Customs Notice 25-23: CARM Release Prior to Payment (RPP) Contingency Plan – Time Sensitive/Perishable Goods

Ottawa, May 30, 2025
1. The information contained in this notice is for the attention of customs brokers (hereafter referred to as “broker”), and importers involved in the release processing of goods.

2. Effective May 20, 2025, importers without Release Prior to Payment (RPP) privileges are not eligible for release using one of the interim accounting release service options, specifically the Single Window – Integrated Import Declaration (IID), Pre-Arrival Review System (PARS) or the paper Release on Minimum Documentation (RMD).

3. The CARM RPP transition period from October 21, 2024 to May 20, 2025, provided importers the benefit of RPP privileges while allowing additional time to enroll and obtain financial security. While RPP enrollment numbers continue to steadily increase, short-term contingency measures are needed to facilitate the release of certain time sensitive and perishable goods.

4. Unless otherwise specified in this notice, brokers are reminded they are not to use their broker/importer BN15 number to expedite the release of goods for importers who have not yet enrolled in RPP and posted financial security. The only release option available to importers who are not eligible for RPP is to submit a Customs Accounting Declaration (CAD) C-type and pay applicable duties and taxes at time of release.

5. Form A48 RMD Correction presented to a CBSA commercial office seeking to change the BN15 used at time of release to a BN15 that is not eligible for RPP, will be rejected. BN15 changes post release to a non-RPP BN15 are to be completed in accordance with Memorandum D17-2-3 Business Number Changes and Commercial Accounting Declaration Withdraw Request.
RPP Contingency Plan for the Release of Time Sensitive/Perishable Goods Overview

6. Effective immediately, the RPP Contingency Plan is available to brokers for an interim period of time in order to expedite the release of time sensitive/perishable goods on behalf of an importer who has not yet enrolled in RPP and posted financial security.

7. For purposes of this contingency plan, time sensitive/perishable goods are defined as, goods that lose their value or principal utility if not used within an imminent time frame and/or goods which are subject to rapid decay and spoilage. For example: healthcare products such as blood and blood products, human organs, medical radioactive isotopes and other products needed for the preservation of human life or health; live animals; horse semen; fresh or frozen produce, meat, fish, seafood, fruits and vegetables; dairy products; plants; fresh cut flowers; etc.

8. Final accounting (CAD Type AB) is to be submitted using the true importer’s BN15.