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

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!

Topic(s)

Acts & Regulations
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
Disclaimer

The foregoing information is provided for informational purposes only and is not intended as, nor should it be considered, professional advice or a substitute for conducting your own thorough research and review. Before making any decisions or taking any action based on the information provided, you should conduct your own independent investigation and/or seek professional advice from a qualified expert in the relevant field. The CSCB disclaims all liability for actions taken or not taken based on the information provided.