Customs Notice 25-23: CARM Release Prior to Payment (RPP) contingency plan – Time sensitive/perishable goods and goods deemed necessary to support an individual’s continued health and well-being

Ottawa, May 30, 2025

Updated: July 9, 2025

Updated: August 9, 2025

1. The information contained in this notice is for the attention of customs brokers (hereafter referred to as “broker”), and importers involved in the release processing of goods.

2. Effective May 20, 2025, importers without Release Prior to Payment (RPP) privileges are not eligible for release using one of the interim accounting release service options, specifically the Single Window - Integrated Import Declaration (IID), Pre-Arrival Review System (PARS) or the paper Release on Minimum Documentation (RMD).

3. The CARM RPP transition period from October 21, 2024 to May 20, 2025, provided importers the benefit of RPP privileges while allowing additional time to enroll and obtain financial security. While RPP enrollment numbers continue to steadily increase, short-term contingency measures are needed to facilitate the release of certain time sensitive and perishable goods.

4. Unless otherwise specified in this notice, brokers are reminded they are not to use their broker/importer BN15 number to expedite the release of goods for importers who have not yet enrolled in RPP and posted financial security. The only release option available to importers who are not eligible for RPP is to submit a Customs Accounting Declaration (CAD) C-type and pay applicable duties and taxes at time of release.

5. Form A48 RMD Correction presented to a CBSA commercial office seeking to change the BN15 used at time of release to a BN15 that is not eligible for RPP, will be rejected. BN15 changes post release to a non-RPP BN15 are to be completed in accordance with Memorandum D17-2-3 Business Number Changes and Commercial Accounting Declaration Withdraw Request.

RPP Contingency Plan for the release of time sensitive/perishable goods overview

6. Effective immediately, the RPP Contingency Plan is available to brokers for an interim period of time in order to expedite the release of time sensitive/perishable goods on behalf of an importer who has not yet enrolled in RPP and posted financial security.

7. Time sensitive/perishable goods are defined as goods that lose their value or principal utility if not used within an imminent time frame and/or goods which are subject to rapid decay and spoilage. For example"

1. healthcare products such as blood and blood products
2. human organs
3. medical radioactive isotopes
4. other products needed for the preservation of human life or health
5. live animals
6. horse semen
7. fresh or frozen produce
8. meat, fish, seafood, fruits and vegetables; dairy products
9. plants; fresh cut flowers; etc.

8. Effective 11:59 pm August 9, 2025, the RPP contingency plan also includes goods deemed necessary to support an individual’s continued health and well-being, including but not limited to:

1. medical devices, equipment and supplies
2. dental and orthodontic devices, equipment and supplies
3. optical-related goods
4. natural health products
5. veterinary health products; and
6. other products related to supporting health and well-being

9. Brokers should only use their “RPP Contingency” BN15, after confirming an importer has not secured RPP privileges (e.g., receipt of system IID reject code I03 “invalid client privilege”) and after efforts have been made in encouraging the importer to enrol in RPP.

10. Final accounting (CAD Type AB) is to be submitted using the true importer’s BN15. Brokers should not be using their own BN for final accounting.

Process to follow

11. Initial set up:

1. Brokers will need to create a new importer RM extension to their existing BN9 importer account in the CCP. Creation of the new RM account must follow the below naming convention: “RPP Contingency – “Brokerage Name”.
2. Enroll in RPP and post a “cash security deposit” in the amount of $4,999.99 to secure RPP privileges for new RPP contingency importer RM account. A financial security agreement (“bond”) through a financial security provider is not permitted. Cash security deposits will be returned through the disbursement process (Commercial import accounting: Offsetting and disbursements) once the contingency period ends.
3. Upon termination of the RPP Contingency plan and disbursement of cash security deposits completed, the CBSA will expire the BN15 set up for this purpose.

Note: Use of a broker’s existing import BN15 that is used to obtain release for other scenarios such as: first time/one time importers; non-commercial (casual) goods; etc., is not permitted for purposes of this contingency plan.

12. Transmitting the IID and CAD

1. When transmitting the IID release, the name and BN15 of the true importer is to be included in the “Party name” place 6 field along with the related street address information in the “Street and number or post office box identifier” place 9 field. Providing this information will be important in case the CBSA needs to follow-up directly with the importer. Failure to include this information will result in the IID being rejected.

Please see extract from the SWI - IID ECCRD direction Chapter 23 (pages 43-45): Fields bolded below need to be populated with the true importer name, BN15, and street address.

Image description

Image Title - Information to Include When Transmitting the IID Release SWI – IID ECCRD Direction

Image Description – In this screen shot, fields bolded are to be populated with the true importer name, BN 15 and street address.

UN/EDIFACT Definitions EDIFACT GOVCBR Standard Syntax

Tag: 080

Name: Party Name

Pos Place: 040

St: C

Format: Blank

CBSA Implementation Business Application Attributes

St: C

Format:

Usage / Remark: Blank

UN/EDIFACT Definitions EDIFACT GOVCBR Standard Syntax

Tag: 3036

Name: Party Name

Pos Place: 4

St: M

Format: an…70

CBSA Implementation Business Application Attributes

St: M

Format: an..70

Usage / Remark: Provide the first 70 characters of the party name. This field is optional for Importers (IM), Customs brokers (CB) and Declarant’s agents (AE). This field is mandatory for Account owners (HQ).

UN/EDIFACT Definitions EDIFACT GOVCBR Standard Syntax

Tag: 3036

Name: Party Name

Pos Place: 5

St: C

Format: an…70

CBSA Implementation Business Application Attributes

St: C

Format: an..70

Usage / Remark: Use for another 70 characters of the party name if required.

UN/EDIFACT Definitions EDIFACT GOVCBR Standard Syntax

Tag: 3036

Name: Party Name

Pos Place: 6

St: C

Format: an…70

CBSA Implementation Business Application Attributes

St: C

Format: an..70

Usage / Remark: Use for another 70 characters of the party name if required.

UN/EDIFACT Definitions EDIFACT GOVCBR Standard Syntax

Tag: C059

Name: Street

Pos Place: 050

St: C

Format: blank

CBSA Implementation Business Application Attributes

St: C

Format : blank

Usage / Remark: Blank

UN/EDIFACT Definitions EDIFACT GOVCBR Standard Syntax

Tag: 3042

Name: Street and number or post office box identifier

Pos Place: 7

St: M

Format: an..35

CBSA Implementation Business Application Attributes

St: M

Format: an..35

Usage / Remark: Provide the first 35 characters of the street address. This field is optional for Importers (IM), Customs brokers (CB), Declarant's agents (AE) and Account owners (HQ).

UN/EDIFACT Definitions EDIFACT GOVCBR Standard Syntax

Tag: 3042

Name: Street and number or post office box identifier

Pos Place: 8

St: C

Format: an…35

CBSA Implementation Business Application Attributes

St: C

Format: an..35

Usage / Remark: Use for another 35 characters of the street address if required.

UN/EDIFACT Definitions EDIFACT GOVCBR Standard Syntax

Tag: 3042

Name: Street and number or post office box identifier

Pos Place: 9

St: C

Format: an…35

CBSA Implementation Business Application Attributes

St: C

Format: an..35

Usage / Remark: Use for another 35 characters of the street address if required.

Example:

NAD+IM+1234567890RM001++Party Name 1:X:X+Street:X:X+City+ON+X0X0X0+CA'

2. Once released, the confirming CAD (Type AB) must be submitted within 5 business days in order to avoid late accounting penalties being issued to the broker
3. The CAD is to be submitted using the importer’s BN15, not the broker’s RPP Contingency BN15
4. If the broker has not been given CCP delegation of authority and accounting is due, the broker may choose to submit the CAD using their RPP Contingency BN15 and then amend in accordance with the steps outlined in Memorandum D17-2-3 Business Number Changes and Commercial Accounting Declaration Withdraw Request
5. Once the CAD is submitted, duties and taxes will be posted to the importer’s account and the importer assumes all liability for payment of duties and taxes including any re-assessments or verification audits

Note: Submission of Form A48 RMD Correction to amend the BN15 prior to submitting the CAD Type AB is not required and will be rejected by the CBSA commercial office if presented.

13. Additional Considerations

1. Brokers should only use their “RPP Contingency” BN15 after confirming the importer has not secured RPP privileges (e.g., receipt of system IID reject code I03 “Invalid client privilege”).
2. Brokers should first confirm that the importer has delegated authority to them in the CCP prior to agreeing to using their RPP Contingency BN15 in order to avoid late accounting penalties being issued to the broker.
3. Warehouse entries submitted after 11:59 pm on August 9, 2025 under this contingency plan will not be accepted.

14. The RPP Contingency Plan does not change nor is applicable to existing CARM Transition Measures specified in Customs Notice 24-27

15. The RPP Contingency Plan will end upon notice by the CBSA. Upon termination, broker RPP Contingency BN15 will be expired by the CBSA and cash security deposit will be returned to broker through the disbursement process (Commercial import accounting: Offsetting and disbursements).

16. For information on how to post a cash security deposit, please refer to User guides - CARM ( Post Financial Security for Release Prior to Payment Purposes).

Contact information

Questions regarding the RPP Contingency Plan may be directed to the CARM Border Management Division: carm_or-epo_gcra@cbsa-asfc.gc.ca

Questions regarding RPP enrollment or posting cash security deposit, please contact the CARM Client Service Helpdesk.