accounting for imported goods to the CBSA, revenue reporting and the payment of duties and taxes.
2. To use FAST into Canada, importers must be authorized under CSA and join Partners in Protection (PIP). For additional information about FAST and PIP, refer to the CBSA Web site at www.cbsa.gc.ca.
3. The legislative references relating to the CSA program are provided in Appendix B of this memorandum. All legislative references to sections, subsections and paragraphs in this memorandum are from the Customs Act, unless otherwise stated.
4. The CSA program comprises two components:
For CSA clearance, the goods must be eligible, imported by an authorized importer, transported into Canada by an authorized carrier, and when transported in highway mode, the driver must hold an authorization under the Commercial Driver Registration Program (CDRP) or FAST Commercial Driver Program (FAST). Information on these driver programs may be found on the CBSA Web site at www.cbsa.gc.ca.
5. The fundamental features of the CSA program include:
6. To participate in the CSA program, the importer must satisfy basic eligibility criteria and complete the application process. Additional information about how to apply for CSA authorization may be obtained by contacting the Customs Self Assessment offices or Border Information Service, CBSA, listed in Appendix C of this memorandum.
7. Authorization of the importer is subject to the following conditions:
8. To determine that importers meet the authorization requirements, they must satisfy both parts of the application process, which are as follows:
and that information can be transmitted electronically. Part II is completed by the legal entity or company divisions that wish to participate in the CSA program.
9. To satisfy the residency requirement, the importer must have its head office within Canada, or operate a branch office in Canada. The Canadian business entity maintains separate books and records in relation to the Canadian business operations, and prepares separate financial statements; files Canadian income tax returns; maintains and controls bank accounts in Canada; accounts for the imported goods and is responsible for paying the applicable duties and taxes.
10. Importers who wish to have CSA goods transported across the border must use an authorized carrier. Since the authorization as a CSA carrier is separate from authorization as a CSA importer, a carrier that is a division of a CSA importer applicant must make a separate application. Further information about the CSA Carrier program is detailed in Memorandum D3-1-7, Customs Self Assessment Program for Carriers.
11. To apply for authorization, the importer must first complete Form E646, Customs Self Assessment – Importer Application – Part I. The application is available on the CBSA Web site.
12. Part I of the CSA importer application must be signed by an authorized officer of the legal entity.
13. When completed, the original signed application is submitted to the Customs Self Assessment office identified in Appendix C of this memorandum. Communication of importer information, such as the CSA application information, is subject to section 107 of the Customs Act (disclosure of information) and the Privacy Act.
14. When Part I of the application is received, a SPO is assigned to the importer. The SPO serves as a single point of contact for the CSA program, manages the importer’s application, provides ongoing guidance and assistance, and monitors the importer’s CSA program compliance. Importers are advised to contact their assigned SPO to discuss the technical and systems aspects of CSA throughout the application process.
15. During Part I of the application process, the importer and the CBSA should confirm that the company is correctly registered under the Business Number (BN) program. To participate in the CSA, it is essential that the legal entity is registered under only one nine-digit BN, and divisions or branches of the legal entity involved in the import of goods are identified with a unique import/export (RM) account identifier. CSA importers are exclusively identified in CBSA automated systems by their 15-digit BN/RM. The CBSA systems will recognize an importer BN/RM as being CSA approved. CSA processes will take effect and the importer will be eligible for CSA release, accounting, adjustment and payment processes. Additional information about the BN can be found in departmental Memorandum D17-1-5, Registration, Accounting and Payment for Commercial Goods.
16. The importer risk assessment includes an examination of the entire legal entity, including CBSA risk, criminality and outstanding payments to the Crown.
17. The time frame for completion of the CSA risk assessment may vary from case to case, according to a number of factors, such as the corporate structure of the entity and the number of regions in which the importer does business with the CBSA. If importers have not received notification of their Part I results within approximately three months, they may contact their SPO to inquire about the status of their risk assessment.
18. CSA applicants who are determined to be low-risk importers and approved under Part I are informed in writing and invited to continue to Part II of the application process. This notification is not final authorization to participate in the CSA, but permits the importer to proceed with Part II. Final approval for participation is not obtained until the importer signs the summary of importer program requirements, provided by the CBSA.
19. Importers who are not approved under Part I of the application are notified of the decision in writing. The fact that a company has not met the requirements of Part I is a significant and confidential matter. In accordance with section 107 of the Customs Act, such information will be handled with care and communicated in a strictly guarded manner. The letter of notification will be sent to the attention of the authorized person in the company, who signed Part I of the application.
20. Importers who are not approved under Part I are generally given the reason. However, given that the CSA risk assessment might reveal sensitive matters that could jeopardize CBSA protection and enforcement efforts, including the health and safety of citizens, some details relating to the denial of a company may not be explicitly communicated to the applicant. Provisions of the Access to Information Act and Privacy Act may provide an avenue for a formal request by the importer to obtain information to which they are entitled.
21. When possible, the reason for denial may be communicated to the applicant, so that the company can evaluate whether corrective action could be taken. In some cases, the SPO will negotiate an action plan with the importer to improve compliance. Where the importer implements the action plan and compliance is improved, the importer may be reconsidered under Part I.22. An importer who has been denied approval for CSA can make a written submission to the Minister concerning the denial. A committee consisting of senior CBSA representatives on behalf of the Minister will review the carrier’s case. The written submission should be sent to the following address:
Director, Trusted Traders Division
Pre-Border Programs Directorate
150 Isabella, 4th Floor
Ottawa ON K1A 0L8
23. To apply for the second phase of the CSA approval process, the importer is to complete Form E655, Customs Self Assessment Program – Importer Part II Application. The application is available on the CBSA Web site. The form and information about completing the application can also be obtained by contacting the SPO. When completed, the original signed application is submitted to the CSA office at the address listed in Appendix C of this memorandum.
24. The purpose of Part II is to ensure that the importer’s business systems will lead to complete and accurate trade data reporting for all imported goods. The importer must describe the company’s business systems for the import process, including audit trails and internal controls from and to:
25. With Part II of the application, the importer must demonstrate how the following CSA requirements will be met:
26. In Part II, the importer also identifies the CSA accounting option the company has selected and the account security number that is pledged. Where the account security number is assigned to a party other than the importer, a letter of authorization from that party must also be submitted as part of the application package.
27. An authorized officer of the company must sign the application form, as certification that the information provided is true and complete. The signing officer must have authority for the divisions making application, but does not have to be the same officer that signed Part I.
28. The systems requirements to support the CSA do not have to be in place when Part II of the application is submitted, but must in place before final authorization. Details about the CSA specific systems requirements and minimum audit trails are provided in Part II of the application.
29. Evaluation of the Part II application is performed by the SPO who reviews the importer’s application against the CSA requirements. While the SPO exercises due diligence in reviewing Part II, acceptance of the application does not signify certification of the importer’s business systems, or exempt the importer from being subject to a penalty.
30. The SPO will visit the importer to review information and systems descriptions provided in Part II of the application (e.g. tour of the premises, systems walk-through, report generation, etc.).
31. The SPO will work with the importer to meet the CSA requirements. However, where it is evident that these requirements cannot be met, a decision may be made to deny the application. An importer who has been denied approval for the CSA can make a written submission to the Minister concerning the denial. A committee consisting of senior CBSA representatives on behalf of the Minister will review the carrier’s case. The written submission should be sent to the following address:
Trusted Traders Division
Pre-Border Programs Directorate
150 Isabella, 4th Floor
Ottawa ON K1A 0L8
32. While Part I of the application consists of one form for the legal entity, multiple Part II applications are submitted by company divisions that wish to participate separately under the CSA program. Once the legal entity is assessed as a low-risk importer under Part I, individual divisions may become CSA participants in line with their systems readiness or business needs.
33. By allowing more than one application under Part II, company divisions of the legal entity can join the CSA in a graduated manner. Operationally, this means that some company divisions may have separate CSA clearance, accounting, revenue summary, remittance and adjustments. Accordingly, company divisions that make a separate Part II application to be a CSA-approved importer must be clearly defined by a separate 15-digit Business Number (BN).
34. When more than one division makes a single Part II application (e.g. divisions A, B and C), one 15-digit BN must be selected and consistently used to identify that group of divisions. The remaining RM accounts must be cancelled.
35. The one 15-digit BN selected to identify the multiple divisions is used on all clearance, accounting, payment and adjustment documents or transmissions. This also means that concurrent links and audit trails for these divisions must exist in company books and records to produce a single monthly RSF.
36. The authorized CSA importer is required to provide B3 trade data and X-type adjustments electronically from the company’s own business systems, either directly or through a service provider. Where the importer’s Trade Chain Partners (TCP) list is greater than 25, changes must also be transmitted electronically. Electronic transmission of the RSF is also required.
37. Importers or service providers should contact the Electronic Commerce Unit (ECU), who will provide the client with a copy of the CSA Electronic Commerce Client Requirement Document (ECCRD). The ECU can be reached at 1-888-957-7224. The ECCRD gives an overview of the EDI environment at the CBSA, provides message maps (in Appendix B of the ECCRD), and the implementation methodology associated with the CSA program. The main purpose of the document is to assist CSA participants with their internal implementation.
38. Testing of an importer’s electronic transmissions with the ECU does not begin until the SPO approves the importer’s Part II submission. When the importer is Part II-approved, the SPO will forward an EDI survey to the importer to initiate the testing process.
39. The importer must complete testing with the ECU before final CSA authorization.
40. During Part II of the application process, importers must submit an initial list of their trade chain partners, including United States and Mexico vendors and Canadian consignees that receive direct-delivery of imported goods. Where the list consists of 25 or fewer records, it may be submitted to the SPO by e-mail or fax. Where the list consists of more than 25 records, it must be submitted electronically, as per the specifications for the TCP load, as provided in Appendix D of this Memorandum, and in the ECCRD.
41. During Part II, the importer may submit a test file of the TCP list to the SPO to ensure that the final product is readable.
42. Three weeks before the CSA start date, a complete TCP file must be submitted to the CSA office for loading to the CBSA system. Also, the importer is required to submit updates after the CSA start date to include both additions to and deletions from the list. Where there are more than 25 trade chain partners, the update must be transmitted electronically. The ability to add and delete records electronically from the TCP file is part of the importer’s ECU testing. Failure to provide and maintain the list of vendors and consignees may result in an administrative monetary penalty (AMP).
43. Final approval for participation is obtained when the ECU testing is successfully completed and all other requirements have been met. The importer will then be requested to sign a letter, provided by the CBSA, that contains the summary of importer program requirements.
Note: CSA authorisation granted to an importer that has successfully completed the CSA importer application process is not transferable and cannot be sold, disposed of or acquired through amalgamation, change of legal personality or sale of business.
44. When the CSA importer obtains final authorization, there will be transitional issues to be considered. These issues are summarized in Appendix E. The SPO can also provide additional information.
45. CSA importers are required to inform the CBSA of changes to information provided in their application at least 30 days before the change. Exceptions to the 30-day time frame are:
Note: In these instances, the CSA importer is required to notify the CBSA immediately after the change.
46. Throughout the authorization process, the CBSA reserves the right to request information in addition to details provided by the importer in Parts I and II of the application.
47. Importers who misrepresent the facts or provide false information on the CSA application may be assessed a penalty of $25,000, denied acceptance into, or removed from the CSA program.
48. The process used for CSA clearance is similar to an in-bond movement, except that the goods may be delivered directly to the importer, owner or consignee.
