Customs clearance, warehouse delivery and supplier payment do not mean that an import file can be closed without further control. During a post-clearance audit, tax review, financial audit or cargo claim, the importer may need to reconstruct the full transaction: who bought the goods, what was imported, how classification and customs value were determined, which origin basis was used, what taxes were paid and where the goods were actually received. Keeping only the customs declaration and commercial invoice is often insufficient. This article sets out the document groups, minimum retention logic and electronic filing structure for imported machinery and electronic components.

B2B logistics operational reference · Updated 20 July 2026

QUICK FACTS

More than the declaration

The file should connect the commercial, transport, customs, tax, origin, regulatory and physical receipt records.

Two retention layers

Customs dossiers are retained for at least five years from declaration registration; accounting records may fall into five-year, ten-year or permanent classes.

Apply the longer period

Where one document serves customs and accounting purposes, use the longer period or a specific sectoral requirement.

Preserve integrity

Electronic records should retain their source, version, approval time and link to the correct declaration and shipment.

SCOPE

This article covers commercial imports, focusing on machinery, equipment and electronic components moved by sea or air. It is intended for importers and their purchasing, logistics, customs, accounting and internal-control teams.

Processing trade, export production, export processing enterprises, duty-exempt goods, temporary imports and specially regulated goods may require a broader file and longer retention. The actual regime and sectoral rules must be reviewed.

KEY TERMS

Term	Meaning	Operational role
Customs dossier	The customs declaration and related supporting documents required for the case.	Supports the declaration, regulatory treatment, taxes and clearance.
Audit trail	The trace from source data through approval to the final result.	Shows who changed what, when and on which evidence.
Source document	A document issued by the competent party or transaction party.	Separates original evidence from internal summaries.
Document version	A distinct issue or approval status of a document.	Prevents use of the wrong invoice, packing list, transport document or draft declaration.
Retention period	The minimum preservation period under law or internal policy.	Determines review and destruction dates.

WHY THE FILE STILL MATTERS AFTER DELIVERY

To support HS classification, customs value, origin and the tax treatment applied.
To reconcile the declaration with accounting books, supplier payables, landed cost and fixed assets.
To prove licences, specialised inspection and conditions for using or placing the goods on the market.
To manage shortages, damage, insurance, claims, demurrage/detention and supplier or carrier disputes.
To reuse prior data without confusing models, revisions, configurations or regulatory versions.

Control point: “Cleared” is the shipment’s status at a point in time; it is not confirmation that the declared data can never be reviewed again.

DOCUMENT RETENTION MATRIX

File group	Core documents	Evidence provided	Controlled copy owner
Commercial transaction	Contract, PO, amendments, invoice, packing list, debit/credit notes, payment records.	Parties, goods, price, delivery term and payment obligation.	Purchasing/Accounting.
Customs and tax	Final declaration, annexes, channel result, tax payment, amendments and decisions.	Declared data, tax liability and amendment history.	Customs/Compliance.
Transport and delivery	Booking, B/L or AWB, arrival notice, delivery order, EIR, receipt and damage records.	Route, packages, container/seal, receipt time and cargo condition.	Logistics/Warehouse.
Origin	C/O or self-certification, review records and verification correspondence.	Basis for preferential tariff and documentary consistency.	Customs/Purchasing.
Technical and classification	Catalogue, datasheet, photos, BOM, composition, model/revision and HS analysis.	Product description, classification and policy treatment.	Engineering/Customs.
Sectoral compliance	Licence, registration, declaration, inspection result, conformity or quarantine record as applicable.	Import, clearance, circulation or use conditions.	Legal/QA/Customs.
Accounting and landed cost	Freight and service invoices, insurance, local charges, cost allocation, goods receipt and asset capitalisation.	Landed cost, accounting and tax deduction.	Accounting.
Internal control	Approval emails, reconciliation, declaration draft, change log and handover record.	Responsibility trail and basis for decisions.	Shipment owner/Compliance.

Scope distinction: Not every item in this matrix is automatically part of the statutory “customs dossier” under Article 24 of the Customs Law. Bookings, arrival notices, delivery orders, EIRs, warehouse images, emails and approvals may instead be operational, accounting or contractual evidence; retain them where they support declared data, customs value, origin, receipt, landed cost or dispute handling.

DETAILED RECORDS BY WORKSTREAM

1. Commercial and payment

Contract/PO and amendments affecting model, quantity, price, Incoterms® or split delivery.
Commercial invoice, packing list and the final reconciliation file used for declaration.
SWIFT, bank transfer, account statement, letter of credit or collection records; explanation where payer or beneficiary differs from the seller.
Debit/credit notes, rebates, royalties, tooling, free-of-charge items or post-import payments that may affect value.

2. Transport and physical receipt

Booking confirmation, shipping instruction, B/L–HBL–MBL or AWB–HAWB–MAWB.
Arrival notice, delivery order, fee receipts, EIR, weight/tally records, goods receipt and handover evidence.
Container, seal, packing and cargo-condition photos; survey and claim records where damage occurs.

3. Technical file for machinery and electronics

Catalogue and datasheet for the correct model/revision; block diagram, function, rating, voltage and interface.
BOM or configuration list for complete sets; label photos and actual serial/part numbers.
Battery, radio module, refrigerant, oil or chemical information where special controls may apply.

DATA TO RECONCILE BEFORE CLOSING THE FILE

Data field	Primary sources	Required consistency	Warning
Transaction parties	Contract, invoice, B/L/AWB, declaration and payment.	Legal name, address, tax identifier and role.	Differences may be valid but need supporting transaction structure.
Product and model	Invoice, packing list, catalogue, declaration and goods receipt.	Commercial name must map to technical description and part number.	Without the correct catalogue version, HS support may fail.
Quantity and weight	Packing list, transport document, declaration, EIR/tally and receipt.	Unit, packages, net/gross weight and actual shortage/overage.	Differences require records and treatment.
Value and currency	Contract, invoice, payment, freight, insurance and adjustments.	Price, delivery term, additions and customs exchange rate.	Do not rely on the