Customs Notice 25-08: Overdue Releases/Missing Final Accounting

Ottawa, February 26, 2025

1. When the CBSA allows release based upon interim accounting under section 32(2)(a), trade chain partners (TCP) are obligated to finalize this process by submitting their final accounting in accordance with sections 32(3) and (4) of the Customs Act and also paragraphs 10 and 10.1 of the Accounting for Imported Goods and Payment of Duties Regulations.

2. The measures announced in Customs Notice 24-29: Preparing for the CARM October Implementation – Cutover Period and Customs Notice 25-02: CARM Transition Measure – Late Payment Penalties and Interest, related to interest and penalties to aid with the transition to the CARM system, and did not relieve Release Prior to Payment (RPP) participants of the requirement to account within the prescribed time frames.

3. TCPs need to ensure that they submit the final accounting for their releases to ensure that they maintain Release Prior to Payment benefits.

4. The end of the transition measure for late accounting penalties (LAPs) on January 19, 2025, means that the CBSA will resume daily monitoring of overdue releases/missing final accounting. The CBSA may issue late accounting penalties, assess duties and taxes based upon the release information provided, and post monies owing to the business number owner’s account.

Overdue Releases

5. Payment due date for a CAD is based upon the date of release.

6. A CAD presented after the prescribed period to account and the payment due date will show up as overdue on the Statement of Account (SOA). When all CARM transition measures expire, a TCP may find that their account is sent to Canada Revenue Agency (CRA) for collection when a CAD is accounted more than 31 days after the date of release.

7. When a Statement of Account has not been paid by the specified due date, paragraph 34 of CN24-29 and paragraph 4 of CN25-02 state it will be subject to collection measures by the CRA during that period.

8. TCPs can mitigate the risk of collection activities for any CADs submitted late by making payments of duties and taxes owing for overdue releases. CADs accounted late will then be cleared with the estimated payment/credit, thereby reducing or removing the outstanding balance with CRA, assuming no older transactions are still overdue.

9. Should you have any questions relating to your account, you should fill out the CBSA Client support contact form indicating your BN15 as well as the CAD number.