49. Under CSA clearance, commercial goods are reported to the CBSA at the first point of arrival, where the CBSA may give “authority to deliver”. The CSA carrier who reports goods to the CBSA for authorization to deliver is liable for payment of duties and taxes, until the goods are delivered to the place of business of the importer, owner or consignee. Intermediary locations, as designated by the CBSA importer, constitute a consignee. Release will occur at these locations and the release date will be the date the goods were received at the intermediary location. To remove liability, the reporting carrier must ensure that proof of delivery is obtained and kept on hand for CBSA verification.
50. Where commercial goods are reported to the CBSA for authorization to deliver (i.e. reported under CSA clearance) the following conditions apply:
51. Under CSA clearance, the CSA carrier typically provides the following CSA data elements at the border, which are electronically verified by the CBSA at the Primary Inspection Line (PIL):
Note: Where this information is valid, the carrier may be authorized to deliver the CSA shipment. Note that a transaction number is not required.
52. Detailed information concerning the transportation and reporting of goods using CSA clearance is provided in Memorandum D3-1-7, Customs Self Assessment Program for Carriers.
53. Section 2 of the Act states that the meaning of “release” includes, “to receive the goods at the place of business of the importer, owner or consignee”. This meaning applies to eligible goods that are authorized for delivery to, and have been received at, the place of business of the importer, owner or consignee.
54. Given that goods reported to the CBSA under CSA clearance are not released until they are received, the CSA carrier who reports the shipment is “authorized to deliver” the goods to the place of business of the importer, owner or consignee. Subsection 19(1.1) of the Act provides the authorization to deliver goods directly to the place of business of the importer, owner or consignee before release.
55. The service options available to report eligible goods under CSA clearance are:
|Clearance Service Option||Service Option No.|
|CSA Highway Paper||00497|
|CSA Non-highway Paper||00521|
|EDI Highway Cargo||00539|
|EDI LTL Conveyance||00547|
|CSA EDI Rail||00505|
|CSA EDI Highway Release Paper||00612|
56. CSA importers are generally exempted from the requirement of reporting mandatory HS, regardless of the clearance option (CSA clearance or non-CSA) that is used to report imported goods. However, CSA importers are required to provide the HS, where the goods are reported under an electronic other government department (OGD) service option.
57. In the interests of contraband interdiction and the health and safety of the Canadian public, not all goods imported by a CSA importer are entitled to CSA clearance. CSA eligible goods are described as:
58. Carriers who are authorized under the CSA program are required to report empty container shipments to the CBSA. Such shipments can include: empty containers, empty trailers, flatbeds, racks, shipping tanks, skids, pallets and bobtails which are used in the shipment of merchandise. Containers of Canadian origin and containers which have been released and accounted for under section 32 of the Customs Act are exempt from duties and taxes, provided that they have not been advanced in value or improved in condition by any process. In order to facilitate the movement of empty container shipments that are exempt from duties or taxes through the FAST lane, drivers are only required to present their CDRP or FAST driver registration card and the carrier code in bar code format. Should any passengers be on board, they must also be CDRP or FAST approved.
59. Imported goods are generally not eligible for report under CSA clearance, if they are prohibited, controlled or regulated import into Canada, in accordance with the provisions of an Act of Parliament or of the legislature of a province, as well as the regulations made in accordance with any Act, that prohibits, controls or regulates their importation, i.e. subject to regulation by OGDs.
60. While most requirements of OGDs must generally be met before the release of goods, the importer may enter into an agreement with an OGD that allows the importer to provide OGD requirements after importation. Where the CSA importer has made such an agreement, the related goods may qualify for CSA clearance. Contact your SPO to obtain more information.
61. To be eligible for CSA clearance, goods must be shipped directly to Canada from within the United States or Mexico as noted on the carrier’s through bill of lading. For purposes of determining the eligibility of goods for CSA clearance, the “United States” means the 50 states of the United States, the District of Columbia and Puerto Rico.
62. Shipping of the goods to Canada must begin in the United States, or if the goods have entered the United States from a third country, they must first enter the economy of the United States before shipment to Canada. Goods that are shipped to Canada through the United States from a third country without first entering the United States’ economy are generally not eligible for CSA clearance (i.e. in-transit shipments). However, goods that are shipped from Mexico through the United States are eligible for CSA clearance.
63. The same rules applied to the in-transit movement of goods from the United States also apply to goods shipped from Mexico to Canada, i.e. the goods must enter the economy of Mexico before being shipped to Canada.
64. When goods are shipped to Canada from a United States foreign trade zone (FTZ), they may still be eligible for CSA clearance. Goods that enter the FTZ strictly for storage before export to Canada are not eligible for CSA clearance. On the other hand, goods that first undergo a further operation or process within the FTZ before shipment to Canada may be eligible for CSA clearance. Examples of a further operation are when the goods are repacked, assembled, distributed, sorted, graded, cleaned, mixed with foreign or domestic merchandise, or otherwise manipulated, or manufactured. Where goods shipped to Canada from a FTZ are considered eligible for CSA clearance, this information is input into the Accelerated Commercial Release Operational Support System (ACROSS) for the information of border services officers. Importers should notify their SPO of goods that enter FTZs in the United States to ensure the importer’s profile in CBSA systems is updated with this information.
65. To avoid an AMP, it is critical for importers to establish routine communication with their shippers and vendors to identify which products are eligible for CSA clearance. These instructions could be a standard part of foreign purchase agreements and contracts. In turn, it is recommended that shippers and vendors relay this information to the carrier and driver to confirm which shipments qualify for CSA clearance.
66. Importers who are authorized to participate in the CSA program are required to provide and electronically maintain lists of the following Trade Chain Partners (TCPs):
67. The requirement to provide the TCP lists supports ongoing risk assessment. TCP lists submitted by the CSA importer are captured in ACROSS for officers to evaluate the legitimacy of shipments reported under the CSA program; therefore, importers must ensure that the TCP lists remain current. Both additions and deletions must be provided to CBSA.
68. From time to time, border services officers at the border may request the shipment’s delivery paperwork and compare the actual vendor and consignee with the importer’s TCP list. Failure to maintain the consignee or vendor list will result in the assessment of an AMP.
69. The CBSA continues to reserve the right to examine shipments and conveyances that enter Canada. Occasionally, the CBSA may refer a CSA shipment for verification activities such as:
70. Where goods are reported for authorization to deliver, the report is made at the first point of entry into Canada and requires only the presentation of the driver’s CDRP or FAST driver card, and specific bar codes to identify the CSA approved carrier, CSA approved importer. Although the carrier is required to have normal commercial documents on hand (e.g. bill of lading, pro-bill), no documentation is presented to the CBSA at the time of report, unless requested by a border services officer.
71. Under CSA clearance, interim accounting is not required. The accounting for goods imported by the CSA importer occurs after the goods are received at the place of business of the importer, owner or consignee. Therefore, the CSA importer is not required to provide a Form CI1, Canada Customs Invoice, or commercial invoice referred to in Memorandum D1-4-1, CBSA Invoice Requirements, for clearance or final accounting, except when requested by a border services officer.
72. Where goods are reported under CSA clearance for authority to deliver, the carrier is liable for duties and taxes until the goods are delivered to the place of business of the importer, owner or consignee, or otherwise discharged under the provisions of subsection 20(2.1) of the Act.
73. Under the CSA, the requirement of sections 32 and 33 of the Act to account for and pay duties on imported goods is unchanged. For clarity, accounting refers to the submission of the B3. Where an authorized CSA importer imports commercial goods, the following accounting processes change:
74. All commercial goods imported into Canada by the CSA importer are subject to CSA post-importation processes, such as extended accounting time frames, summary reporting of revenue amounts, payment to a financial institution and automated adjustment, regardless of the clearance option used to report the goods to the CBSA.
75. A fundamental feature of the CSA program is that release records reported under the 15-digit BN/RM of the CSA importer and captured in ACROSS do not require a matching acquittal in the Customs Commercial System (CCS). The acquittal of a clearance transaction with an accounting transaction does not occur because:
76. The term “accounting trigger” refers to the method used by a CSA importer to identify that accounting to the CBSA and payment of applicable duties and taxes are required. For example, non-CSA importers are generally told by the CBSA that goods have been released. This is the “trigger” that initiates the process for accounting and payment. However the CBSA does not inform the CSA importer. Therefore, accounting must be triggered from the importer’s own business systems when imported goods are entered into company books and records.
77. The recommended method for CSA importers to trigger accounting is the reconciliation process used in business to authorize payment. Generally, payment is not authorized until the corresponding purchase order, receiving report and vendor’s commercial invoice are compared to verify which goods were received, the vendor’s identity, the price payable and the quantity received. A match of the details from these three files, with appropriate adjustments and allowances, results in the transaction being ready for payment.
78. Transmission of B3 accounting data by the CSA importer is expected to occur when the three-way match of the goods, the quantity received and the invoice value have been reconciled. The accounting time frames are extended for goods imported by a CSA importer to allow for this internal reconciliation process. Where a three-way match does not occur before accounting is due, a similar process, such as a two-way match of the purchase order and the receiving record, may be used; and adjustment filed, if required, when the invoice is received.
79. The business reconciliation process models a typical method from which accounting to the CBSA can be triggered. However, two considerations affect the reliability of this trigger:
80. CSA importers need to examine their systems and processes to ensure that all importations are accounted for to the CBSA in the required time period. A systems sweep should be developed for importers to identify unmatched orders, receipts, invoices and importations that could fall outside the reconciliation process. In performing the sweep, importers should also ensure that all the goods that have been imported have been accounted for to the CBSA and potential adjustments have been identified.
81. Under the CSA program, accounting and payment periods are determined by the release date. The meaning of release under section 2 of the Act allows for the date of release to be identified by CSA importers through their own business systems when imported goods are received at the place of business of the importer, owner or consignee.
82. The date of release/receipt is used to establish the accounting and payment periods for all goods imported by the CSA importer. Goods not eligible for CSA clearance must be reported to the CBSA for a “release” decision, at which time liability for duties on the goods is transferred from the carrier to the importer. Goods eligible for CSA clearance are reported to the CBSA for a decision to “authorize delivery” to the place of business of the importer, owner or consignee; and when the goods are received, liability for duties on the goods is transferred from the carrier to the importer.
83. A key requirement for CSA importers is to ensure that their business systems can record and track the date on which imported goods are received. In addition, the date of release/receipt identified by importers from their business systems must not be later than the date that the imported goods are physically received at the place of business of the importer, owner or consignee.
84. In some situations, such as goods shipped directly from the vendor to a Canadian consignee (direct shipment), the CSA importer may not know the date of physical receipt at the consignee’s place of business. To resolve such a situation, the importer may select an alternative date to identify the date of release. For example, if goods shipped directly by a specific vendor to a consignee in Canada are typically released by the CBSA four days after shipment, then the release date could be calculated as the shipping date plus four. In this example, if the vendor ships goods on April 25 the alternative release date calculated by the importer will be April 25 + 4 = April 29.
Note: The release date cannot be later than the transmission date of the B3.
85. The calculation and rationale of receipt date and/or alternative release date must be submitted by the importer with Part II of the CSA application and be approved by the SPO. Given that the number of days between shipping and typical CBSA release could vary for different vendor-consignee contracts, the importer may have to provide and rationalize more than one receipt date or alternative release date for the CSA.
86. The release/receipt date applied to goods imported by the CSA importer is to mirror the date of a CBSA release decision.
87. The date of release/receipt, or alternative date of release, identified by the CSA importer is the date used to determine the time frames for accounting to the CBSA and is transmitted by importers to the CBSA as the release date on their B3. Where importers choose to consolidate their accounting, the time frames for accounting to the CBSA will be based on the earliest release/receipt date in the consolidation.
88. “Accounting” is different from “payment”. Accounting is the provision of B3 trade data. The accounting options (Option 1 or Option 2) under the CSA define the accounting time frames. Regardless of the accounting option selected by the importer, the payment to the Receiver General for Canada is payable by the last business day of the month for all goods released/received between the 19th of one month and the 18th of the following month. While the “accounting time frame” can vary between CSA importers, the “payment period” is identical for all CSA importers (see below).
