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Destroying transport documents after retention: CMR, waybills and tachograph

Destroying transport documents after retention

A carrier or forwarder gathers a thick stack of paper on every trip. CMR waybills, packing lists, delivery notes, tachograph records, fuel and toll receipts and ADR documents. Much of it you must keep for years, but once the period has passed it should be destroyed confidentially. Those documents carry personal data of drivers, clients and consignees.

Want to check quickly whether your transport archive is in order? Can you answer yes to each of these?

  • Do you know per document type how long you must keep it?
  • Do you have boxes of waybills older than seven years?
  • Do your old transport documents go confidentially and not in the ordinary paper bin?
  • Do you receive a certificate of destruction for your administration?
  • Do you have a fixed moment in the year when you clear out the archive?

If you hesitate on any of these, the sections below show which documents a transport business holds, how long each type must be kept and how to have everything destroyed confidentially after the period.

Which documents does a carrier or forwarder hold?

The paper flow in transport and logistics is large and varied. Per shipment several documents arise quickly: a CMR waybill for international road transport, a domestic waybill, a packing list, a delivery note with signature and sometimes a return note. On top of that comes the administration around the vehicle and the driver. Think of tachograph records, driving and rest time logs, fuel and toll receipts and ADR papers for dangerous goods. Forwarders add customs and forwarding documents to this. All those documents end up in a binder or box, where they sit for years. Whoever wants to keep an overview first looks at the broader framework in logistics and transport: waybills, CMR and archive.

Why transport paper must be destroyed confidentially

Many entrepreneurs think waybills and receipts are just old paper. That is not correct. A CMR carries the name and address of the consignee, often with a signature for receipt. Delivery notes carry signatures of clients. Tachograph records and driving and rest times are directly traceable to an individual driver. Those are all personal data within the meaning of the GDPR. So this paper does not belong in the open paper bin standing on the street for days, but in a closed destruction route. An abandoned waybill is a data breach in the making. More on the approach to personal data is in the overview of data destruction.

First the retention period, then destruction

Destruction starts with knowing what may go. Some transport documents you are required to keep, because they are part of your administration. The tax authority requires the core administration to be kept for seven years. A waybill is, for tax, the substantiation of a transaction, so it falls under that period. Only once the seven years have passed may the document go. For other types their own periods apply, sometimes shorter, sometimes tied to a regulation. So always check per category what the period is before you throw anything away. The background to the seven-year rule is in the 7-year tax retention obligation.

Retention periods per document type

The following table sets out the common periods. The tax period of seven years is in practice often leading, because it is the longest and the document therefore stays in the cabinet anyway.

Document typeRetention periodBasis
CMR waybill7 yearsTax (1 year CMR liability)
Domestic waybill7 yearsTax
Packing list7 yearsTax
Delivery note with signature7 yearsTax and proof of delivery
Tachograph records1 year (EU), 2 years NL practiceRegulation EU 165/2014
Driving and rest time logs2 yearsWorking time rules
Fuel and toll receipts7 yearsTax
ADR documents per shipment5 yearsDangerous goods rules
Customs and forwarding documents7 yearsUnion Customs Code
Driver file (payroll)7 years after leavingTax and payroll administration

CMR waybills and the tax period

The CMR waybill is the best-known transport document, but also the most confusing on its period. The CMR convention has a liability period of one year for complaints about a shipment. That does not mean you may throw the waybill away after a year. For tax, the waybill is a piece of evidence with the invoice, so it stays under the seven-year rule. In practice you therefore keep the CMR for seven years and destroy it only afterwards. What a CMR waybill exactly is can be read in the explainer on the CMR waybill explained and its retention. Because the consignee with signature is on the waybill, it goes confidentially after the period.

Waybills, packing lists and delivery notes

Besides the CMR, domestic transport has the ordinary waybill, the packing list and the delivery note. These documents substantiate what was transported and to whom it was delivered. For tax they fall under the same seven-year rule as the rest of the administration. The delivery note is particularly sensitive, because it often carries a signature of the recipient as proof of delivery. A signature with a name is a personal data item. A stack of old delivery notes that simply ends up with the waste paper therefore forms a real risk. Bundle these documents per year and hand them over after seven years for confidential destruction.

Tachograph records and driving and rest times

The tachograph records when a driver drives and rests. Those records are directly traceable to a person, so they are personal data. The European regulation 165/2014 requires retention of at least one year. In Dutch practice many companies keep two years, partly because of the checks on working and rest times. If you print the records or keep trip logs on paper, a paper flow arises that must go confidentially after the period. Never throw tachograph prints away just like that, because they show precisely where a driver was and when. That is sensitive information for both the driver and your client.

Fuel and toll records

Fuel receipts, fuel card overviews and toll records belong to the cost administration of the fleet. For tax they fall under the seven-year rule. At first glance they look like neutral receipts, but combined with a number plate and a driver they tell where a vehicle has been and when. That makes these documents traceable to a person too. After seven years they lose their tax value and may go. Because they sit among the other financial documents, it is practical to take them in the same yearly clear-out as the rest of the transport archive.

ADR documents for dangerous goods

If you transport dangerous goods, ADR documents arise per shipment, plus the accompanying instructions and logs. The rules for dangerous goods generally require retention of five years for the shipment administration. These documents contain data about the load, the route and the driver involved. After the period of five years they may go, provided there is no tax reason to keep them longer. Keep ADR documents separate in your archive, so that at the yearly clear-out you quickly see which set is past its period. These documents also go confidentially.

