Through the Portal: A CARM Choose Your Own Adventure
An Editor's Note: While reading this blog, please note on April 19, 2024, the CBSA announced the May 2024 implementation date is postponed to October 21, 2024.
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With CBSA’s CARM go-live date only weeks away and a notable number of businesses not yet registered in the CARM Client Portal, we wanted to paint a picture of what the last 46 days leading up to implementation may look like.
CARM is a complete transformation of the way CBSA collects duties and taxes owed on your imports. There are limits placed on all Canadian customs brokers in how they support those clients who are used to the one-stop-shop service they’ve come to rely on.
There are four scenarios that Canadian commercial importers may fall into today:
- In the portal, with a surety or cash bond in place (the best position to be in)
- In the portal, with no financial security in place
- Not in the portal, with financial security in place
- Not in the portal, with no financial security in place (the most precarious)
Our goal with this post is to prompt immediate action if you find yourself in the last two categories.
It must be stated that what is depicted in this week's blog is current as of this publication, and if the past few weeks are any indication of the future, this information will most likely evolve. This further stresses the need to stay up to date with your requirements, implementation, and migration dates.
With that, please choose your own adventure, beginning your day on March 28th, 2024.
NOTE: This week’s blog is written in a ‘choose your own adventure’ style. That means the ‘pages’ are not in a standard order, and instead, you follow the instructions at the end of each section and move to the noted page to continue your hypothetical CARM journey.
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It’s a beautiful sunny morning, and you wake up to a brand new day filled with opportunity. Your middle-of-the-road hobby horse business is an importer into Canada. You attribute some of the success of your business to the people and services you have aligned yourself with, not the least of which is your friendly customs brokerage team. For years, they have kept your wooden horses rocking across the border efficiently. Since the beginning, and despite its occasional complexity, your customs broker has been empowered to handle the bulk of the heavy lifting in your payments to CBSA.
This shouldn’t suggest your situation is entirely stable. As you go through your spreadsheets and start your day, you are reminded that your profits are enough to keep your team's paychecks arriving on time and the lights on in your warehouse, but there isn’t a lot of room for error. You’ve got some ideas for the future, but right now, what’s most important is keeping things on an even keel. A few surprise costs could be the difference between striding confidently into the future and not.
Your day begins when you open up your computer, morning coffee in hand, and see an email from your customs broker regarding the Canada Border Services Agency’s (CBSA) Assessment and Revenue Management (CARM) Client Portal (CCP) requirement. You read through the newsletter and discover that CARM seems to be getting more serious and that you are only a few weeks from its rollout date. They seem very confident that the CBSA is moving ahead with its October 21, 2024, rollout date, and worse, the last chance to register is actually April 26th, as CARM will be down for a planned outage for the prior two weeks.
You take a moment to stop and think. What is your current situation?
Oh yeah, you are…
In the portal with securities posted - Go to Page 4
In the portal, but with no securities posted - Go to Page 5
Not in the portal, but your securities are posted - Go to Page 6
Not in the portal, and with no securities posted - Go to Page 7
Not bothered. You’ll check back on this in a few months - Go to Page 8
(STOP READING HERE and instead, scroll to one of the above-listed pages.)
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Page 2
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It’s April 26th, and you call your broker with the intention of finally sorting this out. Unfortunately, it seems that putting off this issue has left you in a precarious position. Your broker explains that not only are you not in the CARM Client Portal, but you also can’t get into it until after the launch date as the service is shut down for the next two weeks in preparation for its launch.
They apologetically explain that your options at this stage are limited. Under CARM, you are more responsible for your own financial securities than you ever have been before, and there isn’t very much that they can do at this late hour. You’re disheartened. Fortunately, your broker tells you that CBSA has listened to industry trade chain partners and loosened some of the previously very strict requirements regarding registering in the CARM Client Portal (CCP) and posting your own financial security to get your shipments released into Canada.
They point out that there is still a catch, however. After CARM’s implementation, you MUST register in the CCP within five days after your first shipment is released into Canada or else potentially be subject to additional penalties to account for your goods. If you can’t get registered in this window, your broker explains, PCB can still help you out for a period of time by allowing you to use their importer number to file the accounting declaration. This does involve more processing and additional fees, but it will help you avoid late filing penalties and marks against your importing compliance record.
You will end up paying a lot more money than you needed to keep your imports moving smoothly, and what frustrates you most is that it was avoidable. You feel confident that if you had known a bit more about the ramifications of delay, you would have gotten into the portal as soon as possible, but now you’ll just have to make the most of a bad situation.
END
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Page 3
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You have to admit—this is a bit more complicated than you first thought it would be. Fortunately, you’re ahead of the game and have time to get the answers you need. You pause momentarily, reflecting on what might have happened if you’d waited until the last minute. You can almost hear the busy phone lines at your broker, the surge of businesses trying to get help, or calling surety companies scrambling to establish their financial securities.
You shudder, but luckily, that’s not your fate. You’ve got time.
Maybe you join a free webinar, and from the comfort of your own home, you engage with a live course that covers all the details of CARM. You take in the process of getting into the portal, learning how to use its features, and discovering what the next few months will look like for you as a commercial importer.
You take the time to listen to industry experts explain what’s coming and what you can do to prepare. You ask questions pertinent to your business, and you take it in as your peers ask the questions pertinent to theirs. Together, you get a full picture of what is coming in CARM, and armed with this knowledge, you easily register in the CARM Client Portal.
