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For U.S. imports, keep more than the entry form: preserve the ordinary-course business records that support the information and claims in your customs declaration, organize them so you can retrieve them, and generally retain entry-related records for five years from the date of entry. The rule has exceptions, so confirm the period for each record type under 19 CFR Part 163. This guide covers U.S. Customs and Border Protection (CBP) requirements; other countries and particular products or programs may have different rules.
What counts as a customs record?
Under 19 CFR § 163.1(a)(1), a record is “any information made or normally kept in the ordinary course of business” that pertains to a covered activity, including importation, declaration, or entry. The definition reaches beyond documents submitted to CBP. It includes electronic information and data used to derive information filed with CBP.
In practical terms, preserve the records your business relied on to determine what the goods were, how they were valued and classified, where they originated, and what treatment you claimed. A document does not stop being relevant because a broker filed the entry, CBP did not request it at release, or it was not attached to the entry package.
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Part 163 covers a range of people whose activities require a declaration or entry, including owners, importers, consignees, importers of record, entry filers, and certain agents. The importer should establish who holds each record and how to obtain it, rather than assume that using a broker transfers all recordkeeping responsibility.
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CBP defines entry records to include records required for entry whether or not they were presented at the time of entry. That distinction matters: a file should not be limited to the documents transmitted to the agency. Preserve the underlying ordinary-course information used to produce the filed data as well as the final entry and entry-summary information. If CBP returns records submitted without a demand, or waives production at entry, the recordkeeping duty continues under 19 CFR § 163.3.
Build a file that supports each declaration
Organize records around a transaction or entry number. A practical file can include the following items when applicable. This is an organizational recommendation based on the regulation’s broad definition and CBP invoice guidance, not an official exhaustive checklist: the required records depend on the goods, entry type, and claims made.
| Record group | Examples to retain | What it can support |
|---|---|---|
| Filed entry | Entry and entry-summary data, including the information submitted by the filer | The particulars declared to CBP and the link between the declaration and its supporting evidence |
| Invoice and sale records | Commercial invoice or acceptable substitute, purchase order, and relevant records of the sale | Description, quantity, value, and the parties to the transaction |
| Packing and transport | Packing list, bill of lading or other transport document, and shipment records | How the goods were packed, identified, and transported |
| Classification and valuation | Product specifications, classification analysis, valuation calculations, and records of relevant costs or adjustments | The basis for the tariff classification and declared value |
| Origin and special treatment | Origin support, preference certification where applicable, and records used to substantiate the claim | Country-of-origin declarations and claimed preferential or other tariff treatment |
| Payment and follow-up | Duty-payment evidence, broker instructions, CBP correspondence, and ordinary-course records used to resolve entry questions | Amounts paid, decisions made, and the facts provided or relied on during follow-up |
CBP’s invoice guidance identifies several invoice details: an adequate merchandise description, quantities, values or approximate values, the appropriate eight-digit HTSUS subheading, and the name and complete address of the responsible invoicing party. CBP says the invoice or acceptable substitute is submitted with entry documentation before release is authorized, subject to a stated possibility of waiver when information is unavailable at release. The guidance page was published November 4, 2025; the regulation controls if an agency publication differs from it.
Match each important declaration field to its supporting record. For example, the file should let a reviewer trace a declared description and quantity to invoice and product records, and trace the value and classification to the calculations or product information used to determine them. Retain the source records, not just a final summary or a broker’s transmission receipt, if the source records are part of the ordinary-course basis for what was declared.
A useful way to check the file is to work from the declaration back to the evidence: identify each key fact filed, identify the record or data that supports it, and make sure the relationship is clear to someone who did not prepare the entry. If the filed value was calculated from multiple pieces of information, retain the inputs and calculation record that were used. If product specifications informed classification, connect those specifications to the product or SKU in the entry file. These are practical traceability steps, not a separate CBP-prescribed form.
For records held by a customs broker, supplier, or other service provider, record who holds them, how to request them, and how they will be delivered in a usable format. The obligation applies to covered persons based on their activities; simply outsourcing entry filing does not eliminate the need to be able to produce records. Make these arrangements before a request arrives, not after a response deadline has started.
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Keep evidence for preference and other claims
If you claim preferential tariff treatment, retain the applicable certification and the supporting documentation used to substantiate the claim. Part 163 expressly includes records supporting a USMCA claim among its covered recordkeeping activities and also enumerates other trade-agreement claims. A generic certificate alone may not establish every fact about a particular transaction; check the rules for the agreement and keep the underlying evidence used to make the claim.
