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Customs and forwarding documents: retention and destruction

Customs and forwarding documents retention and destruction with a certificate

Anyone who imports, exports or forwards goods builds up a thick file. Import declarations, EUR.1 certificates, commercial invoices, packing lists, T1 documents and bills of lading pile up per shipment. You must keep those documents for years, as a rule seven years under the Union Customs Code. Only once the period has passed may it go, and then confidential destruction with a certificate belongs with it.

Want to check quickly whether you have this in order? Can you answer yes to each of these?

  • Do you know from which year your oldest customs declarations are?
  • Have you recorded the retention period per document type?
  • Do you keep the documents so an AEO inspection finds them quickly?
  • Are expired files destroyed confidentially instead of going to the waste paper?
  • Do you receive a certificate of that destruction?

If you hesitate on any of these, the sections below show which paperwork you may clear out and when, and how to do it safely.

What are customs and forwarding documents?

Customs and forwarding documents are the paper and digital records that accompany a shipment from departure to delivery, plus everything customs wants to be able to check about that shipment. It covers the declaration itself, supporting documents for that declaration such as invoices and origin certificates, and transport documents such as the bill of lading. For a forwarder or customs agent they together form the proof that a shipment was lawfully imported or exported, that the right duties were paid and that the origin is correct. That is precisely why customs looks at them first in an inspection.

The import and export declaration

The import declaration and the export declaration are the heart of the file. In the Netherlands they run through the customs systems, with an MRN as the reference. The declaration records what was imported or exported, under which commodity code, at which value and with which duties and levies. In a later inspection customs wants to be able to link the declaration to the underlying invoice and the transport proof. A declaration without supporting documents is weak, a complete file with declaration, invoice and origin proof is conclusive. So always keep the declaration together with the documents that belong with it.

Origin certificates and EUR.1

A EUR.1 certificate, a Form A or an origin declaration on the invoice proves where goods come from. That determines whether a reduced or zero tariff applies under a trade agreement. For the buyer such a certificate is worth money, because it saves import duties. For customs it is a checkpoint, because an unjustified origin benefit can be recovered years later. So you keep origin proofs as long as the declaration they belong with. If such a certificate goes missing, you cannot substantiate the benefit in an inspection and an additional assessment follows after all.

The commercial invoice and the packing list

The commercial invoice shows the value of the goods and is the basis for the customs value on which duties are calculated. The packing list describes the physical contents per package, with quantities, weights and dimensions. Together they connect the declaration to the actual shipment. These documents are doubly relevant, because they count for customs and for your own tax records. An invoice still relevant for customs often still falls under the tax retention obligation too. So it makes sense to keep both flows for the same length of time.

T1, T2 and transit documents

Goods that travel through the Union under customs supervision are accompanied by a transit document. A T1 accompanies non-Union goods, a T2 accompanies Union goods travelling via a third country. The transit document shows that the goods were carried under suspension of duties and were correctly presented at the destination. The discharge of the transit, the proof that the shipment arrived, is a sensitive point. If a transit stays open, customs can still claim the duties from whoever had the document in their name. So keep transit documents carefully together with the proof of discharge.

The bill of lading and other transport documents

The bill of lading is the transport document for sea freight and represents the goods themselves. Whoever holds the original is entitled to the cargo. Alongside it there are the air waybill and the CMR for road transport. These documents prove the carriage and link the physical shipment to the declaration. What the CMR exactly involves and how long you keep it is covered in the sister article on the CMR waybill. For the customs file what mainly counts is that the transport proof matches the declaration and the invoice, so the chain is right from start to finish.

AEO records and authorisations

Whoever holds Authorised Economic Operator status, or works with authorisations such as a simplified declaration or a customs warehouse, also builds up an authorisation administration. It holds procedures, audits, stock records and the correspondence with customs. Customs expects you to have that administration in order and to be able to produce it for years. An AEO status stands or falls with demonstrable management, including of old files. A messy archive where nothing can be found undermines the trust that underlies the status. Order in the archive is here not a side issue but an authorisation condition.

