Critical CBSA Updates Ahead of CARM R3 and Recommended Next Steps

As the Canada Border Services Agency (CBSA) prepares for the upcoming CARM Release 3 (R3) on October 21, 2024, two important notices have been issued to guide businesses through this transition. These notices outline key measures and processes impacting trade operations and compliance.

Customs Notice 24-27- Transition Measures for CARM R3

Customs Notice 24-27 details the transition measures that will be implemented with CARM R3. These measures are designed to ensure continued border fluidity and the timely submission of accounting information and payment of duties and taxes.

Importers should take note of the Release to Prior Payment (RPP) financial security changes. They will no longer be able to use their customs broker’s financial security to obtain the release of their imported goods before paying duties. Instead, the importer must obtain its own bond. We recommend the importer continue to work with their customs broker to arrange for the financial security on their behalf.

Border Fluidity: CBSA is taking steps to maintain smooth border operations during the transition to CARM R3. As such, they will allow a 180-day transition period for the importer to obtain its own financial security. They are simplifying the process for trade chain partners (TCPs) to register for a new import-export program (RM) account. This enables all trade chain partners to register for the RM account from the CARM portal. Although CBSA is allowing for a 12-month transition period for importers to use their customs broker’s Business Number (BN) for importing commercial goods into Canada, it is recommended that all importers register for their own BN-15 in the CARM Client Portal (CCP) after October 21, 2024.

Timely Compliance: Importers, customs brokers, and other TCPs must adhere to new procedures for submitting accounting information and paying duties and taxes, aligned with CARM’s enhanced capabilities.

Customs Notice 24-28- Submission Processes for DRP and Temporary Importations

Customs Notice 24-28 outlines the procedures for submitting Duties Relief Program (DRP) applications, Drawback claims, and commercial temporary importations under Tariff Item No. 9993.00.00, ahead of CARM R3.

DRP Applications: Businesses must follow the updated process for DRP applications to ensure compliance as CARM R3 approaches.

Drawback and Temporary Importations: The notice provides specific instructions for recovering duties and handling temporary imports under the new system.

Recommended Next Steps

Customs brokers can continue to encourage their import clients to obtain a login to the CARM Client Portal and determine the necessary bond amount they will need. After October 21, Customs brokers can apply for their importer’s bonds with their surety providers. If they are not a client of Roanoke’s, they can contact us to learn more about our services for both U.S. and Canada customs bonds.

Roanoke is updating FastBond™ to allow for the electronic application and issuance of the RPP bond, endorsement and termination after October 21, 2024. Remember that all other CBSA bonds, along with the Goods & Service Tax (GST) bond, will remain the same process as it is today – a paper bond process. Our team is here to answer your questions and help secure your RPP Bond.

Importers should contact their customs brokers to learn more about the preparations needed. It is not recommended that importers directly apply for a customs bond in the CARM Client Portal; instead, they should work with a customs broker to arrange for the appropriate financial security.

With the CARM R3 implementation just around the corner, it is crucial for all TCPs to understand and prepare for these changes. Review the full notices to ensure your business is ready:

• Customs Notice 24-27
• Customs Notice 24-28

Prepare for CARM with Confidence

As the October 21 deadline approaches, ensure your clients are ready for the transition. Customs brokers can count on Roanoke’s expertise to secure the necessary RPP bonds. Not a Roanoke client? Contact us today to learn about our comprehensive services for U.S. and Canadian customs bonds.

 

Disclaimer: this information is provided as a public service and for discussion of the subject in general. It is not to be construed as legal advice. Readers are urged to seek professional guidance from appropriate parties on all matters mentioned herein.