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How long to retain each record
The general federal customs period is five years, but the start date depends on the record and the rule includes specific exceptions. The current eCFR text for 19 CFR Part 163 was stated to be up to date as of October 7, 2026. Treat the periods below as minimums under that cited customs regulation, not as a complete retention policy for every legal, tax, contractual, litigation, or program obligation.
| Record type or situation | Retention period under Part 163 | How to apply it |
|---|---|---|
| Record relating to an entry | Five years from the date of entry | Use the entry date as the starting point for the general entry-related rule. |
| Other covered record | Five years from the activity that required the record | For a covered record not relating to an entry, identify the triggering activity and calculate from that date. |
| Drawback claim records | Until the third anniversary of payment of the claim | Use the claim-payment date for this specific period. |
| Packing lists | 60 calendar days from the end of release or conditional release, whichever is later, subject to the regulation’s redelivery-demand timing rule | Do not apply the ordinary five-year calculation to packing lists without checking this specific rule and its condition. |
| Certain consignees for informal entries | Two years from the informal entry date | This exception applies where the consignee is not the owner or purchaser and appointed a customs broker. |
| Certain duty-free low-value articles and exempt manifested cargo records | Two years from entry or from the activity requiring the record | Confirm that the goods and record qualify for the exception. |
| Another regulation sets a different period | The other applicable rule controls | Check for a more specific rule before applying the general schedule. |
Where another law, contract, open dispute, or program-specific rule applies, it may call for keeping material longer. The customs periods above do not establish one universal longer period for all importers. Coordinate customs retention with the schedules used by tax, legal, and other compliance teams, and preserve records subject to an active hold or proceeding as required.
Do not set a single deletion date for every document simply because it sits in one entry folder. Different record types can have different starting events and periods. Record the relevant event—such as the entry date or, for drawback records, payment of the claim—in the index or retention schedule, and apply an exception only after confirming that the record and transaction meet its conditions. If another applicable regulation establishes a different period, follow that more specific rule.
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Part 163 generally requires covered records to be maintained as originals unless a permitted alternative method is used. Electronic storage can be appropriate, but digitizing a paper file does not by itself establish compliance. Under 19 CFR § 163.5, an alternative method must meet requirements that include integrity, readability, security, indexing, annual testing, and backups. Records must be retrievable on lawful request, and hard copies must be produced when CBP requires them.
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The regulation also provides a 120-calendar-day original-format period for certain entry records held by an importer, subject to the conditions in § 163.5(b)(2)(iii). This is a specific rule, not a universal requirement to keep every import record in its original format for 120 days. Check whether it applies to the record and circumstances before relying on an alternative format.
For paper files, use a secure, consistent filing system that preserves legibility and connects each document to the right entry. For electronic files, restrict unauthorized changes, preserve readable versions, maintain reliable backups, and use an index that supports retrieval by identifiers such as importer, entry number, entry date, supplier, and product or SKU. A scanner may help convert paper documents to digital files, but it is optional and does not replace the storage, integrity, and retrieval controls required by the rule.
When comparing paper with electronic or alternative storage, assess whether the method preserves the required original format for the applicable period, protects integrity and readability, controls access, maintains backups, and lets staff retrieve and reproduce a record promptly. Also account for any active inquiry, detention, or proceeding that may require originals. A scanner can assist with digitization, but neither a scanner nor a particular software product is a compliance solution on its own.
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- Connect each declaration to its evidence. Keep the filed entry data beside, or clearly linked to, the supporting invoice, transport, product, valuation, origin, and payment records that apply.
- Control access and changes. Limit who can edit or delete records, retain readable copies, and use a storage method that protects record integrity.
- Back up and test the repository. Maintain backups and periodically test that a colleague can locate and reproduce a complete file, including records held by a broker or another service provider.
- Maintain an export and response procedure. Make sure the records owner knows how to assemble requested files and produce hard copies if CBP requires them.
The regulation calls for annual testing as part of the alternative-method requirements; make that a scheduled control rather than an informal, one-time check. A practical test is to select an entry, retrieve its linked documents and supporting data, confirm the files remain readable, and verify that the export or print process works. Keep the procedure aligned with the storage method actually in use.
Prepare for a CBP demand
Under 19 CFR § 163.6(a), the general production period is 30 calendar days after demand. CBP may set a shorter period when records concern admissibility or release. A demand may require production or transmission, so the response procedure should cover both locating the file and delivering it in the required form.
If you need more time, submit a reasoned extension request before the applicable deadline and explain the circumstances. A request by itself does not extend the deadline; plan to meet the stated due date unless CBP grants additional time. Assign a records owner, keep current contact details for the broker and other record holders, and know in advance how to export the relevant files.
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On receipt of a demand, identify the requested entry records and the deadline first, including whether CBP has set a shorter period. Notify the records owner and any broker or third party holding relevant material, retrieve the indexed files, and check that the records are complete and readable before producing them. If an extension is necessary, send the request before the deadline and explain the circumstances; do not treat the request as approval. Keep a copy of the demand, response, and any extension decision with the entry file.
CBP’s informed-compliance publication, dated January 2005, explains recordkeeping, but expressly recognizes that regulations control if its explanation varies from them. Use the current regulation for the applicable deadline and requirements.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What can happen if records are missing?
Failure to maintain, store, or retrieve entry records can result in penalties. Under 19 CFR § 163.6(b)(1), the statutory maximum per release for willful failure is the lesser of $100,000 or 75% of appraised value; for negligent failure, it is the lesser of $10,000 or 40% of appraised value. These are ceilings specified by the regulation, not a prediction that every recordkeeping error will receive the maximum penalty.
For goods claiming certain special tariff rates, failure involving required records can also affect the applicable rate of duty. The specific consequences depend on the facts and rule involved, so do not treat a missing document as merely an internal filing problem.
The practical distinction is that the rule addresses failures to maintain, store, or retrieve required entry records; a file that exists but cannot be located or produced may still create a problem. Good controls therefore cover the entire record lifecycle—from creation and indexing through retention and response—not just the act of saving a document somewhere.
A practical review before closing an entry file
- Can the file be found using the entry number and at least one useful business identifier?
- Does it preserve the declaration and the ordinary-course records used to determine its key facts?
- Are the invoice details, quantities, values, classification, and invoicing-party identification supported by the records that apply?
- If a preference or other special treatment was claimed, are the relevant certification and supporting records retained?
- Is the retention start date clear, and has the file been assigned the correct period or exception?
- Can the designated records owner retrieve and reproduce the file, including broker-held items, within the period CBP may require?
Classification, valuation, origin, preferential treatment, regulated goods, and special entry types can affect which supporting evidence matters. A general file structure helps organize records, but it cannot replace checking the rules for the particular goods and transaction. The eCFR is authoritative but unofficial; consult the applicable formal CFR and current requirements when making a legal or compliance decision.
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Frequently Asked Questions
How long should I keep records for a U.S. import declaration?
The general rule is five years from the date of entry for an entry-related record, or five years from the activity that required creation of another covered record. Part 163 has exceptions for certain records, including drawback records, packing lists, some informal entries, and certain low-value or manifested cargo. Check the period and start date that apply to each record.
Do I have to keep documents that were not submitted to CBP?
Often, yes. Part 163 covers records required for entry whether or not they were presented at entry, along with relevant ordinary-course business information and data used to derive information filed with CBP. A broker filing the entry or CBP waiving production at entry does not by itself end the recordkeeping duty.
Can I keep customs records electronically instead of on paper?
Electronic storage or another permitted alternative method can be used if it meets Part 163 requirements, including integrity, readability, security, indexing, annual testing, and backups. Records must be retrievable on lawful request, and hard copies must be available when CBP requires them. The 120-day original-format provision applies only to certain importer-held entry records under stated conditions.
How quickly must I respond to a CBP records demand?
The general period is 30 calendar days after demand. CBP may prescribe a shorter period for records concerning admissibility or release. If you need more time, request an extension before the deadline and explain why; submitting a request does not itself extend the deadline.
Does my customs broker keep the records for me?
A broker may hold or file some records, but using a broker does not transfer every covered person’s recordkeeping responsibility. Know which records the broker holds, how to obtain them, and how to produce them within a CBP deadline.
Are the five-year periods the only retention rules I need to follow?
No. Part 163 sets federal customs minimums and exceptions, but another regulation or an applicable tax, contractual, litigation, or program requirement may call for longer retention. Coordinate the customs schedule with the relevant requirements for your business and transaction.
The Bottom Line
Build each U.S. import file around its entry number, keep the ordinary-course records that support the facts and claims declared, and apply the correct Part 163 retention period to each record type. Use storage that preserves integrity and lets you retrieve and reproduce the file promptly; the general production window after a CBP demand is 30 calendar days, but a shorter deadline may apply.
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