The arrival of the CBSA Assessment and Revenue Management system is nearly upon us, with October 21st being the official implementation date. For commercial importers looking to import into Canada, this new initiative represents a significant shift in the way that they interact with the Canada Border Services Agency (CBSA), but if you are a carrier that works in this area, you would be correct in wondering to what extent you are going to need to engage with this new system.

It’s a fair question, and the answer is a fair amount, depending on your situation. Carriers are foundational actors in the international trade process, and CARM is set to be the primary way that commercial entities interact financially with the CBSA, so any financial interactions carriers have with the CBSA will run through CARM. Some carriers will need it more, and some will simply need it in the periphery, but all carriers will have to register for the CARM Client Portal at some point.

It doesn’t stop there, however; carriers will have a particular role to play in the coming weeks and months because carriers in the age of CARM will be among the ones most affected by an importer failing to register in a timely fashion.

Why Would a Carrier Need CARM?

CARM, as mentioned above, is the key way that all commercial entities, like carriers, are going to interact with the accounting element of the CBSA. In a general sense, anything that could be considered a financial interaction with the CBSA will run through the CARM Client Portal. This includes, most prolifically, financial securities for bonded carriers, taxes, payments of fees, or any other accounting considerations that may arise. CARM is where statements of account, financial reports, or accounting documents you are expecting from the CBSA will reside.

It will also serve as a place to register for what are known, typically, as ‘Programs.’ After October 21st, CARM is the first stop and trusted companion through the registration process for any designation that the CBSA may provide. These ‘Programs’ include broad designations like ‘Importers,’ ‘Customs Broker,’ and, most pertinently, Transporter (Carrier or Freight Forwarder).

Existing legacy carrier codes will still keep their old numbers, but new registrations for these programs and, by extension, their relevant documentation will be applied for and maintained through this system. Similarly, larger institutions like Sufferance and Customs Warehouses are registered, and their interactions with the CBSA are managed through the portal.

This is an incredibly light touch on a topic that has a tremendous amount of depth across a wide number of potential contact points. It is recommended that if you have questions about your specific situation as a carrier, you get in touch with our CARM team for bespoke help.

With that out of the way, let’s talk briefly about CARM in a general sense and what it’s going to mean for both importers and carriers alike.

What You Need to Know About CARM?

Registering in the CARM Client Portal will require a few different things. Most importantly, you will need to have an active business number registered with the Canadian Revenue Agency (CRA) - even as a carrier. If you have imported goods yourself in a commercial capacity, you will also need specific information about your business, including several highly specific pieces of “affinity” information to help ensure your identity.

For carriers who are also importers and clients of PCB, you already have access to everything you need, including your BN and affinity information, through your personal CARM Insights page. This page also guides you through the process of registration from start to finish.

What Else Do I Need to Do? 

After you’ve followed the steps to register in the portal, be it through the CARM Client Portal page, your CARM Insights page, or the instructions of one of our CARM team members in a guided session, you will be asked to also delegate authority to your broker to act on your behalf in the CARM Client Portal. This is an important step as it will be what allows your broker to operate on your behalf.

Once you are in the portal, it is time to engage in what is, arguably, its most important function for bonded entities such as carriers or warehouses, and that is the posting of financial securities.

Importantly, importers also MUST be registered and have a bond in place, either in cash or a surety bond, or they risk penalties and potential delays. This is important for carriers as well because a failure to be properly set up in the portal can mean significant challenges for carriers in this age of CARM.

Carrying the Good News About CARM

What happens when an importer imports without CARM? The answer to that question is complicated, and it depends on when that importer obtained their RM.

There is a release prior to payment grace period that exists between October 21st, 2024, and April 19th, 2025, in which importers can still freely import their goods without too much in the way of consequence. However, qualification for this grace period is a process unto itself, and has many different considerations. Put simply, you, as a carrier, cannot count on this grace period to be in effect for all your customers and clients.

If a company isn’t registered in the CARM Client Portal, has not delegated access to its Customs broker, and/or is not within the purview of the grace period - it could mean significant challenges to your crossing, including delays.

For importers not covered by this grace period or after its expiration date on April 19th, financial security required for Release Prior to Payment will become mandatory for importers, and failing to be registered with that security in place will mean delays as the goods will need to proceed in bond or be subject to a paper release and proof of payment before being allowed to cross.

If this sounds frustrating, it likely will be, and it is a direct result of importers not yet being registered in the portal. That is why you are encouraged, as a carrier, to make sure the commercial importers you are working with are registered in the portal before you accept their shipments.

Not only do you, as a carrier, need to be in the portal to manage your bonds and interact with the CBSA’s financial offerings, but it behooves you to ensure that your clients and customers are in there as well.

In addition to helping with CARM, PCB offers many different services that can help you as a carrier. From applying for bonds to printing labels, we have the tools you need to thrive while you are on the job. For more information about CARM or what we can do to help you as a carrier, please get in contact with our team today!
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