CARM will provide a more open concept of reporting to the importer but will restrict the accessibility of the customs broker. For an importer to use a customs broker for a transaction, the importer, as the Importer of Record (IOR) will need to grant the customs broker access to their account through the online CARM portal.
Under CARM, importers will have their own account on the online CARM portal. As stated above, in order to submit a transaction using a customs broker, importers will have to grant customs brokers access to their account. However, multiple different types of entries can be done; CARM will also allow electronic refunds and electronic temporary entries in addition to the basic release of the B3-3. While the 5-day limit remains, there will be flexibility to make corrections to the B3-3 without having to go through the formal process of applying for a B2. CARM is expected to use a different format for transaction numbers.
Currently under the CADEX program, importers are given three types of payment structures: a) Importer Direct Security Option; b) GST Direct Payment Option; and c) Interim Payment Option. These options will no longer be available with CARM. It is expected that most importers will have to change from a GST direct client to an Importer direct client. This means that importers will have to pay both duties and taxes to CBSA, instead of just GST; because of this, Importers will need to post a surety bond based on the value of tax paid.
“All importers will be required to post their own security to participate in the Release prior to payment (RPP) program. A commercial shipment will not be released prior to payment (of duties & taxes) unless the importer has posted a surety or cash bond. The CBSA is working on the conditions upon which releases will be impacted due to inadequate security. CBSA recommends that the amount of RPP security an importer (resident or non-resident) posts should be based on their highest historic monthly accounts receivable over a 12- month period, inclusive of duties, taxes (GST), fees, and penalties. It is the importer’s responsibility to manage and maintain the appropriate amount of RPP security relative to their accounts receivable, inclusive of duties, taxes (GST), fees, and penalties. The $10 million cap in place today will remain. An importer will have the flexibility to make interim payment to reduce their RPP security utilization and raise or lower their RPP security to account for seasonality or other fluctuations in their business.” – CSCB
CARM will be fully in effect as of May 2024.
CBSA has advised that if you have activated your CARM portal by May 2024, you will be granted 180 days to obtain a Surety Bond once CARM goes live, avoiding any unnecessary delays in importing.