CARM Release Prior to Payment: Make RPP Status a Release-Control Check

The recent review of CARM and Release Prior to Payment (RPP) materials found no qualifying new change to CARM Client Portal functionality, RPP eligibility or the requirement to pay duties and taxes at release when an importer is not enrolled in RPP. For importers in Toronto, Mississauga and Brampton, the practical issue is therefore control: the release team should confirm the importer’s RPP position before treating a shipment as eligible for release prior to payment.

What the current rule means

RPP is not a general release instruction that can be applied because a shipment is urgent, the goods are already at the airport or the importer has previously paid on time. The CBSA’s RPP guidance states that importers using the programme are required to post their own financial security. Importers who are not enrolled in RPP are generally required to pay duties and taxes when the goods are released. The same guidance identifies the CARM Client Portal as the system used for account management, RPP enrolment and financial-security administration. CBSA, Release Prior to Payment

That creates two different release paths:

• RPP path: an importer with the relevant enrolment and financial-security position may have release processed before payment, subject to the applicable release and accounting requirements.
• Non-RPP path: an importer without RPP generally needs duties and taxes paid at release rather than relying on release prior to payment.

The key control is not whether the broker has handled the importer before. It is whether the importer’s current CARM and financial-security position supports the requested release treatment.

What did not change in the recent review

The CBSA customs-notice index does not show a CARM or RPP notice issued or revised during the reviewed July 3 to October 1, 2026 period. The notices listed in that period concern other customs matters, including surtaxes, warehouse notices and unrelated procedures. The index identifies Customs Notice 25-23, concerning an RPP contingency plan for time-sensitive or perishable goods, as the most recent specifically RPP-related notice shown in the supplied research; that notice was revised on August 9, 2025. CBSA customs notices index

Memorandum D18-5-1, dated June 30, 2026, is also not an RPP eligibility revision. It addresses excise and GST-exemption coding in CARM. It predates the reviewed period and does not change the release-prior-to-payment or financial-security position described above. CBSA Memorandum D18-5-1

For operational purposes, this means an importer should not treat a recent CARM coding update, a notice about another customs programme or a change in shipment urgency as evidence that RPP treatment has changed.

Build the RPP check into the release queue

1. Identify the importer of record

The release decision should be tied to the importer whose account and financial security support the transaction. A freight forwarder, customs broker or related company may coordinate the shipment, but those roles do not by themselves establish the importer’s RPP position.

For groups operating warehouses or distribution functions across Mississauga, Brampton and Toronto, this check is especially important where multiple legal entities share purchase orders, vendors or receiving locations. The release instruction should identify the importing entity rather than relying only on a facility name or internal business unit.

2. Confirm the requested treatment

The release file should state whether the importer is requesting release prior to payment or is arranging payment of duties and taxes at release. This prevents a shipment from entering the wrong work queue simply because the request was described as “urgent release” or “clear as usual.”

Importers generally should discuss with their broker how RPP status is verified before the release request is submitted, particularly when an account has recently changed ownership, legal name, financial security or internal customs responsibility.

3. Check CARM and security status before escalation

Because the CARM Client Portal is used for RPP enrolment and financial-security administration, the importer’s CARM records should be treated as a source of release-control information. If the account team cannot confirm the relevant status, the shipment should be escalated for review instead of being assumed eligible for release prior to payment.

This is a control question, not merely an accounting question. A shipment may be physically ready for release while the importer’s payment treatment remains unresolved. At a Peel Region warehouse, that distinction can affect receiving plans, delivery appointments and inventory availability even when the freight itself has reached the GTA.

4. Record the outcome

A useful transaction record should capture:

• the importing legal entity;
• the requested release treatment;
• the CARM and RPP status reviewed;
• the financial-security issue identified, if any;
• the broker instruction and date of confirmation; and
• the reason for any payment-at-release exception or escalation.

The record does not replace the importer’s responsibility to maintain accurate account information. It gives the release team an auditable explanation for why the shipment was routed through one payment path rather than the other.

Questions to resolve with your broker

Importers should consider putting the following questions into their release procedure:

1. Which legal entity is the importer for this shipment?
2. Is that entity currently treated as eligible for RPP in the relevant CARM workflow?
3. Does the importer’s own financial-security position support the requested treatment?
4. If RPP treatment cannot be confirmed, what payment arrangement is required before release can proceed?
5. Who is authorized to change the shipment from release-prior-to-payment handling to payment-at-release handling?
6. Where is the confirmation recorded for audit and month-end reconciliation?

These questions are useful for air cargo arriving through Pearson, truck freight moving through the 401/407 corridor and imports destined for GTA distribution. The transport mode does not, by itself, determine whether the importer can use RPP; the relevant control is the importer’s programme and financial-security position.

Practical conclusion

There is no newly identified CARM or RPP development in the reviewed period that changes the basic release decision. Importers generally using RPP need to maintain their own financial security and keep the relevant CARM account information current. Importers without RPP generally need to plan for duties and taxes at release. CBSA RPP guidance

The actionable change should be in the importer’s internal queue: make RPP status, importer identity and financial-security confirmation prerequisites for a release-prior-to-payment instruction. That approach reduces the risk of treating operational urgency as a substitute for programme eligibility.