CARM’s focus is on modernizing, streamlining, and transforming the way duties and taxes are collected on imported goods. On May 25th, CBSA officially launched Release 1 of its new CARM Client Portal, a self-service tool meant to facilitate accounting and revenue management processes for companies importing goods into Canada. The first phase in the CARM rollout introduced the basic portal functionality available only to importers, brokers, and trade consultants. At this stage, registered users can view their transactions and statements of account, request a ruling, and pay invoices with new electronic payment options.
In Spring of 2022, CBSA says it will expand the functionalities of the CARM client portal by adding electronic commercial accounting declarations and the ability to make corrections and adjustments. At that point, the remaining trade chain partners (e.g., carriers, exporters, surety companies, etc.), are expected to be able to enroll into the portal. The second phase will also include changes to release-prior-to-payment requirements for bonds; harmonized billing cycles; new offsetting options; and the electronic management of appeals and compliance actions.
Tackling Bond Requirements
Past and current practices allow brokers to facilitate the payment of duties, taxes, or both to CBSA on behalf of importers, and invoice their customers for the total amount due. CARM focuses on shifting the responsibility for payment of those financial obligations from the broker to the importers to pay CBSA directly. To maintain release prior to payment (RPP) privileges, importers (both resident and non-resident) must post their own surety bonds.
Schenker is helping importers manage this complexity through an arrangement made with a selected surety company. “Our teams are experienced and fully engaged to facilitate a seamless process for our clients by working closely with the surety company and CBSA,” said Eleonora Delibaltov, Senior Manager, Regulatory Affairs and Consulting at Schenker Canada, “with the goal of getting importers set up on a Customs D120 bond.”
For now, any importers that have not prepared their businesses and/or worked with a surety to get their D120 customs bonds set up will need to act quickly. “As a service provider,” said Delibaltov, “Schenker Canada is highly encouraging clients to do this step a minimum of six months ahead of CARM’s Phase 2 Go Live, anticipated for May 2022, to avoid the last-minute influx of requests, processing delays or risking not getting their goods released.” Only importers having zero ($0) accounts payable within the last 12 months will not require a bond. This status will need to be indicated within the appropriate CARM portal field.
Delibaltov stated that, “The portal will have the capability to monitor and measure the security utilization of each importer and send nudges to the importer to provide increased security if the accounts payable exceeds the amount of the secured bond amount.”
Put simply, importers that aim to have their bonds in place by October 2021 will be prepared in advance and have time to prepare financially, make the related business decisions, and alter their business processes accordingly.
CARM Client Portal Registration
To register for the portal, importers need to have a BN9 business number issued by the Canada Revenue Agency and an import/export program account identifier. All users must log into the CARM Client Portal using a GC Key registration setup with CBSA or a Sign-in Partner and create a personal profile. Once importers are registered and able to log into the CARM portal using their credentials, their Business Account Managers (BAMs) can delegate authority to their customs broker, get set up to receive dashboard notifications, and begin to navigate the portal.
Providing a Helping Hand
Delibaltov said that the Schenker Canada Customs team has been helping importers choose their companies’ BAMs, noting that this highest management access role, with complete read, write and edit privileges, should be assigned to a minimum of two employees (i.e., just in case the first one moves into a new role or leaves the company).
Within the CARM portal, importers can delegate authority to Schenker of Canada Limited, using the ‘Manage Business Relationships’ menu from the main dashboard. “If we do not have the appropriate delegation of authority established within the CARM portal, we would not actually be linked between the importers and broker’s business accounts,” said Delibaltov, “and we will not have any visibility to provide them with any services.”
Delibaltov emphasized that “During the delegation of authority, in order for us as a broker to be able to see a client’s SOA in the portal or be able to reconcile their account, we will need to have BUSINESS Management selected (not Program Management), as well as all three (3) Transaction Visibility Rules checked off.”
To help importers adjust to the new requirements, the Schenker Canada Customs team has also been holding one-on-one sessions with these companies, walking them step-by-step through the CARM Client Portal registration process, showing them how to navigate the portal, and explaining the new rules and functionalities. Other importers have asked Schenker to provide statement of account (SOA) information, which they can use to search for transactional information and be able to answer the affinity questions that are a mandatory part of the CARM portal registration process.
As importers adjust to the new regulations, the CARM portal tool and do-it-yourself duty and tax payment requirements, Schenker of Canada Limited will continue to offer guidance, support, and services to those already using the portal while also helping other entities prepare for the phase 2 rollout, scheduled for the Spring of 2022.