Customs and forwarding documents

Forwarders and international carriers have an extra layer of paper: customs declarations, transit documents and certificates of origin. Under the Union Customs Code a retention period of seven years applies to customs documents. These documents contain business and personal data of sender and consignee. Keep them in a separate folder, because the process runs apart from the ordinary freight administration. How you keep and clear out this category after the period can be read in the article on customs and forwarding documents retention and destruction. After seven years they go in the same confidential collection as the rest.

Personal data of drivers on the documents

A common thread through all these documents is the driver. Their name is on waybills, their signature on delivery notes, their driving and rest times in the tachograph and sometimes a copy of their driving licence in the personnel file. A driving licence copy can contain an ID number, which is particularly sensitive. As a result the whole transport archive is saturated with personal data, even when at first glance it concerns dry receipts. That makes confidential destruction after the period not a luxury but an obligation. How you handle this data in the fleet is in the article on driver data and the GDPR in the fleet.

How do you have transport documents destroyed confidentially?

Once the period has passed, the paper goes in a closed route. We collect it sealed at your terminal or office and destroy it at the right DIN level. The chain from collection to destruction stays closed, so there is no moment where a waybill goes missing. Collection happens within 20 km of Amsterdam without a call-out fee. Beyond that we work nationwide with pooled collection rounds at a fixed price, so a transport business further away can also be served. We only come by appointment and have no walk-in. So you are sure your archive does not end up at an open container but in a controlled destruction.

The right DIN level for transport paper

How finely it is shredded is set by the DIN 66399 standard. For transport documents with personal data, P-4 is the starting point. If an ID number is on a driving licence copy or it concerns special data, P-5 is appropriate.

LevelParticle sizeSuitable for
P-2StripsGeneral print without data
P-4Small particlesWaybills, receipts and tachograph prints
P-5Very small particlesID numbers on driving licence copies and special data

The applied level appears on the certificate, so you can show it was appropriate to the sensitivity of the documents.

The certificate as proof

After destruction you receive a certificate of destruction. On it are the date, the quantity and the applied DIN level. That document is your proof that the transport administration was cleared out neatly after the retention period. At a tax inspection or a question from a client you can immediately show what happened. Keep the certificate digitally with your record of processing, so you find it quickly. What exactly should be on such a certificate can be read in the explainer on the certificate of destruction. Destroying a waybill without proof leaves a gap in your administration.

What does destroying a transport archive cost?

You pay a fixed price per box or roll container, from about 30 euro for the first box. The certificate is included. If you have data carriers such as old on-board computers or a written-off server from the transport management system, we settle those per item, with serial-number registration. Within 20 km of Amsterdam there is no call-out fee. The full pricing and a worked example for a larger archive are in the article on archive destruction cost. For a transport business with years of waybills it stays clear what a clear-out costs.

A fixed yearly clear-out

It works most pleasantly if you tie the clearing-out to a fixed moment in the year, for example after the year-end close. You then assess which boxes are past their period, hand those over in a collection and archive the certificate. So year after year you build a clean line of evidence and the archive does not grow endlessly. For a forwarder with much customs paper it pays to let this coincide with the declaration check. A fixed round prevents old waybills from sitting for years in an attic or in a sea container on the yard.

Practical tips

  • Bundle per calendar year so you see at a glance which boxes are past their period.
  • Keep customs paper separate from the ordinary freight administration.
  • Never throw tachograph prints away loose, because they are personal data.
  • Always ask for a certificate with date and DIN level.
  • Plan a fixed yearly round after the year-end close.

Clear out your transport archive in 4 steps

  1. Inventory per year how many boxes and which document types you have.
  2. Determine the period per category and set apart what is older than seven years.
  3. Have it collected sealed and destroyed at DIN P-4 or P-5.
  4. Keep the certificate with your record of processing.

Common mistakes

  • Throwing CMR away after a year. For tax the waybill stays under the seven-year obligation.
  • Receipts in the open paper bin. With signatures and names that is a data breach in the making.
  • No proof. Without a certificate you cannot show the archive was cleared out.
  • Keeping endlessly. Keeping longer than needed conflicts with storage limitation.

Have your transport archive destroyed with a certificate?

Tell us what you have and you get a fixed price. We collect it sealed, destroy it at the right DIN level and you receive a certificate matching your tax and CMR administration. No call-out fee within 20 km of Amsterdam.

Request a quote

Frequently asked questions

How long must I keep CMR waybills?

The CMR liability period is 1 year, but for tax the waybill falls under the 7-year retention obligation. So keep it for 7 years and destroy it confidentially afterwards.

Can transport documents go in the ordinary paper bin?

No. CMR waybills, delivery notes and tachograph records carry personal data of drivers and consignees, so confidential destruction is needed rather than the open paper bin.

At which DIN level are transport documents destroyed?

Documents with personal data go at DIN P-4. For ID numbers on driving licence copies or special data, P-5 is appropriate.

Do I receive a certificate of destruction?

Yes. Per collection you receive a certificate with the date, quantity and DIN level, matching your tax and CMR administration.

Conclusion

A transport business runs on paper full of personal data, from waybills and delivery notes to tachograph prints and customs declarations. Most documents stay for seven years because of the tax obligation, while tachograph records and ADR papers have their own periods. Once the period has passed, the paper does not go in the open bin but in a closed destruction route, at DIN P-4 or P-5, with a certificate as proof. Tie the clearing-out to a fixed moment in the year and you keep your archive small and your administration demonstrably in order.


See also: dig into logistics and transport: waybills, CMR and archive, into the CMR waybill explained and its retention, into driver data and the GDPR in the fleet and into customs and forwarding documents retention and destruction.


Transport archive ready for a clear-out? Request a quote via desnipperaar.nl. You receive a certificate as proof.

Related sector guides: Taxi companies: destroying ride and passenger data.

Related guides: Courier services: destroying delivery data.