We’ve posted many updates about the Canada Border Services Agency (CBSA) and its Assessment and Revenue Management (CARM) system, and what that means for importers.
CARM included some noteworthy changes, including to the Release Prior to Payment (RPP) Program which now requires importers to post their own minimum bond (rather than rely on their customs broker’s) to clear shipments and receive release before accounting, tax, and duty payment. A 180-day transition period (implemented to give commercial importers time to post their financial security) expired on May 20, 2025. Importers enrolled in the RPP now have their goods released electronically at the border before duty and tax payments; importers who did not enroll in the RPP program now have to pay all duties and taxes before their goods are cleared via a process called ‘self-clearance.’
Self-clearance involves the following:
- Submitting a commercial accounting declaration (CAD, type C) in person at the port of release (POR). It can be prepared in advance, offsite, or at the CBSA office using the CARM client portal but cannot be submitted electronically.
- Importers submitting a type C CAD will use a CBSA-generated transaction number that starts with five zeros; they cannot provide their own number.
- After submitting their CAD, the importer should print two copies and assemble the release and account package, which includes any permits, certificates, any paperwork required for various government departments or agencies, and the cargo document obtained from their transportation service provider (TSP, although the cargo document may not be applicable in all cases).
- When the goods arrive at the POR for examination, the importer submits the package in person for processing. The CBSA reviews the documentation, and if approved, the CAD is marked ‘complete’ and the importer is directed to make payment.
Both PCB and Roanoke have good write-ups about both the RPP and self-clearance. The bottom line is that the process is more complicated for importers without an RPP.
We recommend contacting the CARM client service and helpdesk directly to discuss the process as it pertains to your specific case. The CBSA also has a list of licensed customs brokers who may be able to offer additional information and assistance.
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