Logistics and transport: consignment notes, CMR and archive destruction
A transport company produces a paper flow per trip: CMR consignment notes, pallet slips, return slips, customs documents, cargo manifests. On top of that it keeps driver files, lease records for trucks, ADR permits, tachograph data. The regime is a mix of fiscal, civil law, CMR and GDPR. This article lays out the retention periods.
The relevant regimes
- AWR / tax: 7 years for administration.
- CMR (road transport convention): 1 year for complaints about a shipment; extended to 3 years for gross negligence.
- Customs conventions: 7 years for customs documents (DGV/AGS).
- ADR (dangerous goods): 5 years for incident records.
- Tachograph data: at least 1 year (EU Regulation 165/2014), Dutch practice often 2 years.
- GDPR: driver files and customer records under the general periods.
Retention periods per category
| Category | Period |
|---|---|
| CMR consignment note | 1 year (CMR), 7 years (tax) |
| Delivery and return slip | 5 years |
| Customs declaration (T1, T2, EUR.1) | 7 years |
| ADR permit per shipment | 5 years |
| Tachograph data | 1 year (EU), 2 years (NL practice) |
| Driver file (driving hours) | 2 years |
| Customer and order records | 7 years (tax) |
| Lease records for trucks | 7 years after end of lease |
| Camera footage of loading/unloading | 4 weeks |
The longest tax period (7 years) generally drives paper archive retention; the 1-year CMR liability period is rarely used on its own to shorten anything.
Specific points of attention
Driver personal data
- Driving licence copy and BSN: necessary for payroll, so retention 5 years after leaving employment.
- Tachograph data is personal data; one file per driver.
- Complaints about a driver: 2 years after handling.
Customer data (shipper and consignee)
- Name and address of the consignee on the CMR is personal data.
- Retention follows the 7-year tax rule.
- After that, actively delete.
Customs documents
Separate track; often organised in a dedicated folder. Retention 7 years required under the UCC (Union Customs Code).
The practical clean-up
- Inventory per calendar year: how many cabinets, how many boxes.
- Identify documents older than 7 years: anything covered by tax rules.
- Identify documents older than 5 years for ADR and delivery slips.
- Schedule mobile destruction on site.
- Destroy at DIN P-4 or P-5.
For a wider clean-up workflow, read how to organise an archive clean-up day.
Hardware in transport
- On-board computers and GPS systems: data on routes and driver. Destroy on replacement.
- Tablets in the cab: apps with customer correspondence and route data. Read destroying smartphones and tablets.
- Central systems: TMS (Transport Management System) servers on replacement.
- Camera footage from trucks or loading yards: read camera footage retention.
For freight forwarders and logistics service providers
Forwarders have a broader paper flow because of the variety of transport and customs documents. Good practice: an annual clean-up after the year-end close, in step with the invoice review.
Mobile destruction at the transport site.
We come to your terminal or office. Destruction at DIN P-4 or P-5 with a certificate that fits your financial and CMR records.
Request a quoteTransport archive ready for a clean-up? Email us via desnipperaar.nl.