If you’re an Amazon seller based outside of North America looking to expand into the Canadian market, there’s a compliance step you might not be aware of: Canada Border Services Agency (CBSA) record keeping requirements.
In a nutshell, if you import goods into Canada as a non-resident importer (NRI) – which is often the case for global Amazon and e-commerce sellers – you are required by law to maintain your import records in Canada for several years.
This blog article will explain what CBSA record keeping entails, why it matters for Amazon FBA and other e-commerce sellers, and how our new CBSA record storage service helps you stay compliant without tying you down to a single customs broker.
Understanding CBSA Record-Keeping Requirements
CBSA’s 6-Year Rule: The CBSA requires all importers to keep detailed records of their imports for six years after the importation date cbsa-asfc.gc.ca. These records include things like invoices, shipping documents, proof of payment of duties/taxes, origin of goods, and any permits or advance rulings related to your shipments. In other words, essentially “all records” relating to your imported goods must be retained for audit purposes. This applies equally to Canadian businesses and to foreign importers (NRIs) who ship goods into Canada.
Where Must Records Be Kept? Under Canadian customs law (Section 40(1) of the Customs Act), your import records are supposed to be kept at your place of business in Canada. Of course, if you’re an overseas seller, you likely don’t have a physical office in Canada.
The CBSA anticipated this scenario: non-resident importers can request permission to keep their records at an alternate location in Canada. In fact, you are required to designate an agent in Canada – such as a licensed customs broker or accountant – who will maintain these records on your behalf, with CBSA’s approval cbsa-asfc.gc.ca. This is typically done by submitting an official request (via form BSF900 through the CBSA’s CARM portal) to authorize a specific Canadian address/agent for record storage.
Why is this important?
CBSA can ask to inspect your records at any time as part of a trade compliance audit. If you cannot produce records in Canada when asked, you risk heavy penalties. Failing to keep records in Canada for the required period can trigger fines of up to $25,000 per audit under Canada’s Administrative Monetary Penalty System (AMPS). Likewise, not providing records when requested can lead to escalating penalties on each request. In short, proper record-keeping isn’t optional – it’s a legal must for anyone importing into Canada, including Amazon FBA sellers overseas.
Non-Resident Importers and the Need for a Canadian Records Agent
Who is a Non-Resident Importer?
A Non-Resident Importer (NRI) is simply an importer of record who does not have a physical presence in Canada. Many Amazon sellers and global e-commerce businesses fall into this category when they ship inventory to Canadian customers or Amazon fulfillment centers (FBA warehouses). As an NRI, you enjoy the benefit of accessing the Canadian market without setting up a local company – but you also inherit the same compliance obligations as Canadian importers that includes registering for a Canadian business/import number and, of course, maintaining your importation records properly.
The Records Maintenance Challenge
Since you likely have no office in Canada, you need another way to satisfy the “keep records in Canada” rule. The CBSA allows you to designate a Canadian party to hold your records. Some NRIs have relied on their customs broker to fulfill this role usually if they are exclusively using them. For example, if you hire a customs brokerage firm to handle your shipments into Canada, they might offer to store the required documents for you at their Canadian office, but that means you are tied to that customs broker.
An accountant or another authorized agent in Canada can also do this.
The key is that CBSA must officially approve where and with whom your records are kept. In fact, starting May 2024, CBSA has tightened enforcement of this requirement: new importer accounts won’t even be issued unless you have an approved records maintenance arrangement (Form BSF900) in place via the CARM portal cbsa-asfc.gc.ca.
This means before you can begin importing, you must have your record-keeping agent and location sorted out – underscoring how critical this step is for new Amazon sellers expanding to Canada.
Consequences of Non-Compliance: Ignoring this requirement is risky. CBSA’s audits are not hypothetical – they do conduct trade compliance verifications. If your records aren’t where they’re supposed to be (i.e. accessible in Canada through your designated agent) or you haven’t kept the necessary documentation, you could face those steep fines (up to $25,000 per audit as noted above) and potential disruptions to your ability to import. For a small business or individual seller, such penalties can be devastating. Beyond fines, non-compliance can damage your credibility with customs authorities, possibly leading to increased inspections or delays on your shipments. In short, staying compliant with record retention rules is not just a bureaucratic box to tick – it’s essential for keeping your cross-border business running smoothly.
Common Record-Keeping Solutions (and Their Limitations)
Given the importance of CBSA record compliance, what options do non-resident sellers have? Traditionally, most NRIs have taken one of two approaches:
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Using a Customs Broker’s Record-Keeping Service: Some customs brokers in Canada will agree to be your “agent” for record maintenance (often as part of their brokerage services). This makes sense – your broker already handles your import paperwork, so they can archive it for the required period. However, there’s a catch: in many cases, brokers offer this service only if you use them exclusively for all your shipments. In other words, if you sign up with Broker X to be your record keeper, Broker X expects to clear all your goods into Canada. This can lock you into a single service provider. If their rates aren’t competitive or their service doesn’t meet your needs, you might feel stuck because switching brokers could jeopardize your record-keeping arrangement.
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Hiring an Accountant or Third-Party in Canada: Some sellers work with Canadian accountants like Jones and Cosman who store digital copies of records and ensure compliance. This can be a good neutral solution, but you have to ensure they understand CBSA requirements thoroughly. Additionally, you’d likely still need to coordinate getting every import document to them and be confident they’ll manage any CBSA inquiries. There may also be challenges if your volume grows or if CBSA wants to inspect records in person.
Both of these traditional solutions come with a degree of inflexibility. Relying on a customs broker often means sacrificing the freedom to shop around for the best shipping or brokerage deal for each shipment. You might also worry: “What if my broker decides to exit the business or I outgrow them?”
Our Flexible CBSA Record Storage Service for Amazon & E-Commerce Sellers
We heard these concerns and created a new service designed for sellers just like you. Our CBSA record storage service is a compliance solution that lets you meet all Canadian customs record-keeping requirements while maintaining complete freedom in how you manage your imports. Here’s how it works and why it’s different:
Authorized Record-Keeping Agent
We operate as an authorized agent (in the capacity of a customs brokerage service and/or through a certified accountant partner) to maintain your import records in Canada, as allowed by CBSA cbsa-asfc.gc.ca. When you sign up, we’ll get you set up with the necessary CBSA authorization (including handling the BSF900 agreement process) to officially designate us as your records keeper in Canada. This means you’ll be fully compliant – your records will be stored securely at our Canadian storage servers and registered with the customs authorities.
Use Any Customs Broker or Carrier
Unlike traditional brokers, we don’t require you to use us for customs clearance for your shipments. You are free to use any customs broker, freight forwarder, or shipping carrier of your choice for importing your goods. Whether you’re using Amazon’s Global Logistics, UPS, a specialized freight forwarder, or different brokers for different shipments, it doesn’t matter. You simply upload the documents for each shipment in your own restricted folders, and we ensure all relevant import documents get logged in our system. You retain flexibility and control over your supply chain, and we take care of the compliance back-end.
Centralized Digital Recordkeeping
For every shipment you import into Canada – whether it’s inventory going to an Amazon FBA warehouse or direct-to-consumer orders you will securely store all required records (commercial invoices, B3 customs forms, bills of lading, duty receipts, etc.). If CBSA initiates an audit or asks for documentation, you won’t be scrambling to collect papers from various brokers or sources; instead, you can confidently direct the request to us and we’ll handle the rest. Your records are organized, backed up, and readily accessible in Canada, as per CBSA’s requirements.
Compliance Monitoring and Updates
We stay on top of CBSA regulatory changes (for example, recent CARM portal requirements and any updates to record retention rules). As part of our service, we’ll inform you if there are new compliance steps you need to take, so you’re never caught off guard by changing laws. Our focus is keeping you compliant at all times, so you can focus on growing your business.
Benefits of a Flexible Record-Keeping Service
Using our CBSA record storage solution offers several key benefits for Amazon sellers and other global e-commerce businesses:
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Guaranteed CBSA Compliance: You meet all CBSA record-keeping obligations without having to set up a physical office in Canada. We ensure your records are stored at a valid location in Canada and available to CBSA on demand, protecting you for non-compliance. Peace of mind is priceless when you’re dealing with international regulations.
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Freedom to Choose Your Broker/Forwarder: Enjoy flexibility in logistics. You’re not locked into a single customs broker contract. Use the customs brokers or shipping services that make sense for your business (cost-wise, speed-wise, etc.) for each shipment. We’ll work in the background with any provider by handling the recordkeeping separately. This can potentially save you money and let you adapt as your business grows or as better shipping options come along.
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One-Stop Record Management: Keep all your Canadian import records in one place. Even if you have multiple suppliers or use multiple shipping methods, all your documentation is centralized with us. This makes it easier to track what’s been imported, when, and that everything is retained properly. It also simplifies responding to any inquiries from CBSA or the Canada Revenue Agency (for GST/HST audits related to imports, for example).
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Expertise on Your Side: Our team understands the ins and outs of CBSA regulations and Amazon’s importing processes. We can answer your questions about things like importer of record setup, business number registration, and how to handle documents for Fulfillment by Amazon shipments. Think of us as not just a storage service, but your consultant for Canadian import compliance. If an issue arises (say, a customs audit or question), we’ll guide you through it – a level of support you might not get from a generic document storage solution.
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Fast Setup and Integration: Getting started is straightforward. We’ll help you file the necessary request with CBSA to name us as your record-keeping agent. Once approved, you can immediately start listing our address as the “records location” on import documents. We also provide simple guidelines for your freight providers or customs brokers to forward us copies of entry documents. In short order, you’ll be fully set up and compliant without heavy bureaucracy on your end.
Expanding to Canada Made Easy and Compliant
Entering the Canadian market as a global seller offers huge opportunities – Amazon Canada (Amazon.ca) has millions of shoppers, and fulfilling orders through FBA or other channels can significantly boost your sales. Compliance hurdles like CBSA record keeping should not hold you back. Our service was created to remove this barrier by giving you a hassle-free way to satisfy Canadian customs requirements.
Ready to expand into Canada with confidence? Get in touch with us to learn more about how our CBSA record keeping and compliance solutions can support your business. We’re here to help global sellers thrive in Canada, offering the freedom to choose your partners and the assurance that you’re meeting every requirement along the way. Here’s to growing your Amazon business internationally – without compromise on compliance or flexibility!
Sources:
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Canada Border Services Agency – Memorandum D17-1-21: Maintenance of Records and Books in Canada by Importerscbsa-asfc.gc.cacbsa-asfc.gc.ca