International Trade committee  Mine would be the same—an opt-in program for importer registration. The second one would be to have a steady system and more testing of the brokerage and importer community.

International Trade committee  I agree with the comments that have been made. Having a blackout period really prevents the registration, the accounting and the payment of duties and taxes. It really causes a lot of havoc, even in billing customers. One of the issues you can see is that customers expect the duties and tax bills during a certain period of time.

International Trade committee  I'm happy to speak about that. eManifest is a requirement for carriers to provide information in advance for security vetting of all cargo. It's information on the conveyance—the aircraft or truck information—and all the cargo. It doesn't pertain to customs release, but it's a prior step to obtaining customs release.

International Trade committee  Everything is linked together in one way or another. For example, when we talk about eManifest, as a carrier, it's an admissibility filing, saying I am admissible or not. If we don't have admissibility filing that is accurate, we can't obtain release, and then we can't do the accounting.

International Trade committee  I agree. It is about separating the two functions. There are policy pieces that relate to the CARM client portal registration, mandating that every importer must follow these steps. It's a bond. It's delegating your broker online. It's providing a lot of information in the CARM client portal and also managing that business.

International Trade committee  I did mean permanently, that there's always an option for an importer to choose to utilize a broker's security versus posting their own security and registering in the CARM client portal and hosting security.

International Trade committee  Yes.

International Trade committee  The system is different from how CARM is designed. The U.S. system has a component that's called ACE. It has a component for carrier reporting as well as customs broker reporting. There is an option for an importer to delegate the use of a broker. The requirement to report to customs, clear customs and account duties and taxes—where there are taxes in the U.S.

International Trade committee  Yes, because the requirement, as it stands today with CARM, is that it's mandatory for an importer to register and post their own security. In today's environment, an importer can use a broker's bond and security, and they delegate that responsibility to the broker. The broker pays the duties and taxes to the government and bills the customer.

International Trade committee  I don't have the numbers off the top of my head, but it ranges based on the amount of security you post.

International Trade committee  Thank you. Good afternoon, Chair and members of the committee. Thank you for the invitation to be with you here today as you continue your important study on the CARM initiative. My name is Renate Jalbert. I'm the managing director of regulatory affairs at FedEx Express Canada.