The CBSA’s CARM Client Portal is Now Live

After several years’ wait, the Canadian Border Services Agency (“CBSA”) opened registration for its online Assessment and Revenue Management system, known as CARM, on May 25th. The opening of registration, and the launch of the CARM Client Portal (the “Portal”), represents the first importer-facing phase of the multi-year initiative, which the CBSA positions as transforming the importation process.

Pre-Registration

As paper processes are phased out, Canadian importers will be required to register for the CARM Client Portal. The Portal will be importers’ primary channel to transact with the CBSA for customs accounting and reporting purposes. Fortunately, the CBSA recently published some long-awaited clarity on the registration process.

In order to register for the Portal, importing entities must have obtained a BN9 business number from the Canada Revenue Agency, as well as an importer/exporter program account identifier. (Learn how to obtain a BN9 number and an importer/exporter account identifier here.)

Importers will begin by choosing an individual to act as their company’s Business Account Manager, or “BAM”. The BAM will have full access to the importer’s Portal account, and will be the primary point of contact for the Portal. The BAM will also be responsible for granting Portal access to other members of the business, as well as requesting and accepting third-party relationships with customs broker and other third-party service providers. It is generally advisable to choose an individual who already plays an active role in business operations to act as the importer’s BAM. Given the centrality of the BAM role to the functioning of an importer’s CARM account, we recommend that businesses eventually designate multiple BAMs.

The Portal Registration Process

Those accessing an importer’s Portal (including, of course, the BAM) will create an individual user profile using either GCKey or Sign-in Partner. The BAM will link their personal user account to the business, and answer a series of authentication questions. In order to answer these questions, it will be helpful if the BAM has the following information at hand:

  • The legal name of the business;

  • The business’ mailing address;

  • Recent CBSA transaction numbers, including the total duties and taxes of the last 5 imports (these numbers can be found on the B3 Canada Customs Coding form for each transaction);

  • The last registered payment amount that was accepted by the CBSA (this can be found on your DailyNotice); and

  • The last statement of account balance.

The CBSA has emphasized that this information needs to be a perfect match for the information in the CBSA’s records (punctuation, capital and lower case letters, spaces, etc.) in order to facilitate successful registration.

Roles and Assignees

Once a BAM is authorized for the purposes of the importer’s Portal account, they can delegate certain controls to other users. For example, they can assign a Program Account Manager, or “PAM”, to modify administrative elements of the business’s CARM account. Importantly, the BAM will also assign access to a trade or customs broker as a Third-Party Business Account Manager. This will allow businesses to continue to delegate importing logistics to their broker, once they are registered and have had their BAM assign access.

Implications for Importers

Ultimately, the CARM Client Portal has the potential to streamline importing processes and generate administrative efficiencies for Canadian importers. Although the launch of the Portal only represents the first significant phase of the CARM rollout – with additional substantive changes to customs accounting processes expected within the next 12 months – it is important that businesses begin to identify their BAM and initiate the registration process. Doing so sooner rather than later will permit importers to get acquainted with the system, learn about maintaining client relationships through the online platform, and delegate business and account responsibility as desired.

We will have further updates with respect to the rollout of future CARM phases, particularly those that will require fundamental changes to importers’ reliance on customs brokers’ bonds for the purposes of the Release Prior to Payment program, in the months to come.

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