The customs retention obligation: often seven years

The Union Customs Code requires you to keep the documents for a customs declaration so customs can check them. In the Netherlands that comes down in practice to seven years, counted from the end of the calendar year in which the declaration was made. Those seven years align with the tax retention obligation, which keeps the management simple. So the whole file around a shipment follows the same line, from declaration to invoice and origin proof. You therefore do not need to track a different period per document, but can keep the file as a whole for seven years.

Why sometimes longer than seven years applies

Seven years is the main rule, not an iron law. In a number of cases you keep longer. If an objection, a recovery or a court case about a declaration is running, you hold the file until that procedure is fully concluded. With an ongoing authorisation or a customs warehouse, customs can ask you to keep the underlying documents available for as long as the authorisation runs. Capital goods with a long review period can also be a reason to keep longer. The rule of thumb is simple. If there is still a chance that someone asks for the document, you do not destroy it.

Retention periods per document type

The following table lists the common periods. The tax and customs periods usually run in parallel, so the longest period is leading for the whole file.

Document typeWhat it isRetention period
Import and export declarationCustoms declaration with MRN7 years
EUR.1 and origin certificateProof of origin for the tariff7 years
Commercial invoiceBasis for the customs value7 years (also tax)
Packing listContents per package7 years
T1 and T2 transit documentGoods under customs supervision7 years after discharge
Bill of lading / air waybillTransport proof sea or air freight7 years
AEO and authorisation recordsProcedures and auditsAuthorisation term plus 7 years
File with ongoing disputeDeclaration under objection or appealUntil end of procedure
The seven years apply from the end of the year of the declaration. A declaration from March 2019 may therefore only be destroyed after 31 December 2026.

Commercial and some personal data in these documents

Customs and forwarding paperwork revolves around commercial data, but also contains personal data. Declarations and invoices carry names of contacts, email addresses, telephone numbers, signatures and EORI numbers. Transport documents carry names and addresses of consignor and consignee, sometimes a driver's data. With that, the GDPR applies alongside the customs rules. You keep these documents no longer than needed and you destroy them afterwards in an appropriate way. A general explanation of careful clearing-out is in the overview on data destruction. For customs files it mainly means that old paper does not belong with the ordinary waste.

The tax retention obligation runs in parallel

Most customs documents are at the same time part of your bookkeeping. A commercial invoice counts for the customs value and for the VAT, a declaration ties in with the purchase and sales records. As a result much customs paper also falls under the seven-year tax retention obligation. Those two periods rarely clash, they reinforce each other. In practice keep the longest period, then you are right for both. How the tax side works exactly is in the 7-year tax retention obligation. A file that meets the tax period usually also meets the customs requirement.

First keep, then destroy

Clearing out starts with knowing what may go. Go through the files per calendar year and determine which are past their period. Set aside documents with an ongoing dispute or an active authorisation, because you keep those longer. What remains may be destroyed confidentially. A fixed rhythm works best. Many forwarders clear out yearly after the year-end close, in the same period as the tax check. That way the archive does not grow endlessly and the overview is kept. You then destroy precisely the year that has just fallen outside the period and leave the rest standing.

Confidential destruction after the period

Once the period has passed, these files do not belong in the paper bin. They contain commercial and personal data that competitors and bad actors would love to see. Confidential destruction means the paper is collected sealed and shredded at an appropriate DIN level, with a certificate as proof. We work with a collection service within 20 km of Amsterdam, without you having to come by yourself. Outside that area we pool runs nationwide via group deals, so you keep a fixed price. You hand nothing in at a counter, we come to collect it. What the complete route for a transport archive involves is in the pillar on logistics and transport.

Sealed collection and the chain of custody

The security begins at collection. The paper goes along in a closed unit and stays sealed until the moment of destruction. As a result there is no moment where a file can lie around on the street or on a loading dock. That closed chain is called the chain of custody. For customs files that matters extra, because a EUR.1 or a commercial invoice that disappears on the way is not only a data breach but also a gap in your customs records. A sealed collection rules out that risk and makes the proof afterwards stronger.

The right DIN level

The DIN 66399 standard sets out how finely it is shredded. For customs and forwarding paper with commercial and personal data, P-4 is the standard. If it contains special or highly sensitive data, you choose P-5.

