If you import commercial goods into Canada, CBSA expects you to keep every record tied to those shipments for six years after the goods arrive. The rule applies to Canadian companies and non-resident importers equally, and the records are supposed to sit at a place of business in Canada unless CBSA has approved a different arrangement in writing. Get either part wrong and the downside is real: the AMPS penalty for keeping no records at all runs to a flat $25,000, and CBSA can hold your goods at the border until you comply.
What counts as an import record
The net is wide. Under the Customs Act and CBSA’s Memorandum D17-1-21, importers must keep all records relating to the origin, marking, purchase, importation, costs and value of the goods, payment for them, and what happened to them after they entered Canada, including their sale or disposal. In practice that means commercial invoices, shipping documents, proof of payment, origin certificates, tariff classification support, and your sales records for the imported inventory.
If a document touches the shipment, keep it.
Electronic records are fine, with a catch: they need to meet the Canadian imaging standard (CAN/CGSB-72.34-2017), and you have to be able to hand CBSA readable copies. Your eManifest or CARM portal account doesn’t count as record keeping, so don’t treat the portal as your filing cabinet.
The six-year clock starts at importation
CBSA’s retention period runs for six years following the importation of the goods. That’s a different clock from the CRA rule most business owners already know, where books and records are kept for six years from the end of the last tax year they relate to.
The trap is assuming one retention policy covers both. A shipment that clears in December 2026 stays on CBSA’s clock until December 2032, no matter when your fiscal year ends. Most sellers who purge files by tax year end up short on the customs side without knowing it.
Records have to live in Canada, unless CBSA signs off
The default rule is that records stay at your place of business in Canada. That means real premises where the business operates. A post office box or a mail-forwarding address doesn’t qualify.
No place of business in Canada? CBSA gives you two sanctioned routes, both through the same agreement: keep the records in the United States or Mexico (the only foreign locations CBSA accepts), or designate an agent in Canada to hold them for you. Either way, the arrangement is formalized with form BSF900, approved through the CARM Client Portal. Since May 13, 2024, CBSA won’t issue an import-export account until that approval is in place, which for a non-resident seller means no clearance and no business until it’s sorted. We walk through the form itself in our BSF900 guide for non-resident importers.
What missing records cost
Record keeping feels like the least urgent compliance job right up until a CBSA verification letter shows up. At that point the file either exists or it doesn’t, and there’s no rebuilding six years of shipment documents in the short window CBSA typically allows.
When a CBSA verification finds no records were kept at all, the AMPS penalty for that contravention is a flat $25,000. Failing to produce records when CBSA asks triggers separate penalties that escalate with each request, reaching $2,400 per request. Beyond the dollar amounts, CBSA can cancel your records agreement, detain imported goods until you comply, and deny preferential tariff treatment, which converts into back duties on shipments you thought were duty-free.
The fix is unglamorous: a Canadian custodian who actually holds the documents and can answer CBSA directly. That’s the service behind our CBSA record custody arrangement, and it’s why the BSF900 names a specific address rather than a good intention.
Frequently asked questions
How long do importers have to keep records for CBSA?
Six years following the importation of the commercial goods. The clock runs per shipment from the date of importation, not from your fiscal year end.
Can I keep my import records at my office in the US?
Yes, but only with an approved BSF900 agreement, and only in the United States or Mexico. Records kept anywhere else outside Canada don’t qualify, so importers based in the UK, Europe, or Asia generally need a designated agent in Canada instead.
Do the record keeping rules apply to non-resident importers?
Yes. CBSA applies the same six-year requirement to resident and non-resident importers, including foreign sellers who ship commercial goods to themselves in Canada, which is exactly how most Amazon FBA and e-commerce importers operate.
Is CBSA’s six-year rule the same as CRA’s six-year rule?
No. They’re separate obligations with different starting points. CBSA counts six years from importation of the goods, while CRA counts six years from the end of the tax year the records relate to. You need to satisfy both.
Related guides
- BSF900 Form Filed Through CARM: Non-Resident Importer Guide
- CARM Client Portal for Importers: Setup Guide
- Customs Clearance for Amazon Sellers Shipping to Canada
- GST Registration for Non-Residents: How It Actually Works
- CBSA Record Custody Service
Not sure where your records stand?
We act as the Canadian records custodian for non-resident importers and handle the BSF900 arrangement that goes with it, alongside the GST/HST side of selling into Canada. If you’re importing and can’t say exactly where your last six years of shipment records live, get in touch and we’ll close the gap before CBSA finds it.
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