89. In the CSA environment, all commercial goods with a value for duty of CAN$1,600 or more, are accounted for to the CBSA within one of two accounting time frames, regardless of the CSA clearance or release option that was used to report the goods. A table comparing the similarities and differences of the two CSA accounting options and the accounting requirements of a non-CSA importer is provided in Appendix F of this memorandum. The CSA accounting options are:
Note: Goods cannot be accounted for before the date of release/receipt.
90. CSA importers must select one of the two accounting options before their CSA start date and must not change the selected option during their participation in the CSA program.
91. Imported commercial goods that have a value for duty of less than CAN$1,600 must be accounted for by the 24th day of the month following the month in which the goods were released/received. Alternatively, CSA importers may choose to use the same accounting option selected for their high value shipments (i.e. Option 1 or Option 2).
Note: Goods cannot be accounted for before the date of release/receipt.
92. In keeping with the Courier Imports Remission Order, commercial goods imported by a CSA importer with a value for duty not exceeding CAN$20 do not have to be accounted for to the CBSA. However, the importer must maintain documentation to support the applicability of the remission. Note the remission is not granted:
93. Duties owing on high value commercial goods released/received from the 19th of one month (month one) to the 18th of the following month (month two) must be paid no later than the last business day of month two. Note that the payment period is the same regardless of the accounting option selected.
94. For commercial goods that have a value for duty of less than CAN$1,600 released/received in a particular month, duties must be paid by the last business day of the following month, regardless of the accounting option selected.
95. Where a CSA importer chooses accounting Option 1, an interim payment of duties may sometimes be required to avoid incurring late payment interest. This is due to the difference in the accounting and payment time frames. Under Option 1, the accounting for commercial goods released/received during a month is not due until the 18th of the following month. However, payment of duties for goods received between the 1st and 18th of a month is due on the last business day of the same month.
96. The actual amount of duties and taxes owing on imported goods is not known until they are accounted for to the CBSA. In situations where payment of duties and taxes is due before accounting is completed, an interim payment may be made to avoid late-payment interest. For example, a CSA importer who uses accounting Option 1 may not know (or have calculated) the actual amount of duties and taxes owing for some goods released/received between the 1st and 18th of a month by the last business day of that month, so he or she may choose to make an interim payment for those goods.
97. In accordance with section 109.1 of the Act, where the importer fails to transmit accepted accounting data within the prescribed time limits, a late accounting AMP will apply. CSA importers are required to account for imported goods within the time limits of the CSA accounting option they select, or late accounting penalties will be assessed.
98. When an error-free accounting transmission is received by the CBSA systems, an “entry acceptance date” message is returned to the importer or broker who has transmitted the information. Where the entry acceptance date occurs after the accounting due date (based on the accounting option selected), the accounting is late.
99. Under the CSA, the importer is not notified by the CBSA of late accounting through the outstanding Transaction Status Client Report or K84. Instead, the importer is notified of instances of late accounting by the issuance of a Notice of Penalty Assessment (NPA), from the Administrative Monetary Penalty System (AMPS).
100. Late accounting for goods imported by the CSA importer is determined by the accounting option they have selected.
101. Three late accounting AMPS may apply to the CSA importer.
102. AMPS for late accounting are assessed to the CSA importer when their compliance level falls below 99.5 percent over a calendar year (January 1 to December 31). In order to calculate the compliance rate in the calendar year, a zero-rated penalty is issued for each late transaction. This penalty is systems-generated each time a transaction is late.
103. Where the accounting compliance rate of the CSA importer falls below 99.5 percent in a calendar year, an AMP of $50 is assessed for each late transaction below the 99.5 percent. This assessment is monitored and manually assessed by the importer’s SPO.
104. In cases where the importer has consolidated more than one shipment in a single accounting transmission, the maximum AMP is $500. Penalties identified through verification are not systems-generated and will be manually assessed by the SPO.
105. The CSA importer is required to keep all records related to the commercial goods released/received for a period of six years following importation of the goods, including information about:
106. B3 information continues to be submitted to the CBSA by the authorized CSA importer. However, there are some changes to the accounting process under the CSA program, for example:
107. There is no link between ACROSS release records and the CCS entry sub-system for the CSA importer’s goods. Release and clearance decisions concerning commercial goods reported under the 15-digit BN of an approved CSA importer are automatically acquitted in ACROSS. The system does not require a matching accounting transaction through CCS.
108. Where a transaction number is required, it cannot be duplicated for seven years and three months.
109. Since the systems acquittal of clearance records with accounting transmissions is not required, the CSA importer must maintain appropriate audit trails between imported goods released/received and accounted for. Failure of the CSA importer to maintain the required audit trails may result in the assessment of an AMP.
110. Coding of the B3 fields is unchanged for CSA, except for:
111. CSA importers continue to use all existing B3 entry types to report trade data to the CBSA. There is no unique B3 entry type for CSA importers, other than the X-type, used for adjustments (see Section 5 and Appendix G of this memorandum).
112. When transmitting a multiple-line B3, the CSA importer does not have to provide a cross-reference between the invoice and the B3 line with the electronic CADEX or CUSDEC (UN/EDIFACT) accounting transmission. To comply with the CADEX message map, input page one, line one.
113. Where the importer uses CSA clearance, a cargo control document is not required for the report of goods. Therefore, information such as the elements listed below may not be readily available to the CSA importer for the accounting of the goods. Collection of this data, however, remains a requirement to sustain Canada’s obligation under a Memorandum of Understanding with the U.S. Census Bureau. Therefore, in the design of their business processes for CSA, importers need to establish a method to provide the following B3 data elements:
114. CSA importers can continue to transmit actual data in these fields. However, they may derive this information in a similar fashion as freight charges (Field 19):
115. Under the CSA program, there is an opportunity to consolidate trade data transmissions to a certain degree. Most B3 header, sub-header, and line information will be required as described in departmental Memorandum D17-1-10, Coding of Customs Accounting Documents, but where fields such as the vendor name and classification number are the same, the importer can also choose to consolidate according to the following conditions:
116. Although the option to consolidate B3 data is available to CSA importers, they are not obligated to do this, and may continue to transmit on a shipment-by-shipment basis. In fact, this would be the better alternative for imports such as a “within access” commitment tariff item. Otherwise, in some situations, the importer could find that the “first come-first serve” tariff rate quota (TRQ) is exceeded by the time a consolidated B3 is presented.
117. Where an incorrect BN is used to clear commercial goods and final accounting has not yet been accepted, the importer/broker is to request the BN change by submitting Form A48, R.M.D. Correction, to the office of release. In addition, the acquittal status of the transaction must be updated in ACROSS as follows:
118. A feature of the CSA program is to minimize requirements related to supporting documentation for reporting, accounting and adjustment of imported goods, except when requested by a border services officer. As discussed in Section 2 of this memorandum, the carrier may report goods for authorization to deliver by simply providing the required bar-code information. Further, given that the CSA importer is not required to provide interim accounting, the reporting and accounting for goods authorized for delivery could, essentially, be paperless. Bar codes are presented to effect authorization for delivery and CADEX or CUSDEC transmission is provided to account for the goods.
119. The CSA importer is not required to provide invoice information described in Memorandum D1-4-1, CBSA Invoice Requirements, but must do so on the request of a border services officer. An AMP may be assessed when the importer fails to provide information requested by a border services officer. While the requirement to submit supporting documentation for report, accounting or adjustment is reduced, the CSA importer must have audit trails between source documents, the accounting for goods, adjustments to original accounting information and revenue amounts.
120. As explained in section 10 of the Act, a broker or agent may transact business with the CBSA on behalf of an importer or owner, provided that the broker/agent has been authorized to do so. Additional information concerning the authority to act as an agent is provided in Memorandum D1-6-1, Authority to Act as Agent.
121. In the CSA environment, although it is the responsibility of the CSA importer to identify the requirement for accounting of imported goods (to trigger accounting), the importer may appoint a broker/agent to complete and transmit the related accounting (B3) information to the CBSA. Further, where such services are offered, a broker/agent may be appointed on behalf of the CSA importer to prepare and transmit the RSF, TCP information and automated X-type adjustments. The CSA importer may also use a broker/agent to prepare and submit documents required at the time of report, for example, when a non-CSA service option is used (e.g. PARS, RMD).
122. Shipments imported into Canada by a CSA importer are subject to the security provisions described in section 35 of the Act for release before payment privileges. Where more than one account security number is used for release and accounting, the CSA importer must ensure that all corresponding revenue amounts are reported on a single monthly RSF (E648). Procedures for the importer or broker to post security are described in Memorandum D17-1-5, Registration, Accounting and Payment for Commercial Goods.
123. Where goods are released before payment under the provision of paragraph 32(2)(b) of the Act and authorized for delivery, the CSA importer becomes liable for payment of duties when the goods are received at the place of business of the CSA importer, owner or consignee.
124. The CSA importer pledges security on Part II of the application. Where the account security of a broker is pledged, written authorization from the broker must accompany Part II of the importer’s application. The pledged account security number may be changed only in consultation with the importer’s SPO.
125. Authorized CSA importers are responsible for the self-assessment and reporting of most CBSA-related revenues. The K84 is eliminated in the CSA environment. (The K84 process is used by non-CSA importers for payment of duties, taxes, late accounting penalties and late transaction payment interest.) While the CSA importer continues to transmit B3 trade data, the related revenue amounts are not generated on a K84. Instead, the CSA importer self-assesses and summarizes revenue amounts. The summarized amounts are reported by financial line object code on a single monthly report called an RSF. Line object codes may be found in Appendix K.
126. Although the RSF is transmitted electronically as outlined in the ECCRD, a sample of the RSF is available on the CBSA Web site.
127. The RSF is used to report CBSA revenue concerning the importation of commercial goods by the CSA importer, including amounts related to the accounting for goods, adjustments, refunds, drawback, interest, penalties and other CBSA assessments. Importers should ensure all transactions have been accepted by the CBSA before including corresponding revenue amounts on the RSF. The RSF is used to report both:
128. Both the importer name and 15-digit BN are completed on the RSF to identify the specific CSA importer for which revenue amounts are being reported. Where a company division or a group of divisions have submitted separate Part II applications to participate in the CSA program, separate RSFs are prepared using the 15-digit BN.
129. Only one monthly RSF is prepared for the CSA importer. Therefore, where more than one account security number has been used for release and accounting purposes, the importer must ensure that the related revenue amounts are included on the single monthly RSF.
130. The CSA importer must submit an RSF to the CBSA each calendar month and make payment of the respective amount reported on the RSF at a financial institution. Both the RSF transmitted to the CBSA and remittance at the financial institution, are required on or before the last business day of the month. The RSF month is the month in which the respective payment is made. For example, amounts reported on the “June RSF” must be paid by the last business day of June. Total amounts paid at the importer’s financial institution during a month must agree with the total payment amount reported on that month’s RSF.
131. The period start date and period end date should reflect activity captured on that month’s RSF. The period start and end dates reported on the RSF may change from month to month to accommodate the business cycles of the CSA importer. The period end date reported on the current month RSF should reflect the last day that B3 records, for which the respective revenue amounts are reported on that RSF, are transmitted to the CBSA and received in accepted status.
132. However, the period start date of one RSF cannot be earlier than the period end date of the previous RSF. Therefore, the CSA importer may choose to default to the start and end dates of the payment period in these fields (see “Payment Period”).
