19 U.S.C. § 1508 requires importers to retain customs-related records for 5 years from import date. Records include entry summaries, commercial invoices, bills of lading, supplier certificates, BOM analyses, USMCA Certificates, valuation documentation. CBP can request records for audit during the retention period.

This guide covers Customs Recordkeeping Requirements. Customs compliance audit work covers CBP focused assessments, CBSA Trade Compliance Verifications, and ongoing compliance program work.

For SMB importers, the practical implementation depends on volume, sector, and operational structure.

Records covered

Entry summaries (Form 7501), commercial invoices, bills of lading/air waybills, supplier certificates of origin, USMCA Certificates, BOM analyses, valuation documentation, broker correspondence.

Retention period

5 years from import date for U.S. CBP. 6 years for Canadian CBSA. Specific records (drawback) may require longer.

Storage formats

Original physical or electronic copies. Electronic must be accessible and unalterable.

CBP audit access

CBP can request records during the retention period. Failure to produce supports negligence finding.

Frequently asked questions

When is this most relevant?

For SMB importers facing audit, refund opportunity, or compliance gap remediation.

What documentation matters?

CBP forms, supporting records, supplier certificates, and BOM analysis as applicable.

What is the timeline?

Simple matters 2-4 weeks; complex audits or refund filings 3-12 months.

What does this cost?

Project scope $5,000-$45,000 depending on complexity. Refund work often on contingency.

How do I begin?

Book a 15-minute scoping call. We confirm fit before any engagement.

Get started

Already received an audit notice? Contact us within 48 hours.

About the author

Kyle Peacock is the Principal of Peacock Tariff Consulting, an independent tariff and customs advisory firm serving SMB importers across the U.S., Canada, the U.K., and the E.U. He has been quoted in Forbes, CNN, The Washington Post, BBC, CBC, CTV, Financial Post, Nasdaq, Supply Chain Brain, and Harvard Business School publications. Connect on LinkedIn.