Customs clearance does not end the company’s record responsibility. During post-clearance audit, customs valuation consultation, duty refund or origin verification, the authority may require the exact documents and data relied upon when the declaration was registered. If Accounting holds the invoice, Technical holds the catalogue, Logistics keeps the B/L, Procurement retains the C/O email and only the broker has the supplementary declaration, the company may be unable to reconstruct the filing logic even though every item exists somewhere. The central risk is not one missing file; it is the inability to prove which version was used, which source was authoritative and why the data changed. This article sets out a shipment-file model comprising the statutory customs core, supporting evidence, change history and record-governance layer, and explains why the five-year customs period is not always the date on which every related document may be destroyed.

Operational reference for Importers, Exporters, Customs, Compliance, Accounting and Logistics | Updated 20 July 2026

QUICK FACTS

ONE SHIPMENT – ONE CONTROLLED FILE

Assign a unique shipment file ID linked to each customs declaration number and registration date, transport document, PO, container and SKU mapping.

RETAIN THE EXACT DECLARATION SNAPSHOT

Keep the actual document versions submitted, transmitted or relied upon at filing, together with amendments, explanations and approvals. Do not overwrite them with a later “latest version”.

FIVE YEARS IS THE CUSTOMS-RECORD PERIOD

Cleared-goods customs records are retained for five years from declaration registration unless otherwise provided; accounting books and related evidence follow their applicable retention laws.

A DECLARATION AND INVOICE ARE NOT ENOUGH

The file should allow the business to reconstruct classification, value, origin, quantity, customs regime, permits, transport and the history of changes.

Illustration for How Should Customs Records Be Retained for Each Shipment? — Illustration of the logistics topic, document or operation discussed in the article.

SCOPE

Applicable to importers, exporters, EPEs, manufacturers, traders and customs service providers managing sea, air, road or rail shipments. It is particularly relevant to machinery, electrical/electronic equipment, components, multi-SKU goods, preferential origin claims, complex valuation and sector-controlled goods.

Boundary: A shipment file is an internal governance model. The actual statutory document set depends on the customs regime, goods, declaration date and laws then in force.

KEY TERMS

TERM	MEANING	OPERATIONAL ROLE
Shipment File	The controlled set of documents and data for one shipment or a group of declarations linked to the same transaction.	Provides a complete retrieval unit across departments.
Customs Dossier	Documents forming the customs file under applicable rules and the actual declaration scenario.	The statutory core that must match filed data.
Supporting Evidence	Documents not always submitted with the declaration but used to support HS classification, customs value, origin, model or quantity.	Critical during consultation, post-clearance audit or inspection.
Audit Trail	History of who created, changed, reviewed, approved, transmitted and used each item.	Explains the basis of the declaration at the filing time.
Authoritative Copy	A copy issued by the competent party or officially recorded by the relevant system.	Distinguishes valid evidence from an unverified scan or internally edited file.
Retention Schedule	A register of start date, minimum period, legal basis and disposal conditions.	Prevents premature deletion where accounting, tax or sector rules require longer retention.

HOW SHIPMENT-BASED ARCHIVING WORKS

Shipment-based archiving is not simply placing all emails and files in one folder. The objective is to reconstruct the declaration decision: what information the company received, which version was used, who approved it, what data was transmitted and what changed before or after clearance.

1. STATUTORY CUSTOMS CORE

Keep the registered declaration and supplementary declarations; commercial invoice or equivalent document; transport document; permit, specialised inspection result, C/O, customs value declaration and other documents where applicable. Retain the version used at filing.

2. OPERATIONAL SUPPORTING EVIDENCE

Keep the contract, PO, packing list, catalogue/datasheet, label or nameplate photographs, HS classification memo, customs value calculation, freight and insurance evidence, payment documents, debit/credit notes, manufacturer statements, inspection records and warehouse receipt evidence.

3. CHANGE AND COMMUNICATION HISTORY

Retain amendment requests, before-and-after versions, approval emails, carrier or forwarder notices, customs communications and proof of transmission and receipt. This layer is often omitted but is decisive when the declaration must be explained.

4. RECORD GOVERNANCE

Each file should include an index, accountable owner, access permissions, retention start date, disposal review date, physical original location, electronic storage location and a Legal Hold status for audits, disputes or authority requests. Legal Hold is an internal disposal-suspension control, not a term defined by Vietnam’s Customs Law.

SEVEN RECORD GROUPS TO RETAIN

FILE GROUP	TYPICAL DOCUMENTS	COPY TO RETAIN	EVIDENTIARY PURPOSE	INTERNAL OWNER
Declaration and processing	Declaration, channel result, clearance/release, supplement, cancellation/amendment, system notice	System-recorded version; retrievable PDF/XML/receipt or equivalent	Proves filed data and processing status	Customs/Compliance
Commercial	Contract, PO, invoice, credit/debit note, payment terms	Issued version used for the shipment and all relevant amendments	Price, parties, transaction terms and payments	Procurement/Accounting
Technical goods evidence	Packing list, catalogue, datasheet, nameplate, photos, test report	Correct model, revision and scope for the imported goods	Description, model, function, material, quantity, HS and sector control	Technical/Customs
Transport	Booking, SI, B/L/AWB, manifest confirmation, arrival notice, D/O, EIR	Carrier/airline/forwarder-issued version and amendment history	Consignee, route, packages, weight, container and delivery milestones	Logistics
Origin and sector control	C/O, permit, inspection registration, result/certificate	Version used for preference or regulatory clearance	Preferential duty and import conditions	Customs/QA
Value and tax	Value worksheet, freight/insurance invoice, royalty, assists, tax payment	Approved calculation and original evidence	Customs value and tax basis	Customs/Finance
Changes and approvals	Change log, email, LOI, manufacturer statement, discrepancy record	Before/after chain, approver and effective time	Reconstructs why data changed	Document Owner

FILE INDEX: FIELDS TO LOCK

INDEX FIELD	RECORDING REQUIREMENT	WHY IT MATTERS
Shipment ID	Unique internal identifier, never reused	Links systems and departments
Declaration number + registration date	Record every declaration separately	Legal key and start of the five-year period
Direction/regime/customs office	Import/export, regime code and clearance location	Defines the applicable record scope
PO/Invoice/B/L/AWB	Number, date, issuer and revision	Links commercial and transport evidence
Container/SKU/model	List or mapping file	Supports traceability for multi-container and multi-model shipments
Clearance/release date	Status plus system evidence	Separates customs completion from physical delivery
Retention start/end	Declaration registration date, each applicable period and review date	Prevents early disposal or uncontrolled indefinite storage
Legal Hold	Status, reason, approver and release date	Suspends disposal for audit, refund, dispute or investigation

SHIPMENT FILE RETENTION PROCESS

Open the file at PO or booking stage: assign a Shipment ID and a minimum index; do not wait until clearance to collect documents.
Define shipment scope: map the Shipment ID to PO, invoice, B/L/AWB, containers, SKUs and every declaration. Use a mapping table where one shipment has multiple declarations.
Build the required-document matrix: determine documents based on regime, goods, sector policy, transport mode, C/O and customs valuation method.
Collect authoritative copies: retain issuer-produced or system-recorded documents; verify source and status of files received through chat or informal channels.
Create the filing-time snapshot: freeze the exact evidence set used to transmit the declaration and never overwrite it with later revisions.
Reconcile before file closure: compare the declaration with invoice, packing list, transport document, C/O, permits, technical data, value, tax and inspection results.
Retain every amendment: preserve the original declaration, supplements, authority decisions, before-and-after documents and approval evidence.
Close the operational file: record clearance/release, tax payment, delivery, container return and outstanding items such as late C/O submission or finalisation.
Preserve electronic and paper evidence under the correct rule: Article 24(2) of the Customs Law requires electronic customs documents to maintain integrity and the prescribed format. Stored data should remain accessible, accurately represented and traceable to its originator, sender, recipient and send/receipt time; electronic accounting records must also remain secure, confidential and retrievable throughout retention. Keep paper or original documents where a specific rule or transaction requires them.
Test retrieval periodically: sample a declaration and require the responsible team to produce the complete file within the company’s internal service level.
Dispose only after a multi-law review: verify customs, accounting, tax, sector, dispute and Legal Hold requirements and document the approval for destruction.

Minimum output: one shipment index, statutory customs core, supporting evidence set, change log, retention schedule and completeness review record.

RISKS AND COMMON ERRORS

ERROR	CAUSE	IMPACT	CONTROL
Keeping only declaration and invoice	Treating the customs file as only what was uploaded	Cannot support HS, value, origin, model or discrepancies	Retain supporting evidence and basis memos
Filing only by supplier or month	No Shipment ID or declaration key	Poor retrieval for multiple shipments/declarations	Use Shipment ID + declaration number + registration date
Overwriting the filing snapshot	Folder keeps only the latest file	No evidence of what existed at filing	Lock the snapshot and store later versions as new revisions
Records held only by broker/forwarder	Outsourced service treated as outsourced responsibility	Company cannot promptly produce records	Maintain a company-controlled copy and handover evidence
No change communications	Only final documents retained	No explanation for changed consignee, model, quantity or value	Keep change log, transmittal and approvals
Unverified scans	Files renamed or internally edited	Authority and integrity cannot be established	Save source metadata and the issuer’s original; a checksum may detect later alteration but does not by itself prove authenticity or issuing authority
Deleting immediately after five years	No accounting/tax/sector/legal hold review	Premature destruction of still-required records	Apply the longest applicable retention period
Backups never tested	Backup exists but cannot be restored	Files unavailable during audit	Perform periodic restore and access tests

LEGAL BASIS AND SOURCES

LEGAL SOURCE	AUTHORITY – STATUS	RELEVANT CONTENT	APPLICATION
Consolidated Customs Law 54/VBHN-VPQH dated 23 March 2026	Office of the National Assembly; consolidated text for reference	Article 18 requires authenticity and consistency between business-held and customs-held records and five-year customs-record retention from declaration registration unless otherwise provided. Article 24(2) requires electronic documents to maintain integrity and the prescribed format.	Direct basis for the five-year customs-record period, file consistency and electronic-document requirements; it is not a universal minimum for every related record.
Decree 167/2025/ND-CP	Government; effective 15 August 2025	Amends Decree 08/2015 on customs procedures, inspection, supervision and control.	Reference for current procedural scenarios.
Circular 121/2025/TT-BTC	Ministry of Finance; effective 1 February 2026	Amends circulars on customs procedures, documents, import/export duties and tax administration.	Used to identify the applicable file composition and electronic submission rules.
Decree 174/2016/ND-CP	Government; effective 1 January 2017	Articles 9–13 require accounting records to be complete, safe and organised by accounting period; electronic records must remain secure, confidential and retrievable; minimum periods are five or ten years depending on category.	Classify accounting evidence under Article 12 or 13; do not assume every item is ten-year material and do not destroy it merely because the customs period has expired.
Law on Electronic Transactions 20/2023/QH15	National Assembly; issued 22 June 2023, effective 1 July 2024	Articles 10–13 address integrity, accessibility, evidential reliability and storage conditions for data messages.	Use it to design an electronic repository that preserves accurate content and identifies the originator, sender, recipient and send/receipt time.

CONSOLIDATED CUSTOMS LAW DECREE 167/2025 CIRCULAR 121/2025 DECREE 174/2016 E-TRANSACTIONS LAW

FAQ

1. One shipment has several declarations. One file or several?

A common Shipment File may be used, but each declaration number, registration date, regime and evidence set must have its own indexed sub-file.

2. Must every item be kept on paper?

Not automatically. Article 24(2) of the Customs Law recognises paper and electronic customs documents, but electronic records must maintain integrity and format. Article 13 of the Law on Electronic Transactions requires accessibility, accurate representation and traceability to originator, sender, recipient and time; paper or original documents remain necessary where a specific rule or transaction requires them.

3. If the customs broker retains the records, must the importer also retain them?

Yes. The declarant’s responsibility is not replaced by the service provider’s storage. The company needs its own controlled copy and access rights.

4. When does the five-year period begin?

From the customs declaration registration date under Article 18 of the Customs Law, unless otherwise provided. Accounting books and related evidence follow the retention periods under their applicable laws.

5. Can the whole file be deleted after five years?

Not necessarily. Accounting, tax, refund, sector, contract, dispute and authority requirements must first be reviewed. Legal Hold is an internal control that suspends disposal until the triggering matter is formally released.

6. Should catalogues, product photos and emails be retained?

Yes where they support description, model, function, HS classification, origin, customs value or a change decision.

7. How should folders be named?

Use Shipment ID, direction, year, declaration number and registration date; use document type, number, revision, status and issue date in file names.

APPLICATION NOTE: The five-year customs-record period starts from the customs declaration registration date unless otherwise provided. It is a specific customs period, not a universal minimum for every document in the Shipment File. Businesses should not apply a single deletion rule to the entire shipment file. Before disposal, review accounting, tax, refund, origin, sector, contract, dispute, post-clearance audit and Legal Hold requirements. Vietnamese legal translations in this article are operational references only and are not official legal translations.

TGIMEX IMPLEMENTATION SUPPORT

TGIMEX helps businesses turn the article into a shipment-ready checklist, covering input-data review, dossier preparation, milestone control, and coordination with the relevant parties.

Convert guidance into checks

Assign an owner and deadline to every operational control point.

Reconcile shipment data

Compare booking, transport, commercial, customs, and delivery evidence.

Manage operational risk

Record discrepancies, actions, and decision evidence to prevent recurrence.

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