The Canada Border Services Agency has issued a Customs Notice that provides an update on the CBSA Assessment and Revenue Management (CARM) system for Customs Bonded Warehouse (CBW) licensees, including operators, importers, and brokers.

The Notice talks about CARM program enhancements and requirements, along with expectations for CBWs.

Highlights include:

  • CBWs will use the CARM platform for enrolment and future accounting, as well as to submit a one-time baseline inventory count of goods in their respective warehouses prior to the implementation of the CARM Client Portal (CCP). In addition, all current program-based requirements and legislative obligations will remain in effect.
  • Through the CARM platform, CBWs will be able provide all necessary documentation to the CBSA in a secure electronic environment, which will facilitate compliance and traceability requirements of the various CBSA trade programs to which they have applied and/or are enrolled in.
  • Although CARM will allow for the electronic submission of applications and documents, the requirement remains for CWSs to keep a hard copy of all electronically submitted applications and associated supporting documentation, as per section 42(2) (a), subsections 43(1) and (2), section 40 of the Customs Act and section 2 of the Imported Goods Records Regulations. These records must be made available to the CBSA upon request.
  • Release 2 of CARM will expand the program based functionalities of the CARM Client Portal to include electronic accounting and application submission for CBWs.

Expectations for CBW TCPs and a One-time inventory capture

In preparation for Release 2 of CARM when it becomes the official system of record for the collection of duties and taxes for commercial goods imported into Canada (May 2024), the CBSA will require all CBWs to provide their up-to-date baseline inventory count of all unreleased goods remaining in inventory and pertinent financial security deposit information (e.g. bond) during the transition period, prior to or at R2, in order to remove goods from the CBW post R2. This one-time inventory capture will serve as a baseline for all subsequent accounting transactions associated to the removal of these unreleased goods from a CBW.

CBWs will be able to submit baseline inventory transactions to CARM either via a file transfer process or by utilizing CARM Electronic Data Interchange (EDI) / Application Program Interface (API) solution components.

CBSA requires all CBWs to confirm to the CARM Stakeholder Engagement Team approach, which will be used at least 60 days prior to the R2 go-live date.

CBWs that choose to use the file transfer method will be required to provide conversion files to the CBSA 14 days prior to the R2 go-live date. The CCP will not be available for the inventory conversion process.

During the 14-day conversion period, CBWs may continue to conduct operations and submit transactions for entrance into and exit from the CBW as normal in CCS. These will be migrated into CARM at R2.

CBWs that choose to use EDI or API are required to submit conversion transactions and any required correction within 14 days of the R2 go-live date, noting that delays may occur with their warehouse movements, as data received will require validation.

Information regarding a submission via EDI can be found in Chapter 26: Commercial Accounting Declaration (CAD) of the Electronic Commerce Client Requirements Document ECCRD. Information regarding submissions via API can be found in the Declaration API section of the CARM API Inventory.

Read Chapter 26: Commercial Accounting Declaration (CAD) of the Electronic Commerce Client Requirements Document ECCRD here.

Read the Declaration API section of the CARM API Inventory here.

The inventory information provided is a considered to be a legal declaration and any inaccuracies, errors and/or omissions may result in Administrative Monetary Penalties. All inventory declarations are subject to post-compliance verification.

Note: CBWs will have the option to provide their inventory declaration directly to the CBSA, or have their representative (agent, customs broker, etc.) submit this information. Should a CBW TCP choose to use a broker to submit their information on their behalf, a copy of Power of Attorney is required before any information can be accepted and processed.

This onboarding activity is an essential component to fully enrol, participate and communicate within the CARM system, and failure to enroll to the CARM system and failure to provide security deposit information and an inventory report prior to R2 may cause significant impediments in regards to the importing and exporting activities of the companies involved.

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