How Long Must Customs Records Be Kept? The Five-Year Rule and Its Exceptions
Short answer
Under 19 CFR 163.4, general customs records are retained for five years from entry, or from the activity creating a non-entry record. Specific exceptions cover drawback claims, packing lists, certain informal entries and qualifying duty-free records. Other rules can control. Customs brokers also have separate retention obligations under 19 CFR 111.23.
What are the customs record retention periods?
| Record type | Retention period | Authority |
|---|---|---|
| General entry records | 5 years from date of entry | 19 CFR 163.4(a) |
| Records not tied to an entry | 5 years from the activity | 19 CFR 163.4(a) |
| Drawback claims | Until the 3rd anniversary of payment of the claim | 19 CFR 163.4(b)(1) |
| Packing lists | 60 calendar days from the later release/conditional release endpoint; special rule on demand for redelivery | 19 CFR 163.4(b)(2) |
| Informal entry, non-owner consignee with broker | 2 years from date of informal entry | 19 CFR 163.4(b)(3) |
| Records for qualifying duty-free admissions under the cited rule | 2 years from entry or the relevant activity | 19 CFR 163.4(b)(4) |
The packing list exception surprises people. It is far shorter than the general rule, and it only applies to the packing list itself — the entry it supports is still a five-year record.
What counts as a record?
The obligation is broader than the filing itself. It covers the documents, data and information that support the entry: commercial invoices, bills of lading, packing lists, purchase orders, payment records, correspondence with suppliers and brokers, classification research, and anything else relied on in making the entry.
Format is not the test. An email thread establishing the terms of sale is a record. So is a spreadsheet used to calculate entered value.
Do customs brokers have separate obligations?
Yes. 19 CFR 111.23 governs customs-broker record retention, generally at least five years after entry, with separate rules for powers of attorney and warehouse withdrawals. A broker holding records on behalf of an importer does not relieve the importer of its own obligation.
Why must general entry records be kept for five years?
The five-year requirement comes directly from 19 CFR 163.4(a). Specific exceptions are in subsection (b), and subsection (b)(5) gives controlling effect to another regulation prescribing a different period for a particular record.
This is why a records request arriving four years after an entry is not unusual, and why "we changed systems" is not an answer CBP accepts.
For the document workflow described here, see Searchable document history.
The packing-list exception has a separate redelivery rule when CBP demands return to custody. This retention table describes the cited regulation; it does not establish current eligibility for duty-free admission. Confirm which rules apply to the transaction before deleting records.
Which primary sources support this article?
- 19 CFR 163.4 — record retention periods and exceptions
- 19 CFR 163.2 — persons required to keep records
- 19 CFR 111.23 — customs-broker retention duties
This guide is general information, not legal advice. Check current requirements with your customs broker or qualified counsel for your shipment.