LevelParticle sizeSuitable for
P-2StripsGeneral print without data
P-4Small particlesCustoms paper with business and personal data
P-5Very small particlesSpecial and highly sensitive data

The certificate states the applied level, so you can show it was appropriate to the sensitivity of the contents.

The certificate of destruction

After destruction you receive a certificate with the date, the quantity and the applied DIN level. That is your proof that the files were made illegible. Keep it with your customs and GDPR records, preferably digitally so you find it quickly in an inspection. If a question comes from customs or an audit for your AEO status, the certificate shows that the clearing-out was done neatly. What such a document looks like and what belongs on it is in the certificate of destruction explained. Without that paper it remains your word, with a certificate you have proof.

What does destruction cost?

You pay a fixed price per box or roll container, from about 30 euro for the first box. The certificate is included. Within 20 km of Amsterdam we charge no call-out fee. Outside it a fixed price applies via nationwide group deals, where runs in a region are pooled. That way a large yearly clear-out stays affordable and you know in advance where you stand. The full pricing, including for larger archives, is in archive destruction cost. Data carriers such as old scanners or hard drives from your customs system can come in the same collection, each destroyed at the right level.

Digital customs files

Many declarations now run digitally, but that does not remove the paper. Attachments, original certificates and signed transport documents often still exist physically. Alongside that, copies sit on servers, laptops and back-ups. For the digital side the same thought applies. What is past its period and no longer needed, you clear out, including on the data carrier. When equipment from your customs or TMS environment is replaced, the old drives should be destroyed, with serial numbers on the certificate. That way you cover the whole flow, on paper and digital, and no forgotten copy is left behind anywhere.

Cleared out in 4 steps

  1. Inventory per calendar year which customs files are past their period.
  2. Set aside exceptions, such as ongoing disputes and active authorisations.
  3. Have it collected sealed and destroyed at DIN P-4 or P-5.
  4. Keep the certificate with your customs and GDPR records.

Common mistakes

  • Destroying too early. Count the seven years from the end of the year of the declaration, not from the declaration date itself.
  • Losing the origin proof. Without a EUR.1 you cannot substantiate a tariff benefit in an inspection.
  • Into the waste paper. Declarations and invoices belong with confidential destruction, not in the open paper bin.
  • Not asking for a certificate. Without proof you cannot show the destruction in an audit.

Have an expired customs archive destroyed confidentially?

Tell us how many boxes or roll containers you have and you get a fixed price. We collect it sealed, destroy it at DIN P-4 or P-5 and you receive a certificate for your customs and GDPR records. No call-out fee within 20 km of Amsterdam.

Request a quote

Frequently asked questions

How long must I keep customs documents?

Customs retention is as a rule 7 years, counted from the end of the year of the declaration. Under the Union Customs Code a longer period can apply for ongoing authorisations or disputes.

Which documents fall under the customs retention obligation?

Import and export declarations, EUR.1 and origin certificates, commercial invoices, packing lists, T1 and transit documents, bills of lading and the related AEO records and authorisations.

Is there personal data in customs paperwork?

Yes. Besides commercial data there are names of contacts, EORI numbers, signatures and sometimes driver and consignee data. So the GDPR applies alongside the customs rules.

How do I destroy expired customs documents?

Have them collected sealed and shredded at DIN P-4 or P-5, with a certificate of destruction as proof. That closes the file demonstrably.

Conclusion

Customs and forwarding documents are the proof behind every shipment, and that is precisely why you keep them for a long time. As a rule seven years under the Union Customs Code, sometimes longer with an ongoing dispute or an active authorisation. Because the documents contain commercial and personal data, they do not belong with the waste paper afterwards but with a confidential destruction. Have them collected sealed, destroy at the right DIN level and keep the certificate. That way you meet the customs requirement, the tax retention obligation and the GDPR, with an archive that is right at every inspection.

See also the pillar on logistics and transport, plus the sister articles on the CMR waybill explained and its retention, destroying transport documents after retention and driver data and the GDPR in the fleet.


Customs archive due for a clear-out? Request a quote via desnipperaar.nl. You receive a certificate as proof for your customs and GDPR records.