Registration must be complete, or the final accounting of your shipments can’t be submitted to CBSA, which will result in the issuance of late accounting penalties per shipment. That means that you must register for the CARM Client Portal and delegate authority to your customs broker(s). CBSA has stressed the importance of registering for the CARM Client Portal well in advance of the
May 2024 deadline, to ensure commercial shipments are not disrupted.
CARM also impacts the way importers post financial security with the CBSA.
- If you have a BN15 or are registered on the CARM Client Portal before Release 2 goes into effect on May 13, you’ll be able to take advantage of a 180-day grace period for the financial security requirement. This means you’ll be able to import without posting your own financial security for 180 days (6 months). However, if you’re not registered on the CARM Portal prior to the release of your goods, you must do so within five business days of your shipment’s release date so that accounting can be submitted to CBSA. If you fail to complete your registration and delegate authority to your customs brokers within five business days of your goods being released, you’ll incur a $100 late accounting fee for each transaction until Portal registration, delegation of authority and retransmission of the CAD are complete.
- If you obtain a BN15 after Release 2 goes live, you will still be able to participate in the Release Prior to Payment (RPP) program for the 180-day grace period. However, the process for CBSA to input the RPP indicator in its systems will be manual and therefore will take some time. In the time it takes the CBSA to input the RPP indicator, you will not have the benefits of RPP and may need to present a cash entry.
Although there’s a grace period planned, CBSA encourages importers to obtain their financial security in advance, to minimize disruptions. The process for obtaining a bond can be lengthy.