BDO Indirect Tax News

Canada - Changes to customs regime requires importers to register in the Assessment and Revenue Management portal

In May 2021, the Canada Border Services Agency (CBSA) introduced the first of two phases of a digital initiative that transforms the collection of duties and taxes for goods imported into Canada. This initiative, called CBSA Assessment and Revenue Management (CARM), provides a much-needed modernisation to the reporting of customs information by importers, the payment of duties and taxes, and the availability of import information online via a self-service online portal called the CARM Client Portal (CCP).
Phase 1 of CARM launched on 25 May 2021 and Phase 2 of CARM is delayed until at least May 2024. However, Canadian importers should not wait until the last minute to register on the CCP.
As part of Phase 1, Canadian importers can now:
  • Create a profile on the CCP in preparation for Phase 2;
  • Assign external designates, such as customs brokers and trade consultants, to assist with importing activities;
  • Request customs rulings for tariff classification, origin and valuation;
  • Submit electronic payments; and
  • View statements of account.
Phase 2 of CARM includes a significant change that requires importers to post a security bond. It also enables importers and external designates to conduct the following activities on the CCP in addition to the functions made available in Phase 1:
  • Submit commercial account declarations, which will replace the current B3 (the customs coding form);
  • Receive daily payment notifications;
  • Submit corrections and amendments online;
  • Obtain a business number and import program account extension; and
  • Post and monitor a security bond.
Participation in CARM is mandatory for Canadian importers
Participation in CARM and registration on the CCP is compulsory for any importer of goods into Canada after the implementation of Phase 2. Failure to comply will result in the importer being prohibited from bringing goods into Canada until the CCP registration process has been completed and all requirements have been met, including posting an importer bond.

For companies that rely heavily on imported goods in their manufacturing processes or retail sales activities, this delay could negatively impact their bottom line if they cannot fill customer purchase orders on time. Such companies may also accrue additional freight and storage costs.
How to prepare for Phase 2 of CARM
Importers of goods into Canada must comply with the new requirements to avoid negative consequences that can cost time and money. Importers must take the following actions before the implementation of Phase 2:
  • Obtain an importer/exporter business number from the Canada Revenue Agency (CRA) if the importer does not already have one. Obtaining CRA a business number can be challenging, especially for nonresidents, who often are subject to a rigorous review by the CRA for security purposes;
  • Register on the CCP using a Government of Canada Key (GCKey) or Sign-In Partner information;
  • Designate individuals in the company, customs brokers or trade consultants to conduct customs business on behalf of the company via the CCP; and
  • Obtain an importer security bond (this is separate and distinct from the bond nonresidents must obtain for Canadian Goods & Services Tax/Harmonised Sales Tax (GST/HST) purposes if registered for GST/HST).


Charmaine Goddeeris
BDO in Canada