Thank you.
Good afternoon.
My name is Corinne Pohlmann. I'm the executive vice-president with the Canadian Federation of Independent Business, which is a non-partisan, not-for-profit organization representing 97,000 small and medium-sized companies across every industry and region in Canada.
I want to share some insights from small businesses engaged in international trade on the challenges they are facing with CARM. My remarks are based on some new data we've just collected from more than 2,000 small business owners, as well as anecdotal feedback we've been getting through our phone lines.
Many small businesses rely on importing goods to meet customer demand, access specialized materials or expand their product offerings. However, with the implementation of CARM, small businesses are starting to encounter a number of new challenges.
First of all, it is important to note that about 65% of small and medium-sized companies actually import goods and/or services. Wholesale, manufacturing, retail and agribusinesses are most likely to be importing goods, and the bigger the business, the more likely they're going to be importing.
Having said that, even among micro-sized businesses, those with four employees or fewer, about one in two are actually involved in importing goods, so the CBSA needs to make sure that CARM is accessible to them and to consider offering alternatives, such as using a broker that allows them to import goods should CARM become too complicated.
When it comes to CARM itself, only 25% of small and medium-sized businesses involved in trade are telling us that they're currently registered with CARM. The smaller the business, the less likely it is that they are registered. For those not registered with CARM, about half are just not aware of it, 22% are not sure whether CARM applies to their business, 16% are relying on their brokers and 11% are confused by the registration process.
Despite the CARM system's aim to streamline and to digitize customs processes, including the assessment and collection of duties and taxes, it has posed many challenges for businesses of all sizes, including micro and small businesses. One of the primary concerns for small businesses is the complexity of the CARM system. About half the small businesses are not importing that often—maybe once or twice a year. As such, navigating the new platform and understanding its intricacies can be daunting.
Many of these businesses have limited resources and expertise in customs procedures, putting them at a competitive disadvantage and a higher risk of making mistakes. Some have even said that the complexities in and challenges of dealing with CARM have actually caused them to reconsider whether it was worth getting involved in international trade at all.
Even though 80% of small and medium-sized businesses actually rely on a customs broker intermediary to assist them with importing, CARM has placed greater administrative responsibilities on small businesses. This added complexity not only consumes valuable time and resources, but also increases the risk of non-compliance and penalties for small businesses unaware of or unable to meet those new obligations.
For example, many have expressed concern with the added cost and complexity associated with the new “release prior to payment” requirements to secure a surety or bond, which have previously been managed by brokers.
Small businesses are also dealing with uncertainty surrounding the accuracy and consistency of CARM assessments. Errors in duty and tax calculations can have serious financial implications for small businesses, potentially impacting their profitability and cash flow.
Most recently, a member contacted us to say that the duty as well as HST on their statements had been charged twice: once through CARM and a second time through their customs broker. We've also had many comments about the fact that when there are these types of discrepancies, it can be a very big challenge to find someone at the CBSA to help them fix it.
While the CARM project aims to modernize customs processes and improve efficiency, its implementation has presented some challenges for small businesses involved in importing. When we asked small business owners whether they felt CARM would make international trade easier, 60% were unsure and more than half felt like they didn't know if CARM had considered the realities of small businesses, simply because they were unaware of what it is and how it works.
Historically, the CBSA has relied on penalties and fines to enforce compliance, which can disproportionately impact small businesses. These fines not only impose financial burdens, but also discourage small businesses from engaging in international trade due to fear of non-compliance. However, we would like to see the CBSA prioritize education and support during the first few years of CARM's full implementation, not just during the first 180 days.
We also would recommend enhancing CARM communications and information by creating tools like detailed guides, FAQs and step-by-step instructions tailored to small businesses and ensuring that the CBSA website content is in plain language. Small businesses should be able to find all these resources very quickly and easily.
Also, we recommend ensuring that all regulatory and policy changes include a comprehensive communication plan aimed at small businesses.
As well, consider providing alternative options to CARM, such as using a broker for all the small firms' importing needs, especially for those small businesses that do not engage in trade on a regular basis.
In conclusion, we would like to see a lengthier transition period that focuses on providing comprehensive training, guidance and support for small businesses, as well as some alternative options to import goods, all of which we believe will help ensure greater small business compliance and acceptance of CARM.
Thank you.