Canada CARM

The Canada Border Services Agency (CBSA) has modernized its processes for managing the import of commercial goods shipped to businesses in Canada through the CBSA Assessment and Revenue Management (CARM) project. As of October 21, 2024, CARM has overhauled how duties and taxes are collected on these shipments, making the system more efficient. The project also introduced the CARM Client Portal (CCP), an online platform that provides businesses with 24/7 access to import-related information and services.

How does CARM affect businesses? 

CARM affects certain businesses by requiring them to register on the CARM Client Portal (CCP) and adhere to new processes for managing commercial imports. Businesses conducting certain types of trade with Canada must register on the CCP, delegate authority to their employees for access to the portal and to their carrier/broker to clear shipments, and may require a bond (financial security) to be posted. CARM aims to streamline import operations and provide better transparency and efficiency in handling duties and taxes.

Which businesses are affected by CARM? 

Not affected by CARM

The following businesses are not affected by CARM:

• Ecommerce businesses with non-commercial, business-to-consumer (B2C) shipments

  • These businesses can continue shipping to Canada as usual. A broker or carrier will handle clearing shipments at the border, so no registration with CARM is required.

• Zonos merchants shipping B2C

  • If your business falls into this category, you do not need to register with CARM and can continue operating as usual. Your broker or carrier will manage the customs clearance process.

Affected by CARM

The following businesses are required to comply with CARM regulations:

• Businesses shipping commercial, business-to-business (B2B) goods

  • If you’re a Canadian company and import or buy goods for your business from outside of Canada (B2B), you are now required to register and use the CARM Client Portal to comply with updated import regulations.

• Non-Resident Importers (NRIs)

  • NRIs, or businesses based outside Canada that import goods for sale or distribution within the country, must also comply with CARM and register through the CARM Client Portal.

Steps to comply with CARM 

If you are affected by CARM, here's what you need to do:

Step one - Register for the CARM Client Portal

1. Obtain a Canadian business number.

   1. Register for one here.
   2. If you already have one, you will need it for the next step.

2. Visit the CBSA's CARM Client Portal website.

3. Follow the registration process, which takes about 10-15 minutes. Ensure that the address and other details match what the Canada Revenue Agency (CRA) has on file, as discrepancies can cause delays.

4. Once registered, you can access your account information, including duties, taxes, and other financial transactions.

Step two - Delegate authority

Within the CCP, delegate authority to your employees and a customs broker or other representative to act on your behalf, similar to granting a power of attorney. Ensure the delegated party has the expertise to manage customs clearance and other import-related processes.

The user roles you can assign are as follows:

• Business Account Manager (BAM): This role provides full access to all of the portal’s functionality for your business account and associated program accounts. It is typically reserved for someone actively involved in managing your business account.

• Program Account Manager (PAM): Full access to CCP functionality for a specific program account only. Useful for giving access to certain program accounts.

• Editor: Can perform operational activities in the CCP, such as requesting rulings and making payments.

• Reader: Can view operational activities in the CCP, such as rulings, payments, and financial information.

For your customs broker or trade consultant, you should typically establish a business relationship and delegate the role of Program Account Manager (PAM) or Editor, depending on the level of access and responsibility you want them to have, which will allow them to transact business with the CBSA on your behalf.

Step three - Post financial security

To cover potential losses, you must post financial security, which is money posted or added to your account as a bond or a cash deposit. This security allows your goods to flow across the border and lets you account for duties and taxes later.

To get financial security approved and a finalized amount for CARM, importers should follow these steps:

1. Determine security type: Decide whether you will use a surety bond or a cash deposit as your financial security. A surety bond is typically obtained through an insurance or bonding company, while a cash deposit involves depositing the required amount directly with the CBSA.

2. Calculate the required amount: The amount of financial security needed is based on your import activity. A surety bond is generally 50% of the highest monthly duties and taxes paid in the previous 12-month period, subject to a minimum of $5,000 CAD. A cash deposit is 100% of the highest monthly duties and taxes paid during the last 12-month period.

   1. Obtain a surety bond (if applicable):

      1. Contact an insurance or bonding company that provides customs bonds.
      2. Provide them with your import history and financial information as required.
      3. The bonding company will assess your risk and determine the bond premium.
      4. Once approved, the bonding company will issue a bond certificate that you must submit to the CBSA.

   2. Make a cash deposit (if applicable):

      1. If you opt for a cash deposit, you must deposit the calculated amount with the CBSA.
      2. Contact the CBSA for instructions on how to make the deposit and the specific account details.

3. Submit your security to the CBSA: Provide the CBSA with the necessary documentation for your chosen type of financial security, which may include the bond certificate for a surety bond or proof of the cash deposit.

4. Wait for approval: The CBSA will review your financial security submission and link your financial security to your importer account in the CARM Client Portal (CCP) once it’s approved.

5. Monitor and adjust as needed: Keep an eye on your import activity and financial security requirements. If your import volumes or duty and tax amounts change significantly, you may need to adjust your financial security accordingly.

It's advisable to work closely with your customs broker or a financial advisor to ensure you meet CARM's financial security requirements. They can help you navigate the process and ensure that your security is approved and finalized in a timely manner.

Why CARM? 

CARM's purpose is to:

• Balance the CBSA's books and provide a clear record of who owes what.

• Centralize the import process into a single portal, where importers can view responsibilities, financial transactions, and other relevant information, similar to how one might view credit card debts or mortgages online.

• Improve efficiency, compliance, and transparency in the import process.

CARM represents a significant shift in how importers interact with the CBSA. By staying informed and preparing for the upcoming changes, you can ensure a smooth transition and continue to thrive in the evolving landscape of international trade.

Stay informed and compliant 

For businesses that do not comply with CARM regulations, you can expect that your packages will not move. CBSA will hold packages and carriers will require you to get a business number and register with the CARM portal. Stay current with any changes or updates to CARM regulations by working closely with your customs broker or representative to ensure ongoing compliance with CARM requirements.