Canada Post ratifies contracts: what the end of strike disruption means for CBSA clearance and last-mile duty payment

Key Takeaways

• Canada Post’s ratified contracts end the disruption that delayed CBSA paper notices, origin certificates, and CARM K84 statements mailed to importers.
• Most CBSA processes moved online through the CARM Client Portal in 2024, but paper fallback and legal-notice timelines still depend on postal delivery.
• Importers who switched to courier delivery during the strike should confirm whether they want to revert or keep the faster routing for time-sensitive documents.
• Watch your CARM portal for arrears and K84 monthly statements that may have been mailed during the disruption but never arrived.

What just ended

Canada Post employees ratified new contracts this month, closing a labour disruption that stretched through the busiest part of the parcel shipping calendar. For most Canadian importers, the strike itself was a shrug: commercial freight moves through PARS and commercial carriers, not the postal network. But the disruption touched a handful of customs workflows that still depend on mail delivery, even after CARM went mandatory in October 2024.

Paper copies of CBSA assessment adjustments, AMPS penalty notices, and CARM K84 monthly statements all rely on Canada Post for delivery when importers or brokers haven’t opted into full electronic routing. Certificates of origin mailed from foreign chambers of commerce, required for CUSMA and CETA preferential tariff claims, also sat in limbo. The legal notice timelines for response start from the mailing date, not the day you finally see the envelope, so the strike created real compliance risk for importers who didn’t catch the electronic version first.

Now that service is resuming, the question isn’t whether mail will arrive again. It’s whether the workflows that broke during the disruption are worth fixing, or whether the workarounds you built in December are better left in place.

What moved during the disruption

Most of the customs clearance cycle didn’t notice. CAD filings, release prior to payment under an RPP bond, and duty payment all happen electronically through the CARM Client Portal. Goods released, carriers picked up, and import managers paid their K84 statements online without waiting for a paper copy.

The friction showed up at the edges. If CBSA flagged a shipment for post-release verification and mailed a D11-4-2 document request, you might not have seen it until weeks after the 30-day response window started. If you filed a CUSMA origin claim and the exporter mailed a signed certificate to your Canadian address, it never arrived in time to satisfy the verification. If you had an outstanding AMPS Level 1 contravention and CBSA mailed the Master Penalty Document with payment instructions, the notice sat undelivered while interest accrued.

Some importers switched to courier delivery for time-sensitive documents. Others leaned harder on their customs broker to monitor the CARM portal for notices that hadn’t arrived by mail. Both fixes worked, but they required deliberate changes to standing operating procedure. The importers who didn’t adjust are the ones dealing with surprise arrears and missed deadlines now that the backlog is clearing.

CARM monthly statements and the K84 reconciliation gap

The K84 monthly statement is the CARM-era replacement for the old consolidated invoice. It lists all CAD filings released under your RPP bond during the calendar month, the duty and GST owing, and the payment due date. CBSA generates the K84 electronically within the CARM Client Portal, but many importers still receive a mailed paper copy as a backup.

During the strike, the electronic version posted on time. The mailed copy didn’t. If your accounts-payable workflow depends on receiving a paper invoice before releasing payment, you either adapted or you missed the due date. Late payment on a K84 statement triggers interest at the prescribed CRA rate, currently 10 percent annually, plus potential AMPS penalties if CBSA decides the delay constitutes a reporting contravention.

We saw clients discover arrears weeks after the fact because their finance team never received the mailed statement and didn’t know to check the portal. The fix is straightforward: treat the CARM portal as the source of truth, not the mailbox. If your AP team isn’t logging into CARM monthly, your broker should be sending them a summary the day the K84 posts.

Origin certificates and the CUSMA compliance window

CUSMA preferential tariff claims require a valid certificate of origin, either signed by the exporter or prepared by the importer with supporting documentation. If CBSA verifies the claim and requests the certificate, you have 30 days to produce it. The clock starts when CBSA mails or electronically transmits the verification request.

During the strike, electronic requests arrived on time. Paper requests didn’t. If the exporter mailed you a signed certificate and it sat in the postal backlog, you had no way to meet the deadline unless you asked the exporter to courier a duplicate or email a scanned copy. Some foreign exporters don’t have that infrastructure. They print, sign, and mail. If that certificate never arrived, your duty drawback claim or preferential rate is at risk.

The same issue affects CETA origin claims. Article 23.4 of the Canada-European Union Comprehensive Economic and Trade Agreement allows CBSA to verify origin by requesting documentation from the Canadian importer. If the European exporter mailed the origin attestation and it never cleared the postal disruption, you’re stuck.

Going forward, the safest practice is to request electronic copies of all origin certificates at the time of shipment. PDF signatures are acceptable for CUSMA and CETA claims, and they don’t depend on Canada Post arriving on schedule. If your suppliers insist on mailing paper originals, have them courier the document or use a commercial carrier that integrates with your freight forwarder.

AMPS notices and the penalty payment timeline

AMPS penalties for non-compliance are issued by mail when CBSA decides a contravention occurred. The Master Penalty Document includes the assessed amount, the legal basis, and the payment deadline. If you want to dispute the penalty, you have 90 days from the mailing date to file a notice of objection.

During the strike, those mailed notices sat undelivered. The 90-day clock kept running. Importers who didn’t monitor the CARM portal for electronic copies of AMPS decisions risked missing the objection window entirely. Once the 90 days expire, your only recourse is a Federal Court application for judicial review, which is expensive and rarely successful.

If you received an AMPS penalty notice in the past three months and you’re not sure whether it was mailed during the disruption, check your CARM account history now. The electronic version will show the issuance date. If you’re inside the 90-day window and you want to challenge the penalty, file the objection immediately. Don’t wait for the paper copy to arrive.

Bonded warehouse receipts and the paper trail

Goods stored in a bonded sufferance warehouse under section 19 of the Customs Act can sit duty-unpaid until they’re released for entry into Canada. The warehouse operator issues a receipt when goods arrive, and that receipt is part of the documentation required for the eventual CAD filing.

Most warehouse operators issue receipts electronically now, but a few still mail paper copies to the importer or the broker. During the strike, those receipts were delayed. If your broker was waiting for the receipt to complete the CAD, your goods sat longer than necessary. The fix is to confirm with your warehouse partner that all receipts and transfer documents are transmitted electronically, not mailed.

What to check now

If you imported goods between mid-November 2024 and early January 2025, run through this list:

• Log into the CARM Client Portal and confirm your K84 monthly statement balance matches what you paid. If there’s an arrears balance you didn’t expect, your December or January statement may have been mailed but never received.
• Review your CAD filing history for any post-release verification requests. If CBSA mailed a D11-4-2 document request during the strike and you didn’t respond, you may have a compliance flag waiting.
• Check your CUSMA and CETA origin claims filed in Q4 2024. If CBSA requested origin documentation by mail and you never received it, follow up now before the claim is denied.
• If you received an AMPS penalty notice in the past 90 days, confirm the mailing date and make sure you’re inside the objection window.

Most importers won’t find anything. The strike affected a narrow slice of workflows, and most of those workflows had electronic fallbacks. But the cost of missing one of these deadlines is high enough that the ten-minute audit is worth running.

The longer question

Canada Post service is back, but the disruption showed how many customs workflows still assume reliable postal delivery. CARM was supposed to eliminate that dependency. Phase 2 Release 3, which went mandatory in October 2024, moved CAD filings, duty payment, and release authorization entirely online. But CBSA still mails paper copies of assessments, penalties, and verification requests as a legal backstop, and many importers still structure their AP and compliance workflows around receiving those paper copies.

If your operation adapted during the strike by switching to electronic monitoring, courier delivery, or broker-managed summaries, you’re already running the way CARM was designed. If you’re planning to revert to mail delivery now that the strike is over, that’s a choice, but it’s also a bet that the next disruption won’t happen during a time-sensitive verification or penalty window.

We file CADs and monitor K84 statements daily. If your current process depends on mail arriving on time, get in touch.

Frequently Asked Questions

Does CBSA still mail customs documents after CARM went live?

Yes. Although CBSA’s CARM Client Portal became mandatory for release prior to payment in October 2024, the agency still mails paper copies of certain notices, including final assessments, penalty decisions under AMPS, and some origin verification requests. Legal timelines for response often start from the mailing date, not the portal notification.

What CBSA documents were delayed during the Canada Post strike?

Paper copies of CBSA assessment adjustments, AMPS Master Penalty Documents, CARM K84 monthly statements, and certificates of origin mailed by foreign chambers of commerce all experienced delays. Most brokers and importers worked around this by relying on the CARM Client Portal and courier delivery, but legal notice timelines were affected for some compliance workflows.

How long does it take CBSA to issue a CAD release after payment?

Under CARM Release 3, CAD acceptance and release typically occur within four hours of duty payment posting to your CARM account, assuming no compliance flags. If you’re using an RPP bond for release prior to payment, goods clear immediately and the K84 monthly statement reconciles charges within 30 days.

Can I switch back to Canada Post delivery now that the strike is over?

Yes, but check with your customs broker first. Many importers moved to courier delivery during the disruption and found the speed gain worth keeping. If you need to update your mailing address or delivery preference in the CARM Client Portal, your broker can walk you through the change.

What should I do if I never received a CARM K84 statement that was mailed during the strike?

Log into the CARM Client Portal and check your payment history and arrears balance. The K84 monthly statement is generated electronically, so even if the mailed copy was delayed, the charges are visible in your account. If you see unexpected arrears, contact your broker to reconcile the entries before interest accrues.

Does Canada Post handle international freight shipments for customs clearance?

Canada Post does clear small parcel shipments through CBSA, but commercial freight over 1,600 kg or declared value above CAD 2,500 typically moves through PARS or non-PARS commercial streams handled by licensed customs brokers. If you’re importing palletized goods, use a commercial broker rather than relying on postal clearance.

Source: Supply Chain Dive