When the CBSA allows release based upon interim accounting under section 32(2)(a), trade chain partners (TCPs) are obligated to finalize this process by submitting their final accounting in accordance with sections 32(3) and 32(4) of the Customs Act, and also paragraphs 10 and 10.1 of the Accounting for Imported Goods and Payment of Duties Regulations.
The measures announced in Customs Notice 24-29: Preparing for the CARM October Implementation – Cutover Period and Customs Notice 25-02: CARM Transition Measure – Late Payment Penalties and Interest, related to interest and penalties to aid with the transition to the CARM system, did not relieve Release Prior to Payment (RPP) participants of the requirement to account within the prescribed time frames.
TCPs need to ensure that they submit the final accounting for their releases in order to maintain Release Prior to Payment benefits.
The end of the transition measure for late accounting penalties (LAPs) on January 19, 2025, means that the CBSA will resume daily monitoring of overdue releases/missing final accounting. The CBSA may issue late accounting penalties, assess duties and taxes based upon the release information provided, and post monies owing to the business number owner’s account.
The payment due date for a Commercial Accounting Declaration (CAD) is based upon the date of release.
A CAD presented after the prescribed period to account and after the payment due date will show up as overdue on the Statement of Account (SOA). When all CARM transition measures expire, a TCP may find that their account is sent to the Canada Revenue Agency (CRA) for collection if a CAD is accounted for more than 31 days after the date of release.
When a Statement of Account has not been paid by the specified due date, paragraph 34 of CN24-29 and paragraph 4 of CN25-02 state that it will be subject to collection measures by the CRA during that period.
Argo Customs Brokers Is at Your Service
If you need help managing your accounting obligations under the CBSA’s CARM framework, Argo Customs Brokers can assist. Our team can help ensure your Commercial Accounting Declarations are submitted correctly and on time to avoid penalties or collections.
Contact us today to stay compliant and protect your Release Prior to Payment status.