CBSA Record-Keeping Rules for Importers – What Every Importer Must Know

Importing goods into Canada does not end when the goods are released at the border. Under the Canadian Customs Act, importers must maintain complete records relating to the importation of goods.

CBSA Memorandum D17-1-21 explains the obligations of importers regarding the maintenance of records.

The purpose of these requirements is to ensure that the Canada Border Services Agency (CBSA) can verify the accuracy of customs declarations, including tariff classification, value for duty, origin, and eligibility for preferential tariff treatment.

Why Record-Keeping Is Important

Proper record maintenance allows CBSA to review and confirm whether imported goods were declared correctly.

This includes verifying:

• Tariff classification
• Value for duty
• Country of origin
• Eligibility for preferential tariff treatment
• Duties and taxes paid

Accurate records help protect importers during audits, verifications, and compliance reviews.

What Records Importers Must Keep

Importers must maintain records relating to all major aspects of imported goods transactions.

This generally includes records of:

• Purchase of goods
• Cost of goods
• Payment records
• Importation documents
• Sale of imported goods
• Invoices and contracts
• Shipping and customs documentation

These records should be complete, organized, and easily retrievable.

Where Records Must Be Kept

Records must normally be maintained at the importer’s place of business in Canada.

This ensures that CBSA can access them if required for examination or audit purposes.

How Long Records Must Be Retained

Importers must keep customs-related records for a minimum of six years after the importation of the goods.

Destroying records early or failing to retain supporting documentation may create serious compliance risks.

Keeping Records at Another Location

If an importer wishes to store records outside their Canadian place of business, approval must first be obtained from CBSA.

This includes storage with:

• Customs brokers
• Accountants
• Third-party record providers
• Locations outside Canada

Approval is generally requested through the CARM Client Portal using the:

BSF900 Agreement to Maintain Records Elsewhere

Broker Keeps the Records? Importer Still Responsible

It is important to understand that even when a customs broker or third party maintains the records, the legal responsibility remains with the importer.

Delegating storage does not transfer compliance liability.

Electronic Records Are Acceptable

Electronic records may be maintained instead of paper records, provided they are:

• Readable
• Traceable
• Accurate
• Accessible
• Capable of being produced to CBSA officers upon request

Importers using digital systems should ensure backups and document integrity are maintained.

Consequences of Poor Record-Keeping

Failure to maintain proper records may result in serious consequences, including:

• Administrative monetary penalties
• Denial of preferential tariff treatment
• Reassessment of duties and taxes
• Audit complications
• Possible CBSA enforcement actions

Final Takeaway for Importers

For businesses engaged in international trade, maintaining proper records is not merely an administrative task—it is a critical compliance requirement under Canadian customs law.

Strong record-keeping systems reduce risk, improve audit readiness, and protect importers from avoidable penalties.

Disclaimer

This article is prepared for educational purposes to help importers understand CBSA compliance requirements.

Importers must always consult the official CBSA memoranda and the Customs Act for authoritative guidance.