Welcome back, dear readers, to our second annual PCB Halloween post! Someone at the CBSA has at long last solved the Lament Configuration, and love it or hate it - CARM has arrived. We are a week into this scary new regime, and the PCB CARM team has seen firsthand some of the jumpscares that our clients are experiencing with this new system.

There are going to be tough lessons for Canadian commercial importers of all shapes and sizes to learn in the coming weeks, but as the grizzled old gas station attendant you stop to talk to before you arrive at your cousin’s cabin in the woods, allow us to fill in the gaps with some experience we’ve gained on our side of the phone. 

Let’s face our fears together, and by the end of this post, hopefully, you’ll be better equipped to stride into this brand-new psychological thriller we call CARM, and if we’re all lucky, we might just survive to see the trilogy. 

Saving Graces

Reprising its role as the heroic babysitter in this slasher flick, the CBSA has offered several ‘grace periods’ as Canadian commercial importers transition into this new system. Specifically, they have offered a 90-day period where importers will not incur penalties or interest for late payments or filings. There is also a 180-day grace period where importers can continue to ship without having financial securities in place.

There are a few things to note about these grace periods. The first and most important thing is that while they are there to cushion this moment of transition, you shouldn’t rely on them, and you should know that they can cause more complications than they actively solve. For example, while you won't incur interest for 90 days, you still are obligated to pay your duties and taxes. If you don't pay each month during the 90-day grace period, CBSA can still send you to collections. Once the grace period is over, then you may incur significant penalties if you haven’t determined how to appropriately manage these processes. Always remember to stay on top of this because importing is a privilege CBSA bestows and also takes away! 

Similarly, having your financial securities in place is a vital part of receiving Release Prior to Payment (RPP) privileges. RPP, for the uninitiated, is a privilege that the CBSA extends to importers that allows them to have their goods cross the border with the understanding that the duties and taxes will be paid at a later date. It’s essentially a way for importers to have goods cross the border without needing to physically be at the border when they cross. As an importer, there are few benefits that are more useful and worth protecting than RPP privileges.

While you have 180 days to get a bond in place, additional steps and direct contact with the CBSA could be required to benefit from those privileges in the intermittent time. And, if at the end of the 180 days, you haven’t established your financial security, you will no longer benefit from RPP privileges. 

Dooming Curses

Unfortunately, like any good horror movie protagonist, it could be too late for some to avoid their fate. If you applied for your RM extension between October 4th to 18th, and you have no prior importing history, you may not have RPP privileges available to you by default. 

Similar to the bonds mentioned above, your RM number and RPP go hand in hand, and if you don’t have an RM number, you will have to work with the CBSA through the CARM portal to get those privileges in place during the grace period.

It is also worth noting that if you have not yet applied for your RM number at the time of this publication, then there is a good chance you, too, will fall under the same curse. If you do not pay in person or prepare financial security with the CBSA beforehand, your goods will be turned around at the border. It has already been happening, and once these grace periods begin to expire - it’s only going to get worse for those who are not prepared. 

There’s no easy way to put it - the witching hour is upon us. If you have not yet taken steps to get into the portal and do the things that are now mandatory for Canadian commercial importers, things are going to get very scary for you very quickly.

No Reanimating CAD-avers 

Another thing we’ve noticed in this ghoulish first week is a level of misunderstanding and confusion when it comes to submitting Customs Accounting Documents (CADs). With that in mind, a significant number of clients have been attempting to submit their own CADs through the portal, but like the basement at the Old Miller’s House, you probably shouldn’t be going it alone. 

The CBSA has implemented many new notifications with CARM, and you may be seeing things that seem scary or you don’t fully understand yet. Before we go any further, the best way to ensure that you are set to survive to the credits is by contacting your broker before doing anything. If PCB is already handling your final accounting, you don’t need to worry about submitting your own CAD, despite what it might say in the portal. 

We’ve had many people seeing “overdue” notifications in the portal and panicking, often making mistakes or submitting incorrect data in an attempt to rectify perceived problems. We understand this is a whole new world for everyone, and we’re all figuring it out together, but in this particular case, the best course of action is simply to get in touch with your broker and ensure everything is on track before taking any action at all.

If you aren’t using a broker for your CAD submissions, you should consider it. However, if you are determined to do it yourself, be careful about what data you are submitting and ensure that you are submitting the correct information at the right time. If you have questions or confusion, please contact our CARM team today. 

As the old adage goes, if there’s something strange in your neighborhood - who you gonna call? Your broker!

With that, PCB’s incredibly scary CARMoween post ends, and if there is one thing you take away from this, let it be that CARM is here, and for the unprepared, the horrors could just be beginning.

We have been saying it for a while now, but it has never been more imperative that you get correctly set up in the CARM Client Portal. However, perhaps even more critical than simple registration is that you fully understand your obligations with this new system.

What elements of CARM do you want to do yourself? Which do you have to do yourself? And what elements should you leave to your broker? 

If your answer to the last one is - ‘everything,’ then we have a service for you. Our CARM Payments service allows us to manage the accounting elements of the CARM portal on your behalf, making this process as simple and frustration-free as possible.

It is also vital for your continued success that you also take advantage of the educational resources that are available. The PCB Learning Center’s next webinar is on October 29th, and it is dedicated to teaching importers how to make payments in the CARM portal. Be sure to book your seat as soon as possible, as it is filling up fast.

All fear is rooted in a fear of the unknown, and the best way to contend with the unknown is by engaging with it head-on. For any and all questions or concerns about CARM, we encourage you to get in touch with one of our CARM experts today.