# How long must DTC importers keep customs records? | LandEdgeHQ

Source: https://landedgehq.com/blog/2026-10-15-customs-recordkeeping-five-year-rule-dtc-importers/

Cross-border operations guide · October 15, 2026


US customs law requires importers to keep entry records for five years, and the list of what counts as a record is wider than most DTC brands expect. The brands that survive audits are the ones whose records are findable, not just kept.

## The five year rule and what it covers

Section 1508 of Title 19 sets the duty: anyone importing merchandise must keep the records Customs requires and produce them on demand. The regulatory list, known as the (a)(1)(A) list, names the documents: entry filings, invoices, purchase orders, contracts, payment records, receiving and inventory records, and correspondence about the importation.

The clock generally runs five years from the date of entry. Drawback records run from liquidation of the claim, and some records tied to other programs carry their own timing. Brands that delete supplier chats, old email, and accounting exports on a consumer style retention schedule are often destroying customs records without knowing they were customs records.

## The records brands forget they need

The filing itself is the easy part; brokers keep copies. The gaps appear in the evidence behind the filing: the email where a supplier confirmed a material, the spreadsheet where value was built up, the chat where an assist was discussed, the spec sheet that justified a classification. In an audit, those documents are the difference between a position and a guess.

Payment proof matters more than brands expect. Customs tests declared value against what was actually paid, so bank records, payment platform exports, and credit notes must reconcile to the invoices on file. A value that matches the invoice but not the money is a finding waiting for an auditor to schedule it.

## Findable beats merely kept

Records scattered across a founder's inbox, a broker portal, a shared drive, and an accounting app are technically kept and practically lost. An audit request comes with a deadline, and a team that cannot assemble a complete entry file in days looks like a team without reasonable care, even if every document eventually surfaces.

Build one entry file per shipment or per entry number with a fixed checklist: entry summary, invoice, packing list, transport document, payment proof, classification note, and origin evidence. Store it in one system with access that survives staff changes. The checklist takes minutes at import time and saves weeks under audit pressure.

## Brokers, platforms, and shared responsibility

Using a broker does not transfer the recordkeeping duty. The importer of record owns it, even when the broker holds the only copies in their portal. Brands should have contractual access to their complete entry data and export it on a schedule, because changing brokers is common and portal access has a way of ending exactly when old records are needed.

The same logic applies to marketplaces and 3PLs that act in the import chain. Know who is importer of record for each flow, whose name sits on the entry, and where that flow's records live. In a multi channel business the answer differs by channel, and assuming one answer covers all of them is a common audit surprise.

## A retention routine that runs itself

Set the retention policy in writing: five years minimum for the full (a)(1)(A) list, longer where drawback, litigation, or an open audit touches the entries. Tie deletion schedules in email, chat, and accounting tools to that policy so a platform cleanup cannot quietly undercut it.

Once a year, run a mock request. Pick three old entries at random and time how long a complete file takes to assemble. If the answer is more than a day, the system needs work while there is no auditor waiting. Recordkeeping is the cheapest compliance insurance an importer buys, and the mock drill is its annual premium check.

Keep reading: [What is a CBP binding ruling letter, and when should a DTC brand ask for one?](https://landedgehq.com/blog/2026-10-15-cbp-binding-ruling-letter-dtc-brands), [What is a CBP liquidated damages claim, and how do importers mitigate it?](https://landedgehq.com/blog/2026-10-14-cbp-liquidated-damages-claims-mitigation), and [Post summary correction vs CBP protest: which one fixes your entry?](https://landedgehq.com/blog/2026-10-13-post-summary-correction-vs-cbp-protest) cover the nearby cases in this series.

## Frequently asked questions

## How long must import records be kept in the US?

Five years from the date of entry for the standard (a)(1)(A) list records, with drawback records kept five years from liquidation of the claim. Some situations call for longer, so five years is a floor, not a target.

## Does my broker keeping records satisfy the requirement?

Not by itself. The duty belongs to the importer of record. You need guaranteed access and your own complete copies, because broker changes and portal limits can cut off access when records are needed.

## What records do brands most often fail to keep?

The evidence behind the filing: supplier correspondence, classification and valuation workpapers, spec sheets, and payment proof that reconciles to the declared value. The entry forms themselves are rarely the gap.

## What happens if records cannot be produced in an audit?

Missing records undermine reasonable care, can lead Customs to draw adverse conclusions about classification and value, and may add recordkeeping penalties on top of any duty owed.