Customs Notice 24-27: CARM October Implementation – Transition Measures
Ottawa,
Updated:
1. This notice is to provide an update to the transition measures originally outlined in Customs Notice 24-27. The information contained in this Customs Notice is applicable to importers and customs brokers (hereafter referred to as “broker”) involved in the importation of goods into Canada
2. Effective the CBSA Assessment and Revenue Management (CARM) system will become the official system that importers and other trade chain partners will use to account for imported goods and pay for duties, including taxes, (hereafter referred to as “duties”) owing on the goods. Additionally, the CARM Client Portal (CCP) also becomes the Agency’s centralized system for trade chain partners to register their CBSA account and enroll in the various CBSA programs (e.g., Importer; Release Prior to Payment; etc.)
3. The CBSA has developed transition measures to ensure continued border fluidity and timely submission of accounting and payment of duties after CARM implementation on .
Release Prior to Payment (RPP)
4. Since CARM became the official system of record on , importers have not been able to use a broker's RPP security to obtain the release of imported goods before paying duties. Importers who want to obtain the release of imported goods prior to the payment of duties are required to post their own financial security through the CCP.
5. A 180-day transition period was provided following CARM implementation and extended to to allow time for importers to obtain financial security. That transition period is period is now concluded.
6. As of , all importers who require release prior to payment of duties must have posted their own financial security in the CCP. Importers that have not done so are not eligible for release prior to payment.
Use of Broker Business Number (BN15) – Commercial Goods
7. The use of broker BN15 was allowed for a 12-month transition period, under specific scenarios as set out below. These transitional measures are being extended and will remain in effect until , to align with the coming into force of the Importer of Record regulatory legislative amendments.
8. Until , a broker can use their BN15 at time of release and accounting for commercial goods (including Commercial temporary importations under Tariff Item No. 9993.00.00 documented on a BSF865/Temporary Admission Permit) for a new NRI who has not registered or is in the process of registering in the CCP to obtain a BN15.
9. For first-time commercial importers (including NRIs), brokers should direct the importer to register to the CCP, obtain a BN15, and enrol in the RPP sub-program immediately and prior to submitting release. If this is not feasible or would result in the release of goods upon arrival being delayed, the CBSA will allow, up until , the use of a broker BN15 for the purpose of obtaining release and to account for commercial goods. The CBSA will also facilitate the use of a CBSA administrative BN15 on paper C-Type CAD for importers that are not using a broker.
10. For one-time commercial importers, the CBSA will allow, until , the use of a broker BN15 for the purpose of obtaining the release and to account for commercial goods. The CBSA will also facilitate the use of a CBSA administrative BN15 on paper C-Type CAD for importers that are not using a broker.
11. Until , the CBSA will allow for the continued use of a broker BN15 to account for commercial goods on the F-type CAD in the CLVS stream when the importer, including NRIs have not registered to the CCP. The release of CLVS shipments will not be delayed due to the commercial importer not having a BN15, not being registered to the CCP, not having delegated authority to a broker or not having enrolled in RPP.
12. Until , if it is determined post release and delivery, that goods did not qualify for CLVS clearance (e.g., HVS, OGD regulated, etc.), broker BN15 may be used on the V-type CAD.
Use of Broker BN15 – Non Commercial (Casual) Goods
13. Current policy permitting the use of broker BN15 and RPP to obtain release and to account for non-commercial goods cleared through the commercial stream will be maintained. This policy will be maintained beyond the transition period after .
14. As a general rule, the BN15 belonging to an approved CLVS participant should be used for accounting when submitting the F-type CAD for non-commercial CLVS goods.
15. When a General Agency Agreement is in place with a non-commercial CLVS importer, a broker will be permitted to submit the non-commercial F-type CAD using the broker BN15.
Use of Broker BN15 – Other Business and Operational Processes
16. The CBSA will continue to allow use of broker BN15 for the temporary importation of trade show, conventions goods for both release and accounting on behalf of Importers. This policy will be maintained beyond the transition period after .
17. CBSA will allow for the continued use of broker BN15 to represent Auction Houses for both the release and accounting of importations on behalf of Importers who are not registered in the CCP or obtained a BN. This policy will be maintained beyond the transition period after .
Coming into Force of the Importer of Record Amendments
18. The legislative amendments to Section 17 of the Customs Act are not yet in force, but will come into effect on by order of the Governor in Council (GIC).
19. The amendments under Section 17 of the Customs Act are worded in such a way that that they will come into force, and subsequently enforced, on by order of the Governor in Council. If you are an entity that becomes subject to Section 17, solely due to these amendments, your liability will begin on the date the Section 17 amendments come into force.
Additional Information
20. If you have any questions about the transition measures, please contact us at cbsa.carm_engagement-engagement_de_la_gcra.asfc@cbsa-asfc.gc.ca
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