Customs Notice 23-20: Introduction to the CBSA Assessment and Revenue Management System (CARM) for Customs Bonded Warehouse (CBW) Licensees and Importers
1. The purpose of this Customs Notice is to provide Trade Chain Partners (TCPs), specifically Customs Bonded Warehouse (CBW) licensees (including operators, importers and brokers),with an introduction to the CBSA Assessment and Revenue Management System (CARM) system. This notice will also outline the expectations for CBW TCPs, and further communicate new program enhancements and requirements.
2. The CARM platform will be used by CBW TCPs for enrolment and future accounting, as well as to submit a one-time baseline inventory count of goods in their respective warehouses prior to the implementation of the CARM Client Portal (CCP). Note all current programbased requirements and legislative obligations will remain in effect.
3. The CARM platform will provide improved mechanisms for CBW TCPs to better communicate and provide all necessary documentation to the CBSA in a secure electronic environment, which will facilitate compliance and traceability requirements of the various CBSA trade programs to which they have applied and/or are enrolled in.
4. Although CARM will allow for the electronic submission of applications and documents, the requirement remains for TCPs to keep a hard copy of all electronically submitted applications and associated supporting documentation, as per section 42(2) (a), subsections 43(1) and (2), section 40 of the Customs Act and section 2 of the Imported Goods Records Regulations. These records must be made available to the CBSA upon request.
5. Release 2 (R2) of CARM will expand the program based functionalities of the CCP to include electronic accounting and application submission for CBWs. Visit the CARM: CBSA Assessment and Revenue Management webpage for more information pertaining to the CARM system initiative and their phased deployment approach.
Expectations for CBW TCPs and a One-time inventory capture
6. In preparation for Release 2 (R2) of CARM when it becomes the official system of record for the collection of duties and taxes for commercial goods imported into Canada (), the CBSA will require all CBW TCPs to provide their up-to-date baseline inventory count of all unreleased goods remaining in inventory and pertinent financial security deposit information (e.g. bond) during the transition period, prior to or at R2, in order to remove goods from the CBW post R2. This one-time inventory capture will serve as a baseline for all subsequent accounting transactions associated to the removal of these unreleased goods from a CBW.
7. CBW TCPs have the option to submit baseline inventory transactions to CARM via file transfer process or by utilizing CARM Electronic Data Interchange (EDI) / Application Program Interface (API) solution components. CBSA requires all CBW TCPs to confirm to the CARM Stakeholder Engagement Team which approach will be used at least 60 days prior to the R2 go-live date.
8. CBW TCPs that elect to use the file transfer method will be required to provide conversion files to the CBSA 14 days prior to the R2 go-live date. Note the CCP will not be available for the inventory conversion process.
9. During the 14 day conversion period, CBW TCPs may continue to conduct operations and submit transactions for entrance into and exit from the CBW as normal in CCS. These will be migrated into CARM at R2.
10. CBW TCPs that elect to use EDI or API are required to submit conversion transactions and any required correction within 14 days of the R2 go-live date, noting that delays may occur with their warehouse movements, as data received will require validation.
11. Information regarding a submission via EDI can be found in Chapter 26: Commercial Accounting Declaration (CAD) of the Electronic Commerce Client Requirements Document ECCRD. Information regarding submissions via API can be found in the Declaration API section of the CARM API Inventory.
12. It is important to note that the inventory information provided is a considered to be a legal declaration and any inaccuracies, errors and/or omissions may result in Administrative Monetary Penalties. All inventory declarations are subject to post-compliance verification. Please note that all CBW TCPs will have the option to provide their inventory declaration directly to the CBSA, or have their representative (agent, customs broker, etc.) submit this information. Should a CBW TCP choose to use a broker to submit their information on their behalf, a copy of Power of Attorney is required before any information can be accepted and processed.
13. This onboarding activity is an essential component to fully enrol, participate and communicate within the CARM system.
14. Failure to enroll to the CARM system and failure to provide security deposit information and an inventory report prior to R2, may cause significant impediments in regards to the importing and exporting activities of the companies involved.
15. CARM will be holding stakeholder engagement sessions specific to CBW onboarding that will provide more context on the inventory and financial security (bond) capture.
16. For all CBW CARM related questions, the point of contact is the CARM Stakeholder Engagement Team: firstname.lastname@example.org.
17. For issues relating to the CARM system once an account is created, please complete the client support contact form.
18. The CBSA's computerized, 24-hour telephone service (Border Information Service) at 1-800-461-9999 is available free of charge throughout Canada; press "0" to speak directly with a live agent available from 6 am to 10 pm (eastern daylight time), 7 days a week. From outside Canada call 204-983-3500 or 506-636-5064, long distance charges will apply. TTY is also available within Canada: 1-866-335-3237. Contact us at the CBSA website may also be accessed for information.
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