133. If the first RSF on CSA is nil and is being transmitted by the CSA importer, the period start and end dates of that first NIL RSF must both be earlier than the CSA participation start date. See also “Reporting a NIL/Credit RSF” below. Note the period start date of the first RSF with data (i.e. not nil) must not be earlier than the CSA participation start date.
134. The value for duty (VFD) of current-month transactions includes both original and adjusted B3 trade data for which related revenue amounts are included on that RSF. The VFD in the RSF includes both B3 and X type revenue. This amount in the header of the RSF is to be rounded to the nearest dollar, without cents or decimals.
135. A field on the RSF described as “Filing ID” is used when a third party prepares the RSF on behalf of the CSA importer and is completed with the five-digit account security number of that third party.
136. A single monthly RSF is prepared for each CSA importer and must be provided to the CBSA, in electronic format, on or before the last business day of the month.
137. Where a complete and error-free RSF is not received by the last business day of the month, an AMP will be assessed against the importer for failure to provide the RSF to the CBSA within the prescribed time. Note that the AMP assessed for failure to provide an RSF within the specified time frame is unique to the CSA and is separate from late accounting and late payment.
138. The CSA importer is generally responsible for self-assessing and calculating amounts for report on the RSF. Amounts owing to the CBSA are reported on the RSF as debits and amounts due to the importer are reported as credits. The credit amounts offset the debit amounts and the remaining balance is payable at a financial institution.
|Total payable $90|
139. Subsection 74(8) of the Act allows CSA importers to apply, within four years from the date of accounting, the amount of a refund to which they are entitled, to the payment of an amount for which they are liable under the Act. This provision provides for the self-assessment of refund amounts on the RSF and, as a result, the CBSA does not issue refund cheques to CSA importers.
140. Unlike the K84, individual transaction numbers transmitted to the CBSA during the RSF period are not reported on the RSF. Instead, revenue amounts are totaled and reported on the RSF by line object code. For example, all duty payable for the accounting of goods during the RSF period is added and reported as a single amount. Similarly, other revenue amounts, both debits and credits, are added by line object code.
141. While transaction numbers are not listed on the RSF, the CSA importer must have the internal controls and audit trails in place for audit purposes to retain the details of the transaction number, dates, VFD and corresponding revenue amounts electronically. Audit trails must also include source documents in relation to the receipt and payment for the goods, CBSA accounting, adjustments, revenue reporting and payment of duties and taxes.
142. In accordance with provisions of the Customs Act, the Excise Tax Act and the Customs Tariff, amounts paid as goods and services tax (GST) at the time of accounting are generally not refunded. These amounts are recovered through an importer’s GST input tax credit. Accordingly, GST amounts are not included as a credit on the RSF.
143. An exception to reporting GST as a credit on the RSF is where a clerical error related to the amount of GST reported on a B3 is corrected within the same RSF month. In this situation, the importer transmits an X-type adjustment within the same period to adjust the GST. When the adjustment is accepted, the amount of GST may be reported as a credit on the RSF against line object code 49129 (GST – credit for current month corrections only). The amount of GST reported on the original B3 is also reported on the debit side of the same RSF against line object code 49121.
144. In addition to amounts self-assessed by the CSA importer, the RSF is used to report revenue amounts assessed by the CBSA, such as the following:
145. The customs assessment section on the RSF is used to report the amount assessed, assessment type, corresponding reference number and port code of the CBSA office that issued the assessment.
146. While most CBSA assessment amounts are reported in the customs assessments section on the RSF, an exception is the report of amounts assessed on a CBSA-initiated B2-1. In this case, the revenue is reported in the following manner:
147. Where the CSA importer chooses to make an interim payment of duties and taxes to avoid late-payment interest, the interim payment is reported on the RSF. The interim payment, an estimate of duties and taxes owing, is reported one month. The actual amount, once calculated, is reported the following month.
148. To avoid possible double payment, the interim payment is reported as a debit in the first month in the Interim Payments section of the RSF, and is reported as a credit in the “credits” section of the RSF in the second month. The credit amount of the second month cancels out the debit amount from the first month (the credit amount in the second month must exactly match the debit amount from the first month). Actual amounts payable are then reported as part of the regular duty and taxes owing in the “debits” section of the second month.
149. GST is not refunded by the CBSA. The report of a GST interim payment as a “credit” on the second month RSF is permitted only because the amount does not represent a refund, but is an offset against the actual amount paid on the same RSF. This situation applies only to the interim payment.
150. The examples below are provided to show reporting of interim and actual amounts on the RSF.
151. In most situations, interest payable to or owed by the CSA importer under provisions of the Customs Act, Customs Tariff, Special Import Measures Act and regulations made under those acts, is self-assessed, calculated by the CSA importer and reported on the RSF. Situations where interest may apply include interest on the reconciled interim payment, late transaction payment interest, interest on adjustments, and interest for late payment of the RSF. Generally, interest is payable beginning the first day after the person becomes liable to pay the amount and ends on the day the amount is paid in full. For information about the application and calculation of interest, refer to the following memoranda:
152. Interest is calculated on a compounded daily basis. There are two interest rates applied in accordance with the Customs Act and the Customs Tariff, depending on the nature of the situation:
153. To calculate interest, the date of payment or duty paid date is the date of remittance to a financial institution, not the date on which the related RSF is transmitted to the CBSA.
154. Interest resulting from the underpayment of an interim payment, late transaction payment and late payment of the RSF is calculated at the specified rate. Interest on adjustments and interest resulting from the overpayment of an interim payment is calculated at the prescribed rate.
155. Interest payable to or owed by the CSA importer that results from an adjustment is reported on the RSF as a credit or debit. This includes interest related to self-adjustments, re-determinations, further re-determinations, and duties relief provisions.
156. Where the adjustment to an original accounting declaration of the CSA importer is submitted using the X-type automated entry, the decision date is the date of the respective entry-acceptance message. Where the adjustment is submitted on Form B2, the decision date is the date of the respective DAS.
157. Section 80 of the Act stipulates that interest granted as the result of a refund applies only on the 91st day after the day an application for the refund is received by the CBSA. However, for a CSA importer, this should rarely occur because the importer does not have to wait for a cheque to be issued from the CBSA. Instead, the importer reports the refund amount on the RSF in the same month that the X-type entry is accepted in CCS.
158. In accordance with subsection 33.4(1) of the Act, late-payment interest is payable when duties and taxes are not paid by the due date. Late-payment interest will not be automatically calculated by the CBSA. Where a payment of duties and taxes is late, the respective interest amount is to be self-assessed and reported on the importer’s RSF.
159. The amount of late-payment interest assessed by the CSA importer is calculated using the specified rate, on the amount of the outstanding balance, for the period beginning on the date after payment was due to the date payment is made. The date of payment is identified by the date on which the importer’s designated financial institution received the related CSA remittance.
160. The due date for payment of duties by the CSA importer is determined by the date the imported goods are released/received at the place of business of the importer, owner or consignee. Payment of duties and taxes for high value shipments released/ received by a CSA importer between the 19th of one month and the 18th of the next month is due on the last business day of that second month.
161. In the following circumstances, the interest amount related to goods imported by the CSA importer may be waived and does not have to be reported on the RSF.
Note: All calculations that relate to the interest amount must be made to determine if the waiver applies. The importer is to retain records to support the calculation.
162. Generally, the CSA importer reports all CBSA-related revenue amounts on his monthly RSF. The exception to reporting CBSA assessments on the RSF is where payment must be made without delay rather than at month end. In these cases, payment is made at the local CBSA office:
163. The requirement to submit or transmit a monthly RSF is mandatory even in circumstances where the net amount is zero or there is a credit amount due to the importer. A NIL report for the section called “Debits” is accomplished by reporting “0” for VFD current month transactions, Duty-49010 (original transactions) and GST-49121 (original transactions). The other RSF sections remain optional if the “Debits” section is NIL. A credit amount may be carried over to the RSF of the following month, or the importer may request the CBSA to issue a cheque.
164. Only one RSF for each CSA importer (as identified on Part II of the CSA application) is to be on file with the CBSA for any given month. Once sent, an RSF cannot be deleted. It can only be changed. Where a change is required to RSF information previously submitted to the CBSA, a replacement RSF, complete with all applicable data elements, must be presented or transmitted.
165. Where changes are made to revenue amounts reported on the original RSF, importers must adjust their payments appropriately and notify their SPOs. A fundamental rule in the change process is that the amount payable reported on the RSF must match the total amount of payments remitted for the same RSF period.
166. The CSA importer is allowed only one RSF on file with the CBSA for each calendar month. The RSF amount must be paid at a financial institution on or before the last business day of the same month. Where CSA importers might incur additional interest charges on amounts owing before the RSF is submitted and paid, they may make supplementary payments at their financial institution before month end. Where more than one payment is made toward an RSF, the sum of the payments is expected to equal the final RSF total, and must be received at the financial institution by the last business day of the month.
167. In some instances, clerical or calculation errors might result in an amount payable reported on the monthly RSF that is different from the actual amount paid at a financial institution.
168. Under the CSA program, revenue amounts owing to or by the CSA importer are reported to the CBSA once a month on the RSF and the total amount payable reported on the RSF is remitted at a financial institution. The date of remittance at the financial institution is the duty-paid date for the goods. The financial institutions where the RSF amount may be paid are described in section 3.5 of the Act, which provides authorization for payment at:
169. Payment of the total amount payable reported on the RSF shall be made at a financial institution operating in Canada, either through electronic transmission or by using form BSF645, Customs Self Assessment – Remittance Voucher - CSA. The vouchers are printed by the CBSA with the importer’s BN and address. These vouchers can be obtained through the SPO of the CSA importer. Note: The original vouchers provided by the SPO must be used because the ink or toner must be magnetized. Specifications for electronic transmission of the remittance are negotiated between importers and their financial institutions.
170. To summarize the CSA revenue reporting and remittance process:
171. When the total RSF amount has not been paid by the last business day of the month, an AMP will be issued. The penalty amount will be $100 for first instance, $500 for second instance, and $1,000 for third and subsequent instances. Failure to remit payment directly to a financial institution will result in a penalty assessment of $250 for the first instance and $500 for subsequent instances.
172. In some situations, importers may make more than one CSA remittance at their designated financial institutions during a single RSF period. Multiple remittances are not to be made for day-to-day payment of duties and taxes. The intent of permitting more than one remittance is to offer the importer a way of paying amounts that are subject to interest and have a due date before the RSF payment is made at a financial institution. Examples of such situations are payment of an AMPS penalty or a DAS issued by the CBSA. While multiple remittances may be made at the importer’s financial institution, only one RSF can be on record with the CBSA for the month.
173. The total amount of the remittances made at a financial institution must equal the “Total Payment” amount reported on the RSF. When more than one remittance is made during the month, the amounts of the multiple remittances paid during the RSF period must add up to the total payment amount that is reported on the RSF.
174. A CSA importer may choose to submit the RSF and payment before the last business day of the month, depending on the company’s business cycle. In addition, the importer may choose to prepare and submit the RSF before making the payment. For example, the importer may submit the RSF on June 25 but make the payment on June 30. Where the importer discovers that the amount reported on the June 25 RSF is incorrect before making the June 30 payment, he or she must provide a corrected RSF to the CBSA by June 30 to replace the June 25 RSF.
175. The following is provided to outline accounting and payment periods for a CSA importer.
176. In the CSA environment, self-adjustments to original accounting information and refund claims are submitted to the CBSA electronically. The format of the automated self-adjustment is similar to a B3 and is identified by type X. Illustrations of the X-type adjustment are provided in Appendix G of this memorandum.
177. Transmission of the X-type adjustment to the CBSA is through CADEX or the UN/EDIFACT version 99B and is supported through CCS. Requirements of the electronic transmission of the X-type entry are detailed in the CSA ECCRD.
