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Business Without Borders ®

To be CARMtinued: Release 2 of CARM for importers/exporters

As we noted, CARM is going to overhaul the way the Canadian Border Services Agency approaches customs collection and streamlining of processes in general. CARM is a huge undertaking, and one that has already been postponed in Release/Phase dates. Regardless of unpredictable delays, you can and must be registered with CARM to avoid lengthy delays in importing into Canada. Not sure how? Just scroll up a bit, or click this link and you can get started with your CARM process.

Already did? Great! We’ve started unraveling your CARM journey for you and hopefully, it is making some sense. Maybe it’s even getting you excited at the prospect of greater insight into your rights as an importer? A reminder, CARM is a service provided by the government of Canada, specifically the Canadian Borders Service Agency. Streamlining the influx of imports AND the data that comes with it should be in everyone’s best interest. Working with a customs broker who has watched changes coming from both sides of the border for over 30 years is a good way to ensure you’re onboarded smoothly, and have a real person to call if you have any questions. They are uniquely positioned to separate the actions required from the confusing jargon.

Data streamlining: much ado about importing data

When you think about how much information, money and ultimately, data that the CBSA acquires, it’s remarkable that they have sat on this data for as long as they have, without seemingly doing much with it. The flow of trade is essential to any functioning (capitalist) country, and so much of that trade hinges on business and personal information required to complete transactions. A & A has seen a surge in business from clients who feel confused and unprepared for CARM, and it’s more important than ever to ensure that your business has all of its legal and financial ducks in a row, before CARM is fully implemented.


Our CEO and President, Graham Robins is hopeful that through CARM, the CBSA will be better equipped to utilize the treasure trove of information that is coming through our borders. For so long, there have been seemingly endless supplies of forms and paperwork, but little sense on how that information is being used. 

Release 2: anticipated 2023 (precise time has not yet been determined). 

The Go-Live Date (for CARM Release 2) will be 1 of 2 dates in 2023, either May 2023 or October 2023. The second release will expand upon the existing functionalities of the CARM Client Portal. Additions include:

  • Electronic commercial accounting declarations with ability for corrections and adjustments;
  • New requirements related to the Release Prior to Payment (RPP) program;
  • Harmonized billing cycles;
  • New offsetting options;
  • Electronic management of appeals and compliance actions.

Great! What does this mean for me? 

You may be wondering how this directly impacts you and your business. It is a mandatory piece of commercial importing into Canada, so you will need to do this if you want to keep importing into Canadian markets. Or, put simply, If you want to keep importing into Canada without expensive penalties and money lost waiting to be cleared. As an importer to Canada, CARM will help streamline your import processes more efficiently and allow the CBSA to collect the revenue needed to deliver the programs Canadians depend on more cohesively, with less time and paper. CARM has no impact on the release process of your imports, but it will help ensure that you’re fully compliant with import rules and regulations while paying the right customs duty. CARM will also enable you to track your forms, make payments, and reconcile your trade reports in a more standardized way.

 A & A has been following CARM closely, and a quick chat with one of our brokers with any questions you have up front could save you hours of frustration, and money. 

Will I need (or…what is?) a surety bond with CARM?

Payment directly to CBSA will require almost all importers to post a yearly surety bond. A surety bond is a three-party agreement between a contractor, an obligee and a bonding company. The surety bond protects the obligee against losses resulting from the contractor’s failure to meet an obligation of the terms of the contract agreement. It’s impossible to say for certain what will be expanded upon for CARM Release 2, but we can expect electronic versions of the Commercial Accounting Declaration, which will replace existing Customs Coding form B3 and Request for Adjustment form, B2. The whole CARM set of processes and systems makes it mandatory for all importers to be enrolled in the CCP. Importers must have their financial security processes soundly in place, or risk uncertainties, like having their shipments held at the border. 

What do I need to do to be ready for CARM Release 2?

  1. If you don’t already have one, get an importer/exporter business number by the CRA (Canada Revenue Agency). These can be challenging to obtain, particularly for non-residents, so act quickly to avoid frustrating and costly backlogs.
  2. Onboard to the CARM Client Portal (CCP) using a GCKey (Government of Canada Key), or Sign-in Partner, like you’d use for taxes.
  3. Designate individuals in your organization, whether it’s internal staff, customs brokers ????or trade consultants who can operate customs business on your behalf within the CCP. We’re biased, but you can take the CBSA’s word for it.  A & A is listed as a verified customs broker, one who can operate on your behalf, streamlining everything so you don’t have to.
  4. Obtain an importer security bond. Important to note that this is separate from the bond non-residents must have for Canadian Goods & Services Tax/Harmonized Sales Tax (GST/HST) purposes if registered for GST/HST.

Those importing goods into Canada must be compliant with the new requirements to avoid negative consequences that can cost time and money, like additional freight and storage costs or lost orders. Participation in CARM and the CCP is mandatory for any importer of goods into Canada following the implementation of Release 2. As the precise date of that is unknown, your best plan of action is to tackle everything ahead of time. If you need some help, we’re here! 

Says A & A President and CEO, Graham Robins, “A & A’s customers hire us to make the border disappear, and it’s our plan to make CARM disappear for our customers as well. Once the program is launched and in effect, it will be business as usual for our customers.”

We won’t leave you in the dark! Contact A & A today and let’s see what you need to take care of before Release 2 kicks in.

NOTE: All details pertaining to CARM R2 processes are based on the current information available at the time of writing. As this is subject to change, it’s recommended you periodically check in with the CBSA or your customs broker.