CBSA’s CARM Launch Update: What You Need to Know

The Canada Border Services Agency (CBSA) announced on April 19, 2024, a crucial update regarding the launch of its groundbreaking CBSA Assessment and Revenue Management (CARM) system. Amidst shifting labor dynamics and a commitment to ensuring a seamless transition, the CBSA has rescheduled the external launch of CARM to Trade Chain Partners (TCPs) to October 21, 2024.

Although CARM implementation is delayed for TCPs, we strongly recommend that customs brokers continue discussions with importers about registering for CARM without delay. CBSA is back to accepting paper bonds as they were before the April 01st cutoff, so importers can still secure their RPP bonds. Be aware that CBSA is taking 10+ weeks to process paper bonds, and this processing delay will likely increase as the volume of RPP requests continues to grow over the coming months. Additionally, customs brokers should continue discussing CARM’s financial security requirements with importers to determine the best time to post the financial security.

Here’s a summary of the recent Customs Notice 24-17:

1. Internal Launch Proceeds as Planned: Despite the adjustment to the external launch timeline, the internal rollout of CARM Release 2 within the CBSA will proceed on schedule, commencing on May 13. This internal launch underscores the agency’s dedication to enhancing compliance and enforcement capabilities.

2. Cancelled Customs Notices: In light of the rescheduled launch, several recently published Customs Notices providing instructions and transition measures have been canceled. This includes guidance on submission and processing procedures and details on transition measures post-implementation.

3. Cutover Period: The previously scheduled cutover period from April 26 to May 13 will not occur as planned. Legacy processes will remain in effect without directly impacting external operations or TCPs.

4. Transition Measures: The CBSA has developed transition measures to ensure continued border fluidity and timely submission of accounting and payment of duties post-CARM implementation. Details of these measures will be communicated to TCPs closer to the October launch date.

5. Accounting and Payment Processes: Until CARM is implemented in October 2024, current systems such as CCS and CADEX will remain used for accounting and payment purposes. Importers can continue utilizing existing release processes before payment and financial security.

6. Communication and Support: The CBSA is committed to providing ongoing communication and support to TCPs throughout the transition period. Detailed information on activities leading up to the implementation of CARM will be disseminated in the coming months.

7. Continued Testing and Certification: The CARM testing environment will remain available to TCPs until May 31, 2024, allowing for ongoing testing and certification activities.

8. Compliance Verification Activities: Following the internal launch of CARM Release 2, the CBSA will continue its compliance verification activities, leveraging CARM alongside existing tools to ensure industry compliance.

9. Business Number (BN) Registration: The process for requesting Business Numbers from the Canada Revenue Agency will remain unchanged. Additionally, work is underway to develop a CBSA-administered process for registering and maintaining program accounts for importers and exporters.

For further inquiries or assistance regarding the rescheduled launch of CARM, TCPs are encouraged to contact the CBSA directly at Canada Border Services Agency (cbsa-asfc.gc.ca) Stay tuned for additional updates as the journey towards CARM implementation continues.
If you have questions about the RPP bond process, please contact Glenn Patton at glenn.patton@roanokegroup.com or Kaylin Panasdir at kailyn.panasdir@roanokegroup.com. You can also reach them at 800-ROANOKE (762-6653).

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.