CARM launch: Customs law delayed to Oct 21

Summary#

This federal order (Registration SI/2024-21) pushes back the date when certain parts of the Budget Implementation Act, 2021, No. 1 and the Budget Implementation Act, 2022, No. 1 come into force from May 13, 2024 to October 21, 2024. The delay aligns the law with the external launch of the Canada Border Services Agency (CBSA)’s new Assessment and Revenue Management system, known as CARM.

What it does#

• Changes the coming-into-force date to October 21, 2024 (at 3:00:00 a.m. Eastern Daylight Time (EDT)) for:
  • sections 209 to 211 of the Budget Implementation Act, 2021, No. 1, and
  • sections 303, 329 and 330 of the Budget Implementation Act, 2022, No. 1.
• Delays the related regulatory changes that depend on those legislative sections so the rules and the CARM system go live at the same time.
• Leaves the internal CBSA launch of CARM on May 13, 2024 in place so the agency can start using the system internally before the public launch.
• Explains the reason for the delay: a possible positive strike vote by the Public Service Alliance of Canada (PSAC) that could affect many CBSA staff and the CBSA decision to move the external launch window to October 2024.

Who's affected#

• Canada Border Services Agency (CBSA) staff involved in running and supporting CARM.
• Trade chain partners (often called TCPs) such as customs brokers, carriers and importers who will use CARM.
• About 71 500 importers already registered in CARM (representing over 92% of import volume), and other businesses that import goods into Canada.
• Industries that depend on customs accounting and duty payments, because the schedule for new legal obligations has changed.
• If it’s unclear who else might be affected, stakeholders are encouraged to follow CBSA communications.

Why it matters#

• The government does not want to create legal duties for traders before the new digital system is ready. Delaying the law avoids forcing businesses to meet new legal requirements when the tool to do so might not be available.
• The extra time gives CBSA staff more chance to help companies onboard and fix technical issues, which should reduce disruption for importers and brokers.
• Businesses already prepared and certified for CARM should not need further changes or extra costs because of the delay.
• Until October 21, 2024, existing systems and rules stay in place, so day-to-day import processes continue as before.