Importer Records Maintained Within Canada

Argo Customs Brokers is pleased to present pertinent guidance from a memorandum issued by the Canadian Border Services Agency (CBSA). The document titled Memorandum D17-1-21 – Maintenance of Records in Canada by Importers (, provides information concerning the requirements regarding the maintenance of records by importers at their place of business in Canada or at any other place designated by the Minister.


Key Takeaways

  • The memorandum has been revised to update the Canada Border Services Agency (CBSA) policy concerning the requirements regarding the maintenance of records in and outside of Canada.
  • The template of the Agreement to Maintain Records Outside of Canada was changed to the Agreement to Maintain Records Elsewhere than the Place of Business in Canada to include all scenarios where the records are not kept at the place of business in Canada.


Importer Records Maintained Within Canada:  Record-keeping requirements for imported commercial goods apply to resident and non-resident importers, including exporters abroad who ship commercial goods to themselves in Canada.

At a minimum, importers are required to keep, for the period of six years following the importation of the commercial goods, all records that relate to the origin, marking, purchase, importation, costs, and value of the commercial goods; payment for the commercial goods; the sale or other disposal of the commercial goods in Canada; and any application for an advance ruling made under Section 43.1 of the Customs Act (the Act) in respect of the commercial goods. In addition to these requirements, the Imported Goods Records Regulations (the Regulations) also require additional records be kept for various specific entities and in various scenarios.

Generally, an importer is required to maintain records at its place of business in Canada. However, an importer may submit an application to the CBSA requesting authorization to maintain records at a location in Canada other than its place of business. The form Agreement to Maintain Records Elsewhere than the Place of Business in Canada can be found at the following CBSA link: BSF900. The agreement must identify the corporate address(es) – the address registered for tax purposes, those of the place(s) of business, as well as the business address where the records will be maintained, and how the location relates to the importer (e.g., accountant’s office, customs broker’s office). If the records are kept at more than one location in Canada, they have to be integral at no less than one of the locations, or a portal must be in place to access the records electronically. Note that in order to respect the above requirements, PO boxes and mail forwarding services will not be accepted.

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