CARM Requirements for Customs Bonded Warehouses
Trade Update • July 16, 2024
he Canada Border Services Agency (CBSA) has issued notice to inform Trade Chain Partners (TCPs) involved in Customs Bonded Warehouses (CBWs) about the new CBSA Assessment and Revenue Management (CARM) system. This following provides an overview of the CARM system, its implementation for CBW licensees, and the new program enhancements and requirements.
Purpose of CARM
The CARM platform is designed to streamline enrolment and accounting processes for CBW TCPs. It also requires these partners to submit a one-time baseline inventory count of goods in their warehouses before the CARM Client Portal (CCP) goes live. All existing program requirements and legislative obligations remain unchanged.
Enhancements with CARM
CARM introduces improved mechanisms for CBW TCPs to communicate with the CBSA and submit necessary documentation securely. This enhancement aims to facilitate compliance and traceability for various CBSA trade programs.
Record-Keeping Requirements
Despite the shift to electronic submissions, CBW TCPs must still maintain hard copies of all submitted applications and supporting documents, as mandated by the Customs Act and the Imported Goods Records Regulations. These records must be available for CBSA review upon request.
Key Dates and Transition
CARM will officially become the system for collecting duties and taxes on imported goods starting October 21, 2024. At this point, CARM will expand to include electronic accounting and application submissions for CBWs.
Preparation Steps for CBW TCPs
CBW TCPs must take the following actions in preparation for the CARM implementation:
- Provide an up-to-date baseline inventory count of all unreleased goods.
- Register in the CARM Client Portal (CCP).
- Maintain accurate records of all CBW movements during and after the transition period.
Legal Obligations and Penalties
Inventory declarations are considered legal documents, and any inaccuracies can result in Administrative Monetary Penalties. Declarations are subject to post-compliance verification. CBW TCPs can submit inventory declarations themselves or through an authorized representative, provided a Power of Attorney is in place.
Submission Options
Option 1: CBSA recommends using Application Programming Interface (API) or Electronic Data Interchange (EDI) for submitting inventory counts due to their efficiency and accuracy.
Option 2: For those without access to EDI or API, the CBSA will allow for manual CAD submissions within the first two weeks of CARM becoming the official system. The date that the CAD is submitted via the CARM portal becomes the date of accounting.
Option 3: Alternatively, CBWs can use a one-time file-upload option during the cutover period, with submissions validated by CBSA officers. However, there are there is a specific procedure to follow with this option – details here.
Questions about these new requirements for CBWs and CARM? We are always here to help, contact us.
Subscribe!
