An Editor's Note: with Release 2 now having no set date, as of Feb 2022, kindly bare this in mind while reading.
What The CARM Is Going On?
The implementation of CBSA Assessment and Revenue Management (CARM) is structured in a series of releases, the first phase was The Accounts Receivable Ledger (ARL) which was introduced and implemented in 2016. In the Fall of 2020 new functionally will be released which will introduce the CARM client portal. This self-service portal is intended to be importer-centric and is designed specifically for importers to self-manage the accounting activity of their import business. This will eventually include making payments on all amounts owed to CBSA, as well as making corrections, and adjustments to release declarations.
CBSA has a challenging and ambitious timeline for implementation. Importers will be required to set up an account in the client portal that is anticipated to go “live” in the fall of 2020.
What Does CARM Mean To Me?
The portal is a self-service driven access point that provides importers with increased visibility, efficiency and consistency with direct accounting capabilities for their customs accounting activity. Duties and tax liability and payment management is transferring to you, the importer.
Currently, it is likely that your customs broker transmits your B3 final accounting information to CBSA using their liability bond. Your customs broker may also provide you with and manage the payment of your monthly statement of account with CBSA on your behalf. A relationship where the importer returns funds back to their customs broker, based on certain terms and conditions.
A key point of CARM is that all financial risk will now be borne by the importer. The Importer of Record (IOR) will be required to have a client self-service portal account, and their own security bond in place in order to enjoy Release Prior to Payment (RPP) privileges, and manage their payments to CBSA directly. The customs broker will transmit the amounts owing into your online account, for your own action. This is a large change for importers who are not used to managing payments with CBSA separately from their customs brokerage service charges.
Can I Delegate Access To My Customs Broker?
Yes, the portal does allow for third party delegation of account, where importers can choose to provide access to their customs broker(s) at agreed-upon levels of importer information exposure. This is where a customs broker could potentially continue to manage payments on your behalf. However, this may require a discussion between importers and their customs brokers regarding the scope of service and potential service fees. The CARM client self-service portal will revolutionize the customs broker/importer relationship, and change the way we do business together.
What Are RPP Privileges?
CARM will focus on moving to importer liability for the Release Prior to Payment (RPP) privileges, meaning:
- Liability will be established at the importer level.
- All importers will be required to purchase and post their own security to participate in the RPP program.
- Importers will no longer be able to use their customs broker’s RPP broker bond to clear shipments and receive release prior to payment privileges.
- It will be the importer’s responsibility to manage and maintain the appropriate amount of RPP security relative to their accounts receivable.
- Should the importer choose not to obtain security, they will not be able to obtain RPP as of the go-live date and may need to establish ways to pay duties and taxes at the time of entry.
The Portal Is Being Deployed In Stages:
Fall 2020 - Release 1 - Basic functionality will be introduced:
- CARM Client Portal is accessible only to clients with an RM account
- Manage payment processing (online payments, pre-authorized debit, etc.)
- HS classification tool, tariff data management
- Case management functionality for rulings
- Revenue reporting
Spring 2021 - Release 2 - Registration and enrollment will be available to all clients, as well as electronic declarations with versioning.
- New portal functionality and notifications
- Electronic declarations
- Digital versioning and mass editing capabilities
- Basic re-assessment risking
- Case management functionality for appeals, compliance and risks
- New offsetting options
- CBSA pre-collections options
- Central trade data reporting
When Release 2 is completed CBSA intends to decommission the Customs Automated Data Exchange (CADEX) - the current program being used to transmit accounting information to CBSA - and all accounting for releases must be done in the CARM customs portal.
Wait...So, The CARM Portal Isn’t Changing The Customs Release Process?
Not yet, the reporting of B3 customs declaration and PGA data which triggers the release/clearance of the shipment using Integrated Import Declaration (IID), transmitted through the Single Window, will remain the same.
For further information on CARM please visit the CBSA website.