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C.A.R.M – New Canada Customs Regulation

What is CARM?

CBSA Assessment and Revenue Management (CARM) is Canada Customs’ new initiative for the collection of Duty and GST on goods imported into Canada.

Under the CARM Program, C.B.S.A. (Canada Border Services Agency) requires that all Importers settle the Duty and GST owing on Imports directly to Canada Customs. Traditionally, Customs Brokers were able to make payments for such charges on behalf of the Importers.

The Importers will have until May 2022 to register through the CARM Portal and establish their accounts.

Once CARM is fully implemented, Importers who fail to maintain a business account on the CARM portal with Canada Customs or are otherwise not in good standing may have their importing privileges revoked. Customs Brokers would no longer be able to make payments on behalf of both resident and Non-resident Importers.

Under CARM, the customs broker can still complete your Customs releases and Customs entries, however, all accounting and payment processes will transition to the Importer directly.

How will CARM affect imports to Canada?

If your client ships to Canada on a DDP basis, there will be a significant impact of CARM on their business.

Under DDP terms, the overseas Exporter must register as a “Non-Resident Importer” in Canada. In addition to obtaining a “Business number” the “Non-Resident Importer” must now also register on the Customs CARM portal for remittance of Duty and GST. The “Non-Resident Importer” must also obtain surety bonds to cover their Duty and GST liabilities. Cole International Inc., as the Licensed Customs Broker, will no longer be able to remit the Duty and GST on behalf of your client i.e. the “Non-Resident Importer”

How can I avoid the burden CARM will impose on my clients exporting to Canada?

Implementation of CARM will pose a significant administrative burden on the non-resident Importers moving goods on a DDP basis. Terms of sale – “Duty and GST inclusive” would require further evaluation to avoid the complexity of remittance to C.B.S.A. Incoterms DAP/DPU can allow greater flexibility. The remittance of Duty and GST would become the obligation of the Canadian company instead of your overseas Exporter.

For further information, please contact Atul Roy – Global Network Manager – atul.roy@coleintl.com