Share your thoughts: Consultation on the use of the customs broker business number (BN) following importer of record regulatory legislative changes
Current status: Closed
Opened on and closed on .
The Canada Border Services Agency (CBSA) is seeking feedback on new scenarios in which customs brokers would be authorized to use their business number (BN) to submit accounting declarations on behalf of importers who are not yet registered in the CBSA Assessment and Revenue Management (CARM) system.
Join in: how to participate
Send an email to cbsa.licensing_unit-unite_agrements.asfc@cbsa-asfc.gc.ca.
Who is the focus of this consultation
The CBSA is seeking feedback from:
- commercial importers
- customs brokers
- trade chain partners
- industry associations
- other government departments
- other interested stakeholders
What is the focus of this consultation
Following the launch of CARM, the CBSA developed transition measures to allow importers to obtain financial security after they were no longer able to use a customs broker's security to release their imported goods.
As of , following amendments to the Customs Act, the importer of record will be jointly and severally liable with the importer and owner of the goods for any amounts owing in duties and taxes.
The CBSA is considering scenario-specific exemptions in which importers can authorize customs brokers to do business with the CBSA on their behalf even though the importer is not yet registered in CARM. We need your help to identify in which situations this would be most beneficial.
The current exempt circumstances, as described in Customs Notice 24-27:
- commercial importation (commercial and Courier Low Value Shipment streams)
- non commercial importation (commercial stream)
- non commercial importation (Courier Low Value Shipment stream)
- trade show or convention
We are seeking your input on whether the following circumstances should be added:
- major events (for example, entertainment, sporting events, etc.)
- other potential scenarios
We would welcome input on potential operational and business impacts, as well as anticipated challenges that could arise once importer of record changes come into effect.
Responses provided will help inform policy development, as well as guidelines on how to implement importer of record changes that were made in the Customs Act. We may consider input received when developing proposals for future legislative or regulatory amendments.
Key questions for input
Your ideas and input are sought around the following questions and related themes:
- What benefits do you see for businesses and the public by allowing the use of the customs broker BN in these circumstances?
- Do you foresee any operational and business impacts by allowing the use of the customs broker BN in these circumstances?
- Are there specific situations or sectors that may face challenges with the use of the customs broker BN in these circumstances?
- Should any other scenario for use of the customs broker business number without the importer registering in CARM be considered, for example, for large sporting events?
- How can the CBSA better support infrequent importers (those importing less than 10 times per year)?
- How can a fully licensed customs broker better serve infrequent importers (those importing less than 10 times per year) and what can the CBSA do to support this?
- How can a fully licensed customs broker serve small businesses (defined as a companies with 1 to 99 paid employees) that import goods into Canada and what can the CBSA to do support this?
- Do you envision new business opportunities for companies or other entities to support small businesses that import goods into Canada under this framework?
Related information
- Customs Act
- Financial Security (Electronic Means) Regulations
- Persons Authorized to Account for Casual Goods Regulations
- Customs Brokers Licensing Regulations
- Accounting for Imported Goods and Payment of Duties Regulations
- Canada Gazette, Part 2, Volume 158, Number 22: Order Fixing as the Day on Which Section 307 of the Budget Implementation Act, 2022, No. 1 Comes into Force
- Customs Notice 24-27: CARM October Implementation – Transition Measures
- What we heard report: Importer of record implementation
- Memorandum D11-6-11: Post-Accounting Obligations of Authorized Agents as Importer of Record
- Memorandum D17-2-5: Duty Liability of Importer of Record
- Customs Notice 25-01: Non-Resident Importers: Determining if shipments are deemed Commercial or Casual
Contact us
Commercial and Trade Branch
Trade and Anti-dumping Programs Directorate
Email: cbsa.licensing_unit-unite_agrements.asfc@cbsa-asfc.gc.ca
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