178. In the X-type transmission, negative values are used to remove original accounting information; positive values are used to replace the information. Changes may be made on a net basis, i.e. only adjusting the incorrect portion. Alternatively, changes can be made using an approach more similar to the B2 (paper) adjustment by removing the entire line that was in error, and replacing it with the correct data. Provided that the correct data is submitted, either method is equally valid. The term “negative value” and the negative sign are used only to illustrate the concept of the X-type adjustment. When these values are actually transmitted to the CBSA, the appropriate coding specified in the ECCRD is used.
179. The X-type entry is used to self-adjust both corrections submitted under Section 32.2 of the Act and applications for refund submitted under subsection 74(1) of the Act. However, adjustments under Section 32.2 must not be combined with adjustments under Section 74(1) on the same X-type, i.e. refunds cannot be combined with amounts payable to the CBSA. For more information on adjustments, see Memorandum D11-6-6, Self-Adjustments to Declarations of Origin, Tariff Classification, Value for Duty, and Diversion of Goods. The X-type adjustment may also be used to self-assess and account for SIMA duties voluntarily.
180. Exceptions to the electronic submission process (X-type entry) are:
181. The use of the automated X-type entry to transmit an adjustment of accounting information does not change legislative provisions that relate to the requirement to correct accounting information, or the authorities for and time limits of self-adjustments, re-determinations, further re-determinations, and refunds. Like non-CSA importers, CSA importers are expected to submit corrections, regardless of the value for duty. However, there are some changes in the CSA adjustment process, such as:
182. The CSA importer reports all revenue impacts that result from the filing of an adjustment on the RSF regardless of the manner of or reason for filing – X-type entry or paper B2. Additional duties, taxes and interest owing to the CBSA are reported as a debit on the RSF and payment is remitted at a financial institution. Duties payable to the importer are reported as a credit on the RSF and CBSA will normally not issue cheques for amounts owing to the CSA importer. Given that GST is excluded from refunds made under CBSA legislation, GST amounts are not recorded as a credit. Importers who are eligible for a refund of GST should contact the Canada Revenue Agency tax services office nearest them for information about benefits available under the input tax credit system.
183. The amounts of additional duties and taxes owing or duties refunded are not to be reported on the RSF until the importer receives the notice of re-determination in keeping with the following guidelines:
184. In accordance with the Customs Accounting Document Error Remission Order, remission is granted when the amount of a bona fide error on any one CBSA accounting document results in an underpayment of an amount not more than $7.50. When an adjustment of a single accounting document results in an amount owing of $7.50 or less, the CSA importer may take consideration of this remission and need not report the amount as a debit on the RSF. As with other revenue amounts, substantiation of the amount is to be retained by the importer. Information about the Customs Accounting Document Error Remission Order is provided in Memorandum D17-1-9, Remission of Underpayment Due to Customs Entry Error.
185. In accordance with subsection 3.3(1) of the Act and section 125 of the Customs Tariff, where the importer submits an adjustment and interest on the duties and taxes, and penalties are less than $5, the interest is waived. In this case, the CSA importer is not required to report the interest waived on the RSF. However, all calculations that relate to the interest amount must be made to determine if the waiver applies. The importer is to retain records to support the calculation.
186. During traditional B2 adjustment processing, an automated DAS is generated as notice to the importer of the CBSA’s decision and to inform the importer of the right to appeal. However, where an X-type automated adjustment is processed, a DAS is not generated. Instead, the entry-acceptance message generated by CCS provides the notice of decision required by subsection 59(2) of the Act or subsection 60.1 of SIMA. Appendix H of this memorandum explains the meanings of the related entry-acceptance messages.
187. Where the CSA importer transmits an X-type adjustment, the date of the entry-acceptance message shall be used:
188. While the X-type automated adjustment is similar to a B3 transmission, there are some significant differences, as described in the CSA ECCRD, including the transmission of negative amounts and the completion of certain fields. The following codes are unique to the X- type entry transmission to accommodate the automated adjustment process:
189. The original transaction and line number used to account for the goods originally is not generally required as part of the X-type transmission. However, the CSA importer is required to maintain the appropriate records and audit trails that relate to the accounting and subsequent adjustment of goods, revenue reporting and payment. Where the importer transmits an adjustment that relates to a preferential tariff treatment under NAFTA or CCFTA, the original transaction and line number is required in Field 24 (previous transaction), and Field 25 (line). For consolidated adjustments that relate to a preferential tariff treatment under NAFTA or CCFTA, the original transaction number and line of the earliest transaction being adjusted are required.
190. Where a CSA importer submits a voluntary X-type entry to correct original accounting information that was determined to be in error during a CBSA program verification, the original B3 transaction number shall be transmitted in Field 24 (previous transaction).
191. Given that the X-type entry is submitted electronically, it is not necessary to provide supporting documentation at the time of the automated adjustment. However, the importer, in accordance with section 40 of the Customs Act, is required to maintain the appropriate records on file and make them available to a border services officer when requested.
192. CSA participants are required to maintain audit trails from the adjustment transaction to the source document that triggered the need for the change, and from the adjustment transaction to the RSF that included the adjusted revenue.
193. Where the CSA importer fails to make information relating to imported goods available to a border services officer when it is requested, an AMP will be assessed. In addition, there is a specific SIMA-related penalty that will be assessed when the CSA importer fails to provide the detailed product description for a particular import when requested. A contravention will be assessed where the importer fails to respond to a written request.
194. The automated X-type adjustment may be submitted to adjust a single transaction or, alternatively, to adjust several transactions as a consolidated adjustment. Consolidated adjustments are those adjustments that cover more than one shipment.
195. Where a consolidated X-type adjustment transmission is used, the adjustment does not have to be directly associated with specific CBSA accounting transactions; however, the goods related to the adjustment must have been accounted to the CBSA and duty paid within the same calendar year (i.e., from January 1 to December 31). The X-type adjustment is not necessarily adjusting individual B3 information, but may be used to adjust blocks of trade data, within legislated time frames. For example, where a correction to the tariff classification of goods imported within the year is required, each individual B3 does not have to be corrected. Instead, one X-type may be transmitted to deduct the total value of goods from the incorrect classification number and that value of goods added to the correct classification.
196. While the consolidated adjustment may be used to adjust accounting information over a period of up to one year, the CSA importer is still required to file a self-adjustment, request for re-determination, further re-determination or refund within the legislated time limits. For example, in accordance with section 32.2 of the Act, the CSA importer is required to correct a declaration of origin, tariff classification, and value for duty within 90 days of the date the importer has reason to believe that the original declaration is incorrect.
197. The following provides an illustration of the automated adjustment process for a consolidated adjustment transmission:
|B3 Number||Tariff Classification||Value for Duty|
198. A consolidated X-type B3 should normally cover exactly the same issue (e.g. re-determination of tariff classification, re-determination of origin or re-appraisal of value for duty), or exactly the same commodity.
199. Several commodities may be adjusted on a single X-type if the issue is the same. For example, an importer can change the tariff classification of shoes, purses and boots all on one X-type.
200. Several issues may be adjusted on a single X-type. However, in this case, each individual commodity must be submitted under a separate X-type. For example, one X-type can be used to change the tariff classification, tariff treatment and value for duty of shoes alone on one X-type. (Separate X-types would be required for similar adjustments to boots and purses.)
201. Only adjustments that are transmitted in the same or current RSF month due to clerical errors can be used to recover GST. The GST cannot be credited by the CBSA outside the current month. Instead, any credit of GST is claimed directly from GST using the input tax credit.
202. CSA importers can combine more than one adjustment, each of which can be more than one line, on a single X-type entry (i.e. a “multiple-line”). However, adjustments under section 32.2 must not be combined with adjustments under section 74(1) of the Act on the same X-type, i.e. refunds cannot be combined with amounts payable to the CBSA. Consider the following example:
203. Information on drawbacks can be found in Memorandum D7-4-3, NAFTA Requirements for Drawback and Duty Deferral. There are some differences with drawback activity under the CSA program.
204. Drawback activity is not processed as an automated X-type entry. For CSA importers, the drawback program remains essentially unchanged, except that individual drawback claims (K32 or K32-1) are not submitted to the CBSA. In lieu of submitting individual claims, the CSA importer submits a new form called a Summary of Drawback Activity (SDA), Form CBSA130.
205. The SDA summarizes details such as the claim number, authority and amount claimed for the RSF period. The SDA also identifies claims affected by the limitations imposed by Article 303 of the NAFTA and, where this is identified, “satisfactory evidence” must be submitted with the SDA. A sample of the SDA and instructions to complete the form are provided in Appendix I of this memorandum, and on our Web site at www.cbsa.gc.ca.
206. The total drawback claimed, as listed on the SDA, is included on the RSF of the CSA importer. The amount claimed on the RSF must match the amount calculated on the SDA for that RSF period. Filing time limits are linked to the RSF period in which the relevant drawback is claimed.
207. Although individual drawback claims are not submitted to the CBSA, CSA importers must continue to prepare their claims. The claims, as well as supporting documentation, certificates and schedules are to be retained by the importer and must be made available to a border services officer upon request, for CBSA verification.
208. Where a drawback repayment is necessary, the details will be included on the SDA and the amount of repayment is deducted from other drawback amounts claimed on that SDA. If the repayment exceeds the amount claimed, a negative will result. This negative amount is listed as a debit on the RSF, using the applicable drawback coding (e.g. 49019). Interest must be applied at the specified rate from the date of the credit of original SDA to the date of the repayment RSF. The CSA importer must retain appropriate records for verification.
209. When goods no longer qualify for relief under the Duties Relief Program and repayment of duties is required, the repayment must be included on the RSF. This will be listed as a debit on the RSF using the “duty on adjustments” coding (49010). Appropriate records are to be retained by the CSA importer for verification. Interest is applicable at the specified rate.
210. The X-type automated adjustment process may be used by the CSA importer to submit a voluntary amendment to pay additional anti-dumping, countervailing duties or provisional duties, in accordance with sections 3, 4, 5, 6, 7, or 8 of SIMA or surtax, in accordance with an Order in Council. In addition, the X-type entry may be used to correct clerical errors that have no revenue impact. As with other X-type automated adjustments, the entry-acceptance message generated by CCS will provide the notice of decision.
211. Code E, “Other Adjustments”, is completed in Field 6 (Payment Code) of the X-type transmission.
212. Requests for downward adjustment of anti-dumping or countervailing duties continue to be submitted to the CSBA on a hard-copy B2. For additional information, please refer to Memorandum D14-1-3.
213. The applicable monies owing as a result of a voluntary amendment are reported on the RSF as a debit against line object code 49011. Refunds of SIMA duties that are the result of a re-determination submitted on a hard-copy B2 are reported on the RSF as a credit against line object code 49018.
214. The automated X-type adjustment is used to transmit a correction related to a NAFTA or CCFTA preferential tariff treatment. In these cases, adjustments must relate the original accounting transaction and line number of the importations involved. The original accounting transaction number is completed in Field 24 (previous transaction number) and the original line number is completed in Field 25 (previous transaction line) of both line one and line two. For consolidated adjustments that relate to a preferential tariff treatment under NAFTA or CCFTA, the original transaction number and line number of the earliest transaction being adjusted is used to complete Fields 24 and 25.
215. The RSF revenue reporting and remittance process for origin is the same as other automated self-adjustments. Supporting documentation such as a certificate of origin is required, but does not need to be submitted with the X-type adjustment unless requested by a border services officer.
216. To ensure that imports of a TRQ “within access commitment tariff item” are classified correctly, adjustments relating to TRQ products require individual review by a border services officer. These adjustments must continue to be submitted to the CBSA on a hard-copy B2, Canada Customs – Adjustment Request form with supporting documentation.
