What is the CARM Client Portal and What Importers Need to Do Next?

The CBSA Assessment and Revenue Management project is a multi-year trade initiative. Once implemented, it will facilitate compliance and enhance the use of data analytics to streamline business processes between CBSA and its clients - the importers!

The multi-year project will transform how the Canada Border Services Agency assesses, collects, manages and reports on import revenue and trade information.

The CARM Client Portal is a central location where importers, or their designated agents, can submit Declarations for Commercial Goods imported into Canada directly to the Canada Border Services Agency (CBSA), request rulings, and obtain Statements of Accounts (SOAs).

The portal is designed to streamline trade processes and enable CBSA to better engage importers while also allowing CBSA to gather and analyze trade-related data.

In January 2021, CBSA finalized migration of the ARL system from its existing data center configuration to the cloud. This process was completed with no changes in functionality for external users and was done to allow the underlying data architecture for the portal to be created.

During the initial release (Phase 1 - June 2021), the CARM Project Portal will give traders uninterrupted access to border services and allow these importers and customs brokers to:

• Use online tools to classify goods and evaluate duties and taxes
• Submit declarations and make payments through a Commercial Accounting Declarations (CAD) which are replacing the current customs coding form (B3) and the request for adjustment form (B2)
• Shift to an Electronic Data Interchange and become paperless by default.

Phase 2, set to be released in June 2022, expands the CARM Portal will be expanded and become available for all trade chain partners. Users will be able to:

• Acquire a Business Number (BN9) and program account (RM account and/or Program ID)
• Submit, correct and adjust a Commercial and Accounting Declaration (CAD), which will replace the current customs coding form (B3) and request for adjustment form (B2), also available via Electronic Data Interchange
• Post and monitor security to participate in the Release Prior to Payment (RPP) program as an importer

Importers will need to register on the CARM Client Portal and properly delegate access to employees and third parties (customs brokers and trade consultants).

Once registered, importers will have the ability to provide access to their customs broker to manage both imports and CARM procedures.

Additionally, importers may look to obtain a customs bond. One of the focuses of the CARM initiative is to shift duty and tax liability to the importers through Release Prior to Payment (RPP) privileges. If importers do not obtain their own RPP security (through a customs bond), they will not be eligible for RPP benefits and will have to establish ways to pay duties and taxes at time of entry – hindering the flow of goods.

It is highly recommended that importers register for the CARM Client Portal as soon as it becomes available.

Because of the phased rollout, the CARM Project is not dramatically altering the customs release process. This will change and Canadian importers need to get ahead of the rollout and be prepared for these changes.

Businesses need to designate a “CARM Champion” who can supervise the changes in internal processes and, ultimately, oversee the CARM Portal. Importers can no longer wholly rely upon a customs broker to manage their compliance.

Beyond conducting customs business through the CARM Portal, the major disruption for importers will be the shifting financial liability and the changes to importer’s accounting processes.

Under CARM, the Importer of Record (IoR) will be required to have their own portal account as well as a security bond in place. Payments to CBSA for duties and taxes will be required to come directly from the importer rather than from a delegated agent such as a customs broker and this process will call for greater connectivity to banks to facilitate these payments.

For these reasons, after registering and obtaining a bond, many importers are tapping the expertise of their customs broker to enable compliance or are looking to technology providers to manage CARM processes.