What should importers expect with CARM R2 and the CN24-14 blackout period announcement?

CN24-14 blackout period

Prior to May 13, 2024, the CBSA’s existing systems will go offline at 4:00 p.m. EDT on April 26, 2024. Importers who have not registered in the CCP by April 26, 2024, may experience the following temporary effects:

• Inability to clear goods through customs — Shipments could be held at the border or require costly alternative clearance processes (paper Form B3 submissions, in-person interventions by customs brokers, etc.).
• Inability to create new importer accounts — It will not be possible to create a new RM account with the Canada Revenue Agency (CRA) or CBSA systems between May 10 and May 13, 2024. The CRA will no longer register import accounts as of May 10, 2024, at 7:00 p.m. EDT. New requests must be made in CARM starting on May 13, 2024, at 3:00 a.m. EDT.

Importers, both those registered and not registered in CARM by this time, are also advised that no electronic customs accounting filings will be possible during the blackout period. While shipments will continue to be electronically released throughout the period, it will only be possible to account for such shipments electronically from May 13, 2024, onwards.

The CBSA is not expected to entertain an increase in paper accounting submissions barring exceptional circumstances. However, it is expected to limit or waive any late accounting consequences for importers accounting up to two weeks late due to the blackout.

Customs business process changes

Once registered, the CCP will be a resource to track all your shipments, payments, and other useful information. Importers will also need to consider and grant varying levels of CCP access to relevant employees and TCPs to be fully operational in CARM.

CARM R2 will introduce the following changes:

• Electronic management of virtually all customs business — Customs accounting, scenario planning (e.g., using the duties and taxes calculator), making payments on the CCP, ruling requests, and post-importation corrections and refunds, will all be part of CARM. Trade verifications will be conducted via documents communicated to and from the importer via the CCP, and applications for various special programs (such as the Duty Relief Program) will also be filed in the CCP.
• Electronic commercial accounting declarations (CAD) — A new commercial accounting declaration will replace the current B3 (customs coding) and B2 (request for adjustment) processes.
• New harmonized monthly billing cycles — The CARM R2 Statement of Account period starts on the 18^th of the previous month and ends on the 17^th of the month. The account must be settled within 10 weekdays (with no deferral due to holidays) of the statement date.
• Changes to the RPP program — Commercial importers are required to post their own security bond. Previously, goods released prior to payment of duties and taxes were normally secured by the customs broker’s bond.

CARM does not impact exporters and export transactions, which are managed through the NEXCOL system. It is also expected to provide full continuity for interdependencies with the functioning of import/export licensing and permitting systems such as MyCFIA and NEICS.

Accessing the CCP

A business number and an import account are required to create a user account in the CCP. Each user will need to set up a GC Key or use the online Sign-In Partner.

Existing importers with a history of import transactions need to be prepared to answer affinity questions respecting their past transactions, payments, and statements of account in order to complete.