Or, instead of the webinar, maybe you book a virtual assistance session with one of PCB’s CARM specialists. They walk you through the entire process for a small fee, showing you what needs to be done and how. You enjoy the benefits of a private instructional session where you and your CARM specialist work through the process of entering the portal, posting securities, and engaging with the new technology in a way that makes sense for your business.
Or, maybe you just take the initiative and figure this thing out yourself. You download PCB’s free CARM checklist and move through it one step at a time, asking your broker questions as they come up. It can be tricky, but you have the tools and, more importantly - the time needed to succeed.
No matter how you go about it, it’s finally done—you’re in the portal. and it looks like it’s going to be a smooth, simple, and prosperous spring.
END
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Page 4
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You’re an old CARM pro at this point. You set up your company in the portal months ago after downloading PCB’s handy checklist. You have since established your financial security and delegated access to your broker(s) and your staff while familiarizing yourself with the system.
The email encourages you to log in one more time to make sure everything is still operational, as inactivity can render your account ‘inactive’ in the days leading up to October 21st. You take the email’s recommendation and log in just to ensure everything is still active. As expected, everything is good. You lean back again, sip your coffee, and congratulate yourself for being so on the ball. You chuckle lightly, trying to imagine what it would look like had you left this to the last minute. Utter chaos, you think to yourself.
You close the email, confident you’ve done all you can, and move on to the next pressing tasks of the day.
END
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Page 5
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Suddenly, you remember: you already did this. You remember attending a free webinar and using that information to get into the portal back when your broker first told you about it - it seemed wise to get ahead of these big changes.
You keep reading and realize that the hard part for you is done. It's been a while, so you are encouraged to log into the portal again before the implementation date both to ensure it’s still active and to double-check that you have properly delegated access to your broker.
Finally, you are reminded that as an importer in the portal before the launch date, your Release Prior to Payment (RPP) privileges are extended for 180 days (the noted grace period afforded to those companies in this position). You resolve to post a form of financial security before November 9th, 2024, to avoid border delays once the grace period expires.
Still, even with that on your mind, you breathe a sigh of relief - you can get that together by then, marking a reminder on your calendar. Once again, your proactive nature and attention to detail have served you well. You relax with another task crossed off your list.
END
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Page 6
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You completely forgot about the CARM Client Portal! There was a part of you that thought it would be fine because you were previously enrolled in the Importer Direct program or you had already secured your surety bond, but actually registering in the portal has completely escaped your mind during your busy season.
Judging by the email, you are in better shape than some, but there’s still work to do. You are informed that even with your own securities, if you aren’t in the CARM portal by April 26th, you won’t be able to confirm your accounting declaration for the duties and taxes owed. Your broker will not be able to complete the data transmission to Customs, and as a result, you are at risk of late filing penalties with CBSA.
You have a few days left, but you resolve to register in the portal as soon as possible.
You decide to…
Stop putting this off! You are almost there - get in the portal already! - Go to Page 3
Put it off. You’ve done some work towards this, and you’re owed a break. - Go to Page 8
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Page 7
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You swallow the lump in your throat. You have found yourself in the worst category, and there are only days left to get this sorted out.
The email reminds you that it’s not yet April 26th, so you have time, but not a lot of it. It reiterates that if you are not in the CARM Client Portal by the 26th, you will have missed the window for getting in before the implementation date. You read on to understand that, of course, there will be time to get in the portal after, but the challenge will be the pure number of companies and people who will be flooding surety companies and brokerages on the day, which will overtax those services. If you are not in the portal ahead of time, the odds are good that you won’t be for at least a few days after - and there may be additional fees required to continue importing under those conditions.
It’s not too late to avoid a catastrophe in May—you just have to hustle today.
Do you…
Time to buckle down and get in the portal. - Go to Page 3
You need to finish up a few important projects, then you will get to CARM - Go to Page 2
Lean back and put this out of your mind. Honestly? What’s the worst that could happen? - Go to Page 8
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Page 8
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The months pass, and you suddenly wake up in a cold sweat on October 21st.
CARM.
It’s going live today! You jolt up as the impending dread of a difficult day rushes in.
You hurry to your phone, picking it up—maybe there’s still time to get into the portal…a busy tone as you and thousands of other businesses across the country struggle to get help registering in the CCP.
Frustrated, you decide to try and get into the portal yourself, but it’s confusing, and you only have some of the necessary information. For some of these questions, it feels like only your broker would have the answer! It’s a quagmire, and as you rush again to the phone, you feel a surge of panic.
Finally, after hours of patience, you manage to reach a noticeably overwhelmed broker. The agent’s tone is apologetic, but they tell you that hundreds of other importers are struggling to get registered in an effort to compliantly account for their goods.
Somewhat sheepishly, you ask if it would be possible for you to get some assistance in getting into the CARM portal…
“Of course!” they say, helping to calm your nerves. However, they inform you of some bad news. They say that you must be registered in the CCP within five days after your first shipment is released into Canada, or you could be subject to a penalty when your goods are accounted for.
Unfortunately, since there is a rush of people seeking PCB’s CARM services, there is a significant backlog, and it will be about a week before they can book you a CARM Virtual Assistance session. If you need to import now, you can, and they can still help by allowing you to use their importer number to file the accounting declaration. However, this will involve more processing on their part, which involves more fees, but it will be necessary to avoid late filing penalties and marks against your importing compliance record.
You realize that, at least for your next shipment, there is nothing left to do but pay more now and either wait to book a CARM Client Portal virtual walk-through or download the setup checklist to try getting into the portal on your own.
END
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