217. A summary of general process requirements is included in Appendix J of this memorandum.
2.(1) In this Act,
Where excess amount to be paid
3.5 Except in the circumstances that the Minister may specify, every person who makes a payment of any amount under this Act shall, if the amount exceeds the amount specified by the Minister, make the payment to the account of the Receiver General in the prescribed manner and within the prescribed time at
4. Where more than one person is responsible for the performance of any obligation under this Act, performance of the obligation by any one of them shall be deemed to be performance by all of them.
4.1 In the case of goods to which paragraph 32(2)(b) applies, the Minister may accept from an importer or transporter an undertaking to assume obligations in relation to compliance with this Act and the regulations.
7.1 Any information provided to an officer in the administration or enforcement of this Act, the Customs Tariff or the Special Import Measures Act or under any other Act of Parliament that prohibits, controls or regulates the importation or exportation of goods, shall be true, accurate and complete.
Goods charged with duties from importation
17.(1) Imported goods are charged with duties thereon from the time of importation thereof until such time as the duties are paid or the charge is otherwise removed.
(2) Subject to this Act, the rates of duties on imported goods shall be the rates applicable to the goods at the time they are accounted for under subsection 32(1), (2) or (5) or, where goods have been released in the circumstances set out in paragraph 32(2)(b), at the time of release.
31. Subject to section 19, no goods shall be removed from a customs office, sufferance warehouse, bonded warehouse or duty free shop by any person other than an officer in the performance of his or her duties under this or any other Act of Parliament unless the goods have been released by an officer or by any prescribed means.
32.(1) Subject to subsections (2) and (4) and any regulations made under subsection (6), and to section 33, no goods shall be released until
(2) In prescribed circumstances and under prescribed conditions, goods may be released prior to the accounting required under subsection (1) if
(3) If goods are released under subsection (2), they shall be accounted for within the prescribed time and in the manner described in paragraph (1)(a) by, in the case of goods to which paragraph (2)(a) applies, the person who made the interim accounting under that paragraph in respect of the goods and, in the case of goods to which paragraph (2)(b) applies, by the importer or owner of the goods.
(4) In such circumstances, and under such conditions, as may be prescribed, goods imported by courier or as mail may be released prior to the accounting required under subsection (1) and prior to the payment of duties thereon.
(5) Where goods are released under subsection (4),
(5.1) Except in prescribed circumstances, where the importer or owner of mail that has been released as mail under subsection (4) takes delivery of the mail, the mail shall be deemed to have been accounted for under subsection (5) at the time of its release.
(6) The Governor in Council may make regulations
(7) The Minister or an officer designated by the Minister for the purposes of this subsection may authorize any person not resident in Canada to account for goods under this section, in such circumstances and under such conditions as may be prescribed, in lieu of the importer or owner thereof.
32.1(1) Subject to this section, every person who accounts for goods under subsection 32(1), (3) or (5) shall, at the time of accounting, furnish an officer at a customs office with the statistical code for the goods determined by reference to the Coding System established pursuant to section 22.1 of the Statistics Act.
(2) The statistical code referred to in subsection (1) shall be furnished in the prescribed manner and in the prescribed form containing the prescribed information.
(3) The Governor in Council may make regulations exempting persons or goods, or classes thereof, from the requirements of subsection (1) subject to such conditions, if any, as are specified in the regulations.
32.2(1) An importer or owner of goods for which preferential tariff treatment under a free trade agreement has been claimed or any person authorized to account for those goods under paragraph 32(6)(a) or subsection 32(7) shall, within ninety days after the importer, owner or person has reason to believe that a declaration of origin for those goods made under this Act is incorrect,
(2) Subject to regulations made under subsection (7), an importer or owner of goods or a person who is within a prescribed class of persons in relation to goods or is authorized under paragraph 32(6)(a) or subsection 32(7) to account for goods shall, within ninety days after the importer, owner or person has reason to believe that the declaration of origin (other than a declaration of origin referred to in subsection (1)), declaration of tariff classification or declaration of value for duty made under this Act for any of those goods is incorrect,
(3) A correction made under this section is to be treated for the purposes of this Act as if it were a re-determination under paragraph 59(1)(a).
(4) The obligation under this section to make a correction in respect of imported goods ends four years after the goods are accounted for under subsection 32(1), (3) or (5).
(5) This section does not apply to require or allow a correction that would result in a claim for a refund of duties.
(6) The obligation under this section to make a correction to a declaration of tariff classification includes an obligation to correct a declaration of tariff classification that is rendered incorrect by a failure, after the goods are accounted for under subsection 32(1), (3) or (5) or, in the case of prescribed goods, after the goods are released without accounting, to comply with a condition imposed under a tariff item in the List of Tariff Provisions set out in the schedule to the Customs Tariff or under any regulations made under that Act in respect of a tariff item in that List.
(7) The Governor in Council may make regulations prescribing the circumstances in which certain goods are exempt from the operation of subsection (6) and the classes of goods in respect of which, the length of time for which and the conditions under which the exemptions apply.
(8) If a declaration of tariff classification is rendered incorrect by a failure referred to in subsection (6), for the purposes of paragraph (2)(b), duties do not include duties or taxes levied under the Excise Act, 2001, the Excise Tax Act or the Special Import Measures Act.
40. (1) Every person who imports goods or causes goods to be imported for sale or for any industrial, occupational, commercial, institutional or other like use or any other use that may be prescribed shall keep at the person’s place of business in Canada or at any other place that may be designated by the Minister any records in respect of those goods in any manner and for any period of time that may be prescribed and shall, where an officer so requests, make them available to the officer, within the time specified by the officer, and answer truthfully any questions asked by the officer in respect of the records.
(2) If, in the opinion of the Minister, a person has not kept records in accordance with subsection (1), the Minister may request that person to comply with that subsection in respect of the records.
(3) The following persons shall keep at their place of business or at any other place that may be designated by the Minister the prescribed records with respect to the prescribed goods, in the manner and for the period that may be prescribed, and shall, where an officer requests, make them available to the officer, within the time specified by the officer, and answer truthfully any questions asked by the officer in respect of the records:
(4) Where, in the opinion of the Minister, a person has not kept records in respect of goods in accordance with subsection (3), the Minister may request that person to comply with that subsection in respect of the goods.
51. (1) Subject to subsections (5) and 47(3), where the value for duty of goods is not appraised under sections 48 to 50, the value for duty of the goods is the deductive value of the goods if it can be determined.
(2) The deductive value of goods being appraised is
(3) For the purposes of subsection (2), the price per unit, in respect of goods being appraised, identical goods or similar goods, shall be determined by ascertaining the unit price, in respect of sales of the goods at the first trade level after importation thereof to persons who
(4) For the purposes of subsection (2), the price per unit, in respect of goods being appraised, identical goods or similar goods, shall be adjusted by deducting there from an amount equal to the aggregate of
(5) Where there is not sufficient information to determine an amount referred to in paragraph (4)(e) in respect of any goods being appraised, the value for duty of the goods shall not be appraised under paragraph (2)(c).
(6) In this section, “time of importation” means
74.(1) Refund — Subject to this section, section 75 and any regulations made under section 81, a person who paid duties on any imported goods may, in accordance with subsection (3), apply for a refund of all or part of those duties, and the Minister may grant to that person a refund of all or part of those duties, if
(1.1) The granting of a refund under paragraph (1)(c.1), (c.11), (e) or (f) or, if the refund is based on tariff classification, value for duty or origin, under paragraph (1)(g) is to be treated for the purposes of this Act, other than section 66, as if it were a re-determination made under paragraph 59(1)(a).
(1.2) The duties that may be refunded under paragraph (1)(f) do not include duties or taxes levied under the Excise Tax Act, the Excise Act or the Special Import Measures Act.
(2) No refund shall be granted under any of paragraphs (1)(a) to (c) and (d) in respect of a claim unless written notice of the claim and the reason for it is given to an officer within the prescribed time.
(3) No refund shall be granted under subsection (1) in respect of a claim unless
(4) A denial of an application for a refund of duties paid on goods is to be treated for the purposes of this Act as if it were a re-determination under paragraph 59(1)(a) if
(5) For greater certainty, a denial of an application for a refund under paragraph (1)(c.1), (c.11), (e), (f) or (g) on the basis that complete or accurate documentation has not been provided, or on any ground other than the ground specified in subsection (4), is not to be treated for the purposes of this Act as if it were a re-determination under this Act of origin, tariff classification or value for duty.
(6) The Minister, within four years after goods are accounted for under subsection 32(1), (3) or (5), may refund all or part of duties paid on imported goods without application by the person who paid them if it is determined that the duties were overpaid or paid in error in any of the circumstances set out in
(7) The duties that may be refunded under subsection (6) do not include duties or taxes levied under the Excise Act, the Excise Tax Act or the Special Import Measures Act or a surtax or temporary duty imposed under Division 4 of Part II of the Customs Tariff.
(8) A person of a prescribed class may apply, within four years after goods are accounted for under subsection 32(1), (3) or (5), in prescribed circumstances and under prescribed conditions, the amount of any refund to which they are entitled under this section to the payment of any amount for which they are liable or may become liable under this Act.
109.1 (1) Every person who fails to comply with any provision of an Act or a regulation designated by the regulations made under subsection (3) is liable to a penalty of not more than twenty-five thousand dollars, as the Minister may direct.
(2) Every person who fails to comply with any term or condition of a licence issued under this Act or the Customs Tariff or any obligation undertaken under section 4.1 is liable to a penalty of not more than twenty-five thousand dollars, as the Minister may direct.
(3) The Governor in Council may make regulations
2.(1) In this Act,
“release” « dédouanement »
These regulations may be viewed on the Department of Justice Canada Web site at http://laws.justice.gc.ca.
Customs Self Assessment
Canada Border Services Agency
P.O. Box 7000, Station A
Mississauga ON L5A 3A4
CSA/FAST Carrier Compliance
Canada Border Services Agency
55 Bay Street North, 6th Floor
Hamilton ON L8R 3P7
Customs Self Assessment
Canada Border Services Agency
1980 Matheson Boulevard East
Mississauga ON L4W 5R7
Calls within Canada 1-800-461-9999 (English)
TTY within Canada 1-866-335-3237
Calls outside Canada 204-983-3500
(Long-distance charges apply) 506-636-5064
As part of the Customs Self Assessment (CSA) application and approval process, importers must submit an inventory of their trade chain partners to the Canada Border Services Agency (CBSA), as follows:
The following outlines the medium on which the list of vendors and consignees must be submitted:
|Number of Vendors and Consignees||Medium to be Used|
|25 or less||include in writing on Part II application|
|between 26 and 1,000||diskette or CD-ROM|
|between 1,001 and 6,000||CD-ROM|
|more than 6,000||magnetic tape|
The following instructions are for importers, who have a list of more than 25 vendors and direct-shipped consignees, to submit to the CBSA.
It is important that the media submitted conform to the media specifications outlined below. Submissions that do not conform to the specifications cannot be uploaded to CBSA systems and will be returned to the applicant. This may lead to delays in the application and approval process.
If a diskette is being submitted, please indicate in writing on the diskette the name of your company, and the name/source of the file.
If a CD-Rom is being submitted, please indicate in writing on the CD-ROM the name of your company, and the name/source of the file.
Also, the CD-ROM must:
If a magnetic tape is being submitted, please indicate the following in writing on the magnetic tape or an attachment:
Also, the magnetic tape must:
Note: One file with multi-volume tapes with only one header and one trailer can be copied, up to a maximum of eight volumes.
It is important that the information provided on diskette, CD-Rom, or magnetic tape, conform to the flat file specifications outlined below. Only flat files in fixed length records with a .txt extension can be accepted by the CBSA and uploaded into CBSA systems. Submissions that do not conform to the specifications and cannot be uploaded to CBSA systems will be returned to the applicant. This will lead to delays in the application and approval process.
CBSA will not manipulate submissions to conform to the flat-file specifications. Should corrections or updates to submissions be required, the CBSA cannot accept them by e-mail.
Flat files consist of the following:
The file must begin with a header record, which must be 450 bytes (i.e. 450 characters, including spaces). All the fields listed below are mandatory at the specified length. Complete the header record with a hard return (i.e. press ‘enter’).
|1||Record Identifier||2 numeric||Must be ‘00’|
|2||Business Number||9 numeric||The 9-digit business number of the CSA importer.|
|3||Filler||439 spaces||439 blank spaces|
Example: The header record should begin like this: 00123456789 and be followed by 439 blank spaces. Do not fill with zeros.
Each line (i.e. each vendor or consignee record) must contain 450 bytes (i.e. 450 characters, including spaces). All the fields listed below are mandatory at the set length specified. Any unused characters must be spaces. (Do not input “0”s) At the end of each line, include a hard return (i.e. press ‘enter’).
|1||Record Identifier||2 numeric||Must be ‘02’ for consignee records
Must be ‘03’ for vendor records
|2||Business Number||15 alphanumeric||BN must be a recognized division of a CSA applicant. Must be nine digits, the identifier RM followed by four digits||123456789RM0001|
|3||TCP Type Code||2 numeric||Must be one of the following:
01 – Dunn and Bradstreet
02 – internal
03 – business number (CDN registered companies)
04 – internal revenue service United States
05 – SCAC #
06 – other
|4||TCP Identifier||15 alphanumeric||Must be 15 characters (including spaces) Will accept number or letters. This must be unique and not duplicated.||12345 67890abcd|
|5||Address Line 1||30 characters||Must have at least two characters; At least one character must be numeric. Will accept punctuation and symbols. Must fill with spaces to equal 30 characters.||128th St.|
|6||Address Line 2||30 characters||Will accept punctuation and symbols. Must fill with spaces to equal 30 characters.||Unit 88|
|7||City||30 characters||Must have at least two characters. Will accept punctuation and symbols. (e.g. St. John’s) Must fill with spaces to equal 30 characters.||New York|
|8||Province/State Code||2 alpha||For consignee records:
A valid province is mandatory.
For Vendor Records: If country code is “United States”, a valid state code is mandatory; If country code is not “United States” a two-character province/state code can be entered, otherwise it must be filled with two blank spaces.
|9||Country Code||2 alpha||For consignee records: Must = “CA”
For Vendor Records: Cannot = “CA”
|10||Postal/Zip Code or other country postal code||10 alphanumeric||For consignee records: Must be valid postal code (no space in the middle)
For Vendor Records: If country code is “United States” then a valid ZIP code is required. A five-digit ZIP code must be followed by five spaces and a nine-digit ZIP code cannot have the hyphen and must be followed by one space. If country code is not “United States”, another country postal code can be entered, otherwise it must be filled with 10 spaces.
|11||Business Name||175 alphanumeric||Must be at least two alphanumeric; Will accept punctuation and symbols. Must fill with spaces to equal 175 characters.||ABC Importing|
|12||Filler||137 spaces||Must fill with 137 spaces.||137 spaces|
The total record must be comprised of 450 characters- including spaces.
The file must end with a trailer record, which must be 450 bytes (i.e. 450 characters, including spaces). All the fields listed below are mandatory at the specified length. Any unused characters must be spaces. Do not include a hard return at the end of the trailer record (i.e. do not press ‘enter’).
|1||Record Identifier||2 numeric||Must be “99”|
|2||Number of Records||9 numeric||The number of records in the file, including the header and trailer records. This number must have preceding zeros (e.g. 000000076)|
|3||Filler||439 blank spaces||439 spaces|
Example: If you had 74 vendors and consignees in the file and, remembered to add the header and trailer records, the trailer would be 99000000076 followed by 439 spaces. Do not fill with zeros.
Submissions will be rejected if:
1. The transition of an importer from traditional CBSA processes to the CSA environment is critical, and requires careful coordination between the SPO, the importer, the service providers and the CBSA. In particular, the implications of the importer’s CSA “start date” need to be clearly understood and applied. On the importer’s CSA start date, transactions submitted to the CBSA with the 15-digit BN of the CSA-approved importer are processed using CSA procedures and the processing of records in ACROSS and CCS will change. These changes include:
2. It is important to note that while most elements of the CSA importer’s business with the CBSA will transfer to CSA processing on the start date, there could be some business activities that may require completion under pre-CSA processing. The following table is provided as a guideline to determine if a CBSA process is completed using a CSA or pre-CSA procedure. To determine the process environment that will apply, there are two key steps:
|Customs Element||Status on CSA Start Date||Transition process|
|Cargo Reporting||Cargo not acquitted on or after the importer’s start date.||Overdue cargo report is generated but tracers not issued. To avoid liability, carriers should obtain proof of delivery from the CSA importer during and after transition period.|
|Release||Release decision or request date is on or after CSA start date.||CSA process applies; i.e. date of release is the date the shipment is physically received at the importer/owner/consignee’s place of business. ACROSS will not search for acquittal of release decision from CCS. Extended accounting time frames apply.|
|Release decision is made before the CSA start date and release is not accounted for by the start date||Overdue release report will be generated but manually acquitted by the CBSA. Importer is to use CSA processes; i.e. account for, report revenue on RSF and pay at financial institution.
Note that these goods may have been physically received by the importer/owner/consignee before the start date and could fall outside the importer’s business accounting trigger. Importer/ service provider is to ensure that these non-acquitted shipments transfer to the RSF remittance procedures.
|Accounting||The B3 is in entry-acceptance status 250 before the CSA start date.||Pre-CSA process will occur and B3 will appear on a K84.
Payment made at a CBSA office.
|The B3 has not reached entry acceptance status 250 on or after the CSA start date.||CSA processing is to be used, i.e. The B3 will not appear on a K84. Related revenue amounts are reported on RSF and payment made at financial institution.|
|Adjustment||Hard-copy B2 is submitted to the CBSA and inventoried before the CSA start date.||Pre-CSA processing is to be used; i.e. DAS will be issued, and payment made to the CBSA (amount owing by importer) or cheque issued (amount due to importer).|
|Hard-copy B2 submitted to the CBSA is inventoried on or after the CSA start date.||The B2 will be keyed into CCS but as an ACOR. DAS will be issued but related revenue amounts are to be reported by the importer on the RSF. Amounts owing to the CBSA are reported as a debit on the RSF and paid at a financial institution; amounts due to the importer are credited on the RSF.|
|Automated adjustment (X-type B3) transmitted on or after the CSA start date||CSA processing will apply, i.e. no DAS issued, revenue amounts reported on RSF. Amounts owing to the CBSA are reported as a debit on the RSF paid at a financial institution; amounts due to the importer are credited on the RS|
|Non-CSA Importers||CSA Option 1||CSA Option 2|
|Release Period||N/A||In the context of providing B3 trade data, 1st to 31st day of Month One.||In the context of providing B3 trade data, 19th day of Month One to 18th of Month Two.|
|Trade Data Reporting (B3)||B3 due within five business days of release (individually)||B3s for receipts/releases from 1st to 31st day of Month One due by 18th of Month Two.||B3s for receipts/releases from 19th day of Month One to 18th day of Month Two are due by last business day (LBD) of Month Two.|
|Trade Data Reporting Trigger||B3 provided based on the CBSA release date||Three-way match between purchase order, receipt and invoice, or equivalent, in books and records. At least two monthly “sweeps” are recommended to account for goods not yet matched:
a) by the 18th day of the month (for trade data reporting); and
b) before the cut-off date (to ensure records within the payment time frame are included on the RSF). Same for LVS.
Other processes are accepted where books and records cannot trigger; however, audit trails must be in place.
|Three-way match between purchase order, receipt and invoice, or equivalent, in books and records. At least one “sweep” is recommended before the last business day of the month to ensure both trade data and payment are included on the RSF. Same for LVS.
Other processes are accepted where books and records cannot trigger; however, audit trails must be in place.
|Time to submit B3||Within five business days after release||Min: 18 days or 12 business days
Max: 49 days
|Min: 10 days or eight business days
Max: 43 days
|Payment Period and Monthly Payment||B3s accepted between 25th of Month One and 24th of Month Two are paid LBD of Month Two.||Receipts/releases from 19th of Month One to the 18th day of Month Two must be paid by LBD of Month Two.||Receipts/releases from 19th day of Month One to 18th day of Month Two must be paid by LBD of Month Two.|
|Billing Statement||Bill (K84) is issued by the CBSA on 25th of Month Two for B3s accepted between 25th day of Month One and 24th day of Month Two.||Importer prepares billing statement (Revenue Summary Form - RSF) detailing duty and tax breakouts for all the B3 and adjustment data accepted between the company’s “period start” and “period end” dates. Submitted by LBD of the month in which the payment period ends.||Importer prepares RSF detailing duty and tax breakouts for all the B3 and adjustment data accepted between the company’s “period start” and “period end” dates. Submitted by LBD of the month in which the payment period ends.|
|Interim Payment||N/A||Optional - Duty and tax estimates on goods that were received/ released but were not accounted for before the submission of the RSF.||Optional - Duty and tax estimates on goods that were received/ released but were not accounted for before the submission of the RSF.|
|Interim Payment Reconciliation||N/A||Interim payment is credited the following month. Actuals reported on RSF. This results in an offset. If actuals are greater than interim payment, difference is paid; if actuals are less than interim payment difference is credited.||Interim payment is credited the following month. Actuals reported on RSF. This results in an offset. If actuals are greater than interim payment, difference is paid; if actuals are less than interim payment difference is credited.|
|Interim Payment Interest||N/A||Difference noted above is subject to interest calculations (debit or credit). Interest is self-assessed by the importer and recorded on RSF.||Difference noted above is subject to interest calculations (debit or credit). Interest is self-assessed by the importer and recorded on RSF.|
|Late Accounting (B3) Penalty||Transactions for goods having a value for duty of $1,600 or more must be accepted by the CBSA within five business days after their release, or a penalty of $25 for each late transaction is assessed.||If importers account for any goods from Month One after the 18th of Month Two, they will incur a late-accounting penalty. Where compliance falls below 99.5 percent on a calendar year basis, the penalty is $50 per transaction below the compliance level. During the calendar year, nil-rated warning notices will be automatically issued to establish the compliance rate. The penalty for late accounting that falls below the compliance level will be assessed by the CBSA, manually billed to the importer, and paid on the next RSF.||Any transaction from the 19th of Month One to the 18th of Month Two not accounted for by the LBD of Month Two will incur a late-accounting penalty. Where compliance falls below 99.5 percent on a calendar year basis the penalty is $50 per transaction below the compliance level. During the calendar year, nil-rated warning notices will be automatically issued to establish the compliance rate. The penalty for late accounting that falls below the compliance level will be assessed by the CBSA, manually billed to the importer, and paid on the next RSF.|
|Late Transaction (B3) Payment Interest||Late-payment interest applies to B3 transaction amounts that are late and not paid by the K84 monthly payment due date, i.e. the last business day of the month.||Any goods received/released between the 19th day of Month One to the 18th day of Month Two not duty-paid by the LBD of Month Two will incur late transaction payment interest. This will be self-assessed by the importer and added to the next applicable RSF.||Any goods received/released between the 19th day of Month One to the 18th day of Month Two not duty-paid by the LBD of Month Two will incur late transaction payment interest. This will be self-assessed by the importer and added to the next applicable RSF.|
|Remittance at a Financial Institution||N/A – (Payment for K84 issued the 25th day of Month Two is made directly to the CBSA cashier by LBD of Month Two.) Same for LVS.||Payment for RSF is required to be made directly at financial institution by LBD of the Month in which the related RSF is due. Same for LVS.||Payment for RSF is required to be made directly at financial institution by LBD of the Month in which the related RSF is due. Same for LVS.|
|Late-payment Interest||Late payment of the K84 is assigned late-payment interest by the Customs Commercial System (CCS). It will automatically appear on the K84 for the following month. Same for LVS.||If remittance for the RSF is made late by the importer, the importer will self-assess late payment interest. Same for LVS.||If remittance for the RSF is made late by the importer, the importer will self-assess late payment interest. Same for LVS.|
|Non-CSA Importers||CSA Option 1||CSA Option 2|
|Release Period||1st to 31st of Month One||Same as non-CSA.||Same as non-CSA.|
|Trade Data Reporting (B3)||B3s for releases from 1st to 31st of Month One due by 24th day of Month Two.||Same as non-CSA, or same as HVS Option 1.||Same as non-CSA, or same as HVS Option 2.|
|Shortest time to submit B3||24 days or 17 business days.||Same as non-CSA, or same as HVS Option 1.||Same as non-CSA, or same as HVS Option 2.|
|Payment Period and Monthly Payment||B3s accepted between 25th day of Month One and 24th of Month Two are paid LBD of Month Two.||Receipts/releases from 1st to 31st day of Month One shall be paid by LBD of Month Two.||Receipts/releases from 1st to 31st day of Month One shall be paid by LBD of Month Two.|
|Billing Statement||Bill (K84) is issued by the CBSA on 25th day of Month Two for B3s accepted between 25th day of Month One and 24th day of Month Two.||Importer prepares billing statement (Revenue Summary Form - RSF) detailing duty and tax breakouts for all the B3 and adjustment data transmitted between the company’s “period start” and “period end” dates. Submitted by LBD of the month in which the payment period ends. (Combined with RSF for HVS.)||Importer prepares billing statement (Revenue Summary Form - RSF) detailing duty and tax breakouts for all the B3 and adjustment data transmitted between the company’s “period start” and “period end” dates. Submitted by LBD of the month in which the payment period ends. (Combined with RSF for HVS.)|
|Late-accounting (B3) Penalty||Any transaction under $1,600 VFD from Month One not accounted for by the 24th day of Month Two is manually issued a late accounting penalty by the CBSA office on the 25th day of Month Two.||If importers account for any goods from Month One after the 24th day of Month Two, they will incur a late accounting penalty. This will be assessed by the CBSA during verification and billed to the importer.||If importers account for any goods received/released between the 1st and 18th of Month One after the 24th day of Month Two, they will incur a late accounting penalty. If importers account for any goods received/ released between the 19th and last calendar day of Month One after the LBD of Month Two, they will incur a late accounting penalty. This will be assessed by the CBSA during verification and billed to the importer.|
|Late-accounting (B3) Payment Interest||Late-accounting interest is manually calculated and issued by the CBSA office.||If importers pay for goods from Month One after the LBD of Month Two, they will incur late accounting interest. This will be self-assessed and added to the next applicable RSF by the importer.||If importers pay for goods from Month One after the LBD of Month Two, they will incur late accounting interest. This will be self-assessed and added to the next applicable RSF by the importer.|
Corrections to original accounting declarations using the X-type entry are to be transmitted using existing CADEX records. Detailed information about the X-type B3, electronic formats are located in Appendix C of the CSA Electronic Commerce Client Requirement Document (ECCRD).
Where a correction is made to an original accounting declaration, the importer is required to maintain an audit trail among the adjustment, source documents and the commercial books and records related to the importation.
The X-type entry can be used to correct original accounting information using either one of two methods:
Note: While the negative sign is used in the following examples to illustrate negative values, the negative sign is not used for X-type transmission. In fact, the following representations are presented for illustration only, since the X-type will never appear in the paper format as shown in these examples. Negative values, along with all the other numbered fields, are actually transmitted, using specific CADEX record types that are provided in the CSA importer ECCRD.
Amounts, including interest, owed to or by the CSA importer as the result of an adjustment, are reported on the importer’s RSF. Duties, GST and interest due to the CBSA are reported as a debit against the respective line object code. Duties and interest due to the importer are reported on the RSF as a credit against the respective line object code.
Entry-acceptance message received for automated self-adjustments to declarations of Origin, Tariff Classification, Value for Duty, and Diversion of goods:
“Your adjustment request has been granted and has been treated as a re-determination under subsection 59(1)(a) of the Customs Act. The CBSA reserves the right to further review (sic) and re-determine at a later date under subsection 59(1)(b) of the Customs Act. If the CBSA does make further re-determination you may be required to re-pay an amount of any refund granted. A request for further re-determination respecting this decision may be made within 90 days of the date of this notice, on form B2, pursuant to subsection 60(1) of the Customs Act.”
Entry-acceptance message received for automated self-adjustments to make a voluntary payment of SIMA duties:
“Your adjustment request has been granted and has been treated as a re-determination under section 57 of the Special Import Measures Act (SIMA). The CBSA reserves the right to further review (sic) and re-determine at a later date under section 59 of SIMA. A request for further re-determination respecting this decision may be made within 90 days of the date of this notice, on Form B2, pursuant to section 58 of SIMA.”
An electronically fillable version of the Summary of Drawback Activity form is available at www.cbsa.gc.ca.
How to complete the CBSA130, Summary of Drawback Activity
CSA importer name and Business Number (to the RM level) – This information has to match your entry on Form E648, CSA Revenue Summary. The Summary of Drawback Activity and the CSA Revenue Summary are directly related. All drawbacks you list on your monthly Summary of Drawback Activity have to appear on your Revenue Summary for that month.
RSF month – Enter the date (i.e., last business day of the month) you paid the amount.
Authority – Enter the legislative authority under which you are claiming the drawback.
NAFTA – Enter “Yes”, if your drawback is affected by the limitations imposed by Article 303 of NAFTA (i.e., satisfactory evidence).
Claim number – Enter the CSA importer’s internal claim reference number. An importer will use this number to identify a claim and its supporting documents. An importer will not repeat a claim number during any four-year period.
Plant – Enter the code or location of the plant where the goods are used in production.
K32A vendor and K32B exporter name – Enter the K32A vendor name, city and province as they appear on any relevant K32A certificate(s), and the K32B exporter name, city and province, as they appear on any relevant K32B certificate(s).
Claim period – Enter the period covered by the claim (e.g. export period, production period or sales period).
Amount filed – Enter the dollar amount of the drawback you are claiming, for each individual claim.
Total claimed – Enter the total amount filed, by totalling all drawback amounts claimed on one month’s Summary of Drawback Activity. This amount has to agree with the corresponding information on your Form E648.
You do not have to match the B3 trade data being claimed on the drawback to the revenue summary accounting period. However, you must have accounted for and paid duty on the goods before claiming a drawback on those goods.
As a CSA importer, you can record any drawback claims (i.e. offsets) on the Summary of Drawback Activity for the month, for which you:
If a filing time limit falls within the revenue summary period during which you claim a relevant drawback, we consider that time limit as having been met.
We have provided the Summary of Drawback Activity as a guide to help CSA importers in the display and presentation of the drawback summary information they need to support the Revenue Summary. On agreement between the CBSA and a CSA importer, other formats for display and presentation will be accepted.
If a CSA importer files a Summary of Drawback Activity on which a drawback is identified as having been claimed, we will consider that the importer has received the drawback.
The points below are provided as a general overview of the CSA process requirements of the CSA importer:
|Code||English description||Description française|
|49010||Import Duties||Droits d’importation|
|49011||Special Assessment||Cotisation speciale|
|49017||Refund of Import Duties||Remboursement des droits d’importation|
|49018||Refund of Anti-dumping Duty (HQ)||Remboursement du droit antidumping (AC)|
|49019||Drawback of Import Duties||Drawbacks des droits d’importation|
|49020||Drawback of Anti-dumping Duty||Drawbacks du droit sur l’antidumping|
|49021||Drawback of Countervailing Duty||Drawbacks du droit compensatoire|
|49121||Goods and Services Tax/Harmonized Sales Tax – Revenue||Taxe sur les produits et services/Taxe de vente harmonisee — Revenu|
|49129||GST/HST – Credit for Current Month Corrections on Forms E648||TPS/TVH – Crédit pour les corrections au mois courant sur les formulaires E648|
|49177||Refund of Sales Tax on Importation||Remboursement de la taxe de vente sur les importations|
|49179||Drawbacks on Importation||Drawbacks sur les importations|
|49407||All Refunds on Importation Excise Tax||Tous les remboursements sur la taxe d’accise a l’importation|
|49409||All Drawbacks on Importation Excise Tax Except Gasoline||Tous les drawbacks sur la taxe d’accise à l’importation, à l’exception de l’essence|
|49425||Automotive Air Conditioners||Conditionneurs d’air d’automoteur|
|49437||Excise Tax – Interest Payable on Refund and Drawback Claims (Importations)||Taxe d’accise — Intérets a payer se rapportant aux remboursements et drawbacks (Importations)|
|49438||Wines – Less Than 7%||Vins – Moins de 7 %|
|49439||Penalty Amount Refunded||Remboursement sur les amendes|
|49441||Penalty for Late Accounting||Amendes pour comptes en souffrance|
|49442||Interest on Late Payment of Revenue Summary Form||Interet pour les paiements en retard des sommaires des recettes|
|49443||Interest on Late Payment of Individual Transactions||Interet pour les paiements en retard des transactions individuelles|
|49450||Wines - More Than 7%||Vins – Plus de 7 %|
|49452||Excise Tax Penalty - Importation||Amendes sur taxe d’accise – Importation|
|49453||Excise Tax - Importations Misc||Divers|
|49454||Excise Tax Interest - Importation||Interet sur taxe d’accise – Importation|
|49460||Excise Tax on Gasoline||Taxe d’accise sur l’essence|
|49475||Excise Tax - Casual Importations||Taxe d’accise – Importations occasionnelles|
|49555||Interest on Various Adjustments; Diversions, Quantity, Price, Retroactive, etc.||Adjust. divers d’interet; quantité; prix etc|
|49745||Special Services Fees||Droits de services spéciaux|
|49764||Port Seizures||Saisies dans les ports|
|49766||Customs Penalties||Amendes douanières|
|49874||Int. Pd on Late Pym of Pen AMPS||Int pay sur pai de l’amende RS|
|49875||Amps – Customs||Rsap la douane|
|49876||Rfd Amps Pen & Int||Rem au rsap amdes et int|
|49878||Int Rfd of Amps||Int pay sur rembsnts rsap|
|49530||Beer – Not More Than 1.2%||Bière - pas plus de 1.2 %|
|49531||Beer – Not More Than 2.5%||Bière - pas plus de 2.5 %|
|49532||Beer – More Than 2.5%||Bière plus que 2.5 %|
|49540||Matured Spirits||Alcool à point|
|49541||Unmatured Spirits||Alcool non à point|
|49542||Spirit Coolers||Boissons rafraîch alcoolisées|
|49613||MB – Prov. Alcohol Levies||Impot prov. boiss. alcoolisées - MB|
|49673||MB – Prov. Sales Tax||Taxe de vente provinciale - MB|
|Issuing office||Customs Self Assessment Program
Trusted Traders Division
|Legislative references||Customs Act, section 32(2)(b)|
|Other references||D1-6-1, D3-1-7, D11-6-5, D11-6-6, D11-6-7, D14-1-3, D14-1-5, D14-1-6, D17-1-5, D7-2-3
Electronic Commerce Client Requirement Document (ECCRD)
|Superseded memoranda D||D17-1-7, August 14, 2009|