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Customs Notice 25-32: End of CARM Transition Measures and Coming Into Force of Importer of Record Changes to the Customs Act

Ottawa,

1. This notice is to confirm that all transition measures outlined in Customs Notice 24-27 will end as planned on .

2. The information contained in this Customs Notice is applicable to importers, customs brokers (hereafter referred to as “broker”) and authorized couriers (i.e., Courier Low Value Shipment (CLVS) Program participants), involved in the importation of goods into Canada.

3. The legislative amendments to Section 17 of the Customs Act will come into force on a date fixed by order of the Governor in Council.

4. If you are an entity that becomes subject to section 17, solely due to these amendments, importer of record liability will begin on this date.

5. The entity identified as the importer at the time of accounting (that is, the importer of record) will be liable along with the importer and owner of the goods, for any amounts owing in duties and taxes and  any post-accounting duties determined due to verifications, or the importer having a reason to believe they made an error at the time of accounting.

6. On , the CBSA Assessment and Revenue Management (CARM) system became the official system of record that importers and other trade chain partners must 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) is the Agency’s centralized system for trade chain partners to register their CBSA account and enroll in various CBSA programs (e.g., Importer; Release Prior to Payment (RPP); etc.)

7. Businesses who import commercial goods into Canada must first register in the CCP and obtain a business number (BN).  Importers who want to benefit from electronic release prior to the payment of duties and taxes must also enroll in RPP and obtain financial security.

8. Beyond , the CBSA will maintain the following operational processes to ensure continued border fluidity,  timely submission of the Commercial Accounting Declaration (CAD) and payment of duties.

Use of Broker BN15 – Non Commercial (Casual) Goods

9. Current policy permitting the use of a customs broker’s BN15 and RPP to obtain release and to account for non-commercial goods cleared through the commercial stream will continue.

10. The BN15 belonging to an approved CLVS participant should be used for accounting when submitting the F-type CAD for non-commercial goods imported under the CLVS Program.

Ensuring the Free Flow of Commercial Goods in Select Scenarios

11. All commercial importers (including Non-Resident Importers), should be directed by their customs broker or the authorized CLVS participant to register in the CCP, obtain a BN15, and enrol in the RPP sub-program, which includes posting financial security, immediately and prior to seeking release of  goods.

12. There may be scenarios where this does not occur in a timely manner and may result in the release of goods upon arrival being delayed. The CBSA may facilitate the use of a CBSA administrative BN15 on a paper C-Type CAD in order to ensure the timely release of the goods.

13. For commercial goods imported under the CLVS program, importers are required to obtain a BN15, register in the CCP, enrol in RPP and post financial security, and delegate authority to a customs broker to transact business with the CBSA. To support immediate release procedures, in situations where release of goods was obtained and an importer has not fully registered with CBSA, a customs broker’s BN15 may be used to account for the commercial goods on the F-type CAD, while the broker works with the importer on securing CARM and RPP enrollment in a timely manner.

14. CLVS participants are expected to take all necessary action to ensure importers enrol in CARM and meet the requirements outlined above.  The CBSA will conduct post-release compliance monitoring and verification of goods imported through the CLVS program to validate that importers are registered in CARM and have enrolled in the RPP Program.  Repeated instances of non-compliance may result in commercial importers being ineligible to import goods through the CLVS Program.

15. If it is determined post release and delivery that goods did not qualify for release under the CLVS Program (e.g., regulated, value for duty exceeding CAD $3,300 etc.), the broker’s BN15 may be used on the V-type CAD.

16. The entity who causes goods to be imported for a trade show or convention may be considered the person who caused the goods to be imported and can register in CARM in order to obtain electronic release of their goods and to submit accounting declarations to the CBSA in CARM.

17. 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.

18. 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.

19. This Customs notice does not change or cancel the RPP Contingency Plan- for Time sensitive/perishable goods and goods deemed necessary to support an individual’s continued health and well-being outlined in Customs Notice 25-23.

Additional Information

20. If you have any questions about the transition measures, please contact us at the Border Information Services line (1-800-461-9999, option 2 - General Commercial Questions) or alternatively, via the webform.

21. For additional information on the implementation of the importer of record changes to the Customs Act, please refer to:

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