If you sell into Canada from overseas and ship inventory to Amazon's warehouses, there is a compliance rule that almost nobody warns you about until it is a problem: the CBSA expects your import records to be kept in Canada, and it can fine you up to $25,000 if they are not there when it asks.
The rule in plain terms
Canada's customs agency requires every importer to keep detailed import records for six years: invoices, shipping documents, proof that duties and taxes were paid, origin paperwork, permits. That applies to Canadian businesses and to foreign sellers equally. The wrinkle is that the law says those records are supposed to be kept at your place of business in Canada, and as an overseas seller, you do not have one.
What that means if you are a non-resident importer
If you are the importer of record but have no physical presence in Canada, you are a non-resident importer, which describes a huge number of Amazon and ecommerce sellers shipping into the country. The CBSA's answer to the "no office in Canada" problem is that you have to designate a Canadian agent, usually a customs broker or an accountant, to hold your records, and get that arrangement officially approved by filing form BSF900 through the CARM portal.
This is not optional, and the timing matters. Since May 2024, new importer accounts are not even issued until you have an approved records-maintenance arrangement in place. So this is something to sort out before you start importing, not after.
Why the penalty is not theoretical
The CBSA does run trade-compliance audits. If your records are not accessible in Canada through your designated agent, the fines under the penalty system run up to $25,000 per audit, and repeated failures escalate. For a small seller, that is the kind of number that ends the Canadian experiment entirely. Beyond the money, it can flag you for more inspections and shipment delays.
The catch with the easy option
The obvious move is to let your customs broker hold the records, since they already handle your paperwork. The problem is that many brokers only offer this if you clear all your shipments through them. That locks you into one provider, so if their rates climb or you outgrow them, switching brokers can put your record-keeping arrangement at risk. An accountant or another approved agent can hold the records instead, which keeps you free to shop your shipping around.
What to actually do
If you are importing into Canada from abroad, confirm two things: that you have a designated Canadian records agent approved through BSF900, and that someone is reliably capturing the B3 entries and invoices for every shipment. If either is missing, fix it before your next inbound, not after a CBSA letter arrives.
We explain the six-year rule, the BSF900 process, and a record-storage service that does not tie you to one broker, in full on our firm's site: CBSA Record Keeping for Global Amazon Sellers.
Expanding into Canada from overseas and not sure what compliance you are missing? That is exactly what we help sellers untangle, and we share the plain-English version in the newsletter.