Memorandum D17-1-21, Maintenance of Records in Canada by Importers –Update

September 16, 2022

On August 18, 2022 we advised members of the new BSF900 form and of the updated D 17-1-21, Maintenance of Records in Canada by Importers on August 26, 2022. Further information has been obtained from the CBSA that members may find helpful.

  1. BSF900 is a requirement for all importers who maintain records at a location other than their place of business or keep them outside of Canada (USA or Mexico). This would also include Canadian importers who are maintaining their records at a location other than their place of business in Canada -  either in the USA, Mexico or elsewhere in Canada.

    CSCB note, in R2 of CARM any new portal registration of a non-resident importer or of a resident importer keeping their books and records at a place other than their place of business will require the BSF900 to be completed at the time of registration!

  1. The following is a list of items that may be requested during a verification (list is not exhaustive):
  • Canada Customs Coding Forms (B3);
  • B3 Recap Sheet (if applicable);
  • Purchase Order;
  • Commercial Invoice;
  • Import Permits (if applicable);
  • Proof of payment;
  • Bill of lading;
  • Freight invoice (if applicable);
  • Screen prints of the importer’s accounting entries for purchasing and payments;
  • Financial statements (audited if available);
  • Detailed adjusted trial balance;
  • List of foreign goods suppliers;
  • Organization chart, identifying the company structure including ownership, affiliates and divisions;
  • Reconciliation of the cost of goods sold (COGS) reported on the financial statements to the adjusted trial balance; identifying imported and non-imported goods;
  • Corporate T2 tax return including Schedule 125 - Income Statement, Schedule 9 Related and Associated Companies, and T106 Schedule of Related Party Transactions (when applicable); and
  • Narrative and/or flowchart documenting the flow of information for the entries.

The third party does not need to have the physical documents on site, but these should be made available, within a reasonable timeframe, upon request.

Our thanks to the member who shared these additional details!

Accessible to: 
Acts, Regulations, Policies & Decisions / Departmental Memoranda (D-memos) / CBSA Assessment and Revenue Management (CARM)
Information Source: 
Canada Border Services Agency (CBSA) / Canadian Society of Customs Brokers (CSCB) / Obtained by CSCB on behalf of members
Document Type: 
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