What Is A FIRM Report And How Can It Help With Import Compliance
A FIRM report is one of the most underutilized tools every importer has access to, provided they use it against their import paperwork.
Even the most compliance-driven importer, who works with the most attentive customs broker, can find inconsistent data between entries if they look. That is why at PCB we recommend all importers review their import paperwork upon receipt. Importers can take this one step further by cross-referencing their import documentation against a FIRM report (or have us do it annually for you with our Pre-Verification Compliance Audit service).
What Is A Customs FIRM Report?
Canada Border Services Agency (CBSA) keeps track of each importer’s Customs Coding Report Form (B3) (aka your import declarations) by way of a Facility Information Retrieval Management System (FIRM, D-8). This report allows importers a complete view of all Canadian import activity under their business numbers.
The Canada Revenue Agency (CRA) states the purpose of a FIRM report as such:
“[...] the information is used for the purpose of assessing compliance with the provisions of the Income Tax Act, the Excise Tax Act, the Excise Act and the Excise Act, 2001. FIRM reports (D-8) may contain information such as ports of entry and exportation, importers, consignees, tariff classification, and destinations. The B3 information is used in CRA risk assessment systems to identify non-compliance issues and the associated revenue risks. The primary user of Appendix D-8 is CPB’s Compliance Research and Risk Assessment Division.“ Source
How Does A FIRM Report Help Me Stay Compliant?
Now that we know what a FIRM report is, now let’s review how you can use it as a compliance tool for various situations.
A FIRM report alone will unlikely to show you a problem with your declarations. That being said a FIRM report remains a powerful tool for all Canadian importers, as it provides a TOTAL view of all your activity, which can be cross-examined against the import documentation (the actual paper or data transmission used). You cannot do a proper audit with just a FIRM report other than seeing that a banana wasn't entered as an orange.
When conducting this review, the report can be used to answer these questions:
- Was the tariff shift that happened a few years back reflected accurately on all applicable imports moving forward?
- Is the H.S. tariff code used for our widgets the same on the declaration made by my multiple customs brokers?
- Did we apply applicable Free Trade Agreements to all qualifying transactions?
A FIRM report is especially helpful for those that use multiple brokers, as it will clearly show any discrepancies between service providers. It’s important to note that any discrepancies you clearly find will also be clear to Customs.
In the event that your team has discovered issues, a FIRM report allows you to make mass corrections with confidence; using it as a checklist for all past imports that need adjustment.
What A FIRM Report Will Not Tell You
Without the actual documents or data used to prepare the B3 in front of you, a FIRM report doesn't tell you if the values were declared correctly, if any deductions were missed or taken incorrectly and if the goods were declared improperly based on the invoice description. If there were questions during the release clearance process that went unasked, the FIRM report will not indicate so.
Instead, ensure that you have a close communication channel with your Customs Broker:
- They are available to you 24/7
- They clearly understand your business, import requirements, and commodities so much so that they are able to catch out of the ordinary activity
- They review your H.S. Tariff Code database against every tariff shift and Participating Government Agency change, and adjust accordingly (and inform you of all changes)
- They reach out to you when a trade regulation/announcement will impact your import activity
- They hold industry certifications with the Canadain Society of Customs Brokers (CSCB) such as a Certifed Customs Specialist (CCS) and/or Certified Trade Compliance Specialist (CTCS)
- They have experience with importing your commodities
How Do I Get A FIRM Report?
If you would like to obtain a FIRM report from CBSA, you may do so by providing written consent on the company letterhead and signed by a corporate officer of the company.
A FIRM report can be obtained by your services provider via the CRA Business Consent for Access by Telephone and Mail form.
Additionally, importers must also provide the following details:
- Your 9 digit business number(s)
- A date range on imports you would like the report to reflect
- Your address and contact details (where the report should be mailed)
Once you have completed the above, you can request your FIRM report via email to CBSA-ASFC_FIRM-SREG@cbsa-asfc.gc.ca.
You may also request this by fax 403-292-4200 or send a request by mail to:
Canada Border Services Agency
FIRM Report Request
#171- 220 4th Avenue S.E.
Please be aware there are costs associated with obtaining your FIRM report, including the postage, based on the parameters of your request.
And there you have it! A FIRM report cannot replace the need to review each and every import declaration you create or is created for you by your service provider. However, when used in conjunction with the import paperwork, it’s a very useful tool on your path to importing success.