CBSA Expands CARM RPP Contingency Plan to Cover All Goods in Sufferance Warehouses

Trade Update • July 14, 2025

Key Points:

• The CBSA has extended the CARM RPP Contingency Plan to cover all goods in sufferance warehouses for 30 days, from July 10 to August 9, 2025.

• This temporary measure supports importers and brokers who have not yet enrolled in the RPP program or posted financial security.
• Brokers must use a special contingency account (BN15) with a $4,999.99 cash deposit to release goods under this plan.
• Importers are responsible for paying duties and taxes and must submit final accounting declarations within 5 business days after release.
• After August 9, 2025, all importers must have proper RPP privileges to access electronic release options.

rom July 10 to August 9, 2025, the Canada Border Services Agency (CBSA) will allow all goods stored in sufferance warehouses (not just time-sensitive or perishable goods) to be released under a special contingency plan. This is to help clear backlogs and give brokers and importers more time to meet CARM requirements.

What’s New?

Previously, only time-sensitive and perishable goods, like medicines, live animals, fresh foods, and flowers, were eligible for this contingency release. Now, all goods in sufferance warehouses qualify for the temporary release process during this 30-day period.

Why Is This Important?

Since May 20, 2025, importers without RPP privileges cannot use interim electronic release methods such as:

• Integrated Import Declaration (IID)

• Pre-Arrival Review System (PARS)

• Release on Minimum Documentation (RMD)

Instead, they must submit a Customs Accounting Declaration (CAD) and pay all duties and taxes at the time of release, which can cause delays.

How Does the Contingency Plan Work?

For Brokers:

• Brokers must create a new importer RM extension account named “RPP Contingency – [Brokerage Name]” in the CBSA system.

• They must post a $4,999.99 cash deposit to secure temporary RPP privileges for this account.

• Brokers cannot use their regular BN15 account for this.

• Before using the contingency BN15, brokers must confirm the importer does not already have RPP privileges (e.g., system reject code I03).

Release Process:

• When submitting release requests, brokers must include the Canada Revenue Agency (CRA) registered importer’s name, BN15, and address in the IID fields to ensure proper CBSA follow-up.

• After release, the broker or importer must file the final CAD (Type AB) within 5 business days using the importer’s BN15 to avoid penalties.

• Duties and taxes will be charged to the importer, who is responsible for payment.

What Happens After August 9, 2025?

• The special contingency BN15 accounts will be closed.

• Cash deposits will be returned through the CBSA’s disbursement process.

• No entries under this contingency plan will be accepted after August 9, 2025.

• Importers must have proper RPP enrollment and financial security to continue using electronic release options.

Important Steps

Importers:

• Enroll in the RPP program and post the required financial security as soon as possible to avoid future delays.

Brokers:

• Follow the contingency plan’s rules and deadlines carefully to ensure smooth processing and avoid penalties.

Final Notes

This contingency plan is a temporary measure to help importers and brokers adjust to the new CARM system. It is not a substitute for proper RPP enrollment. For more information, please refer to the official CBSA Customs Notice 25-23 or contact your customs broker.

How GHY Can Help?

GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.

By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.

Contact Us Today! Booking a Meeting, email consult@ghy.com, or call +1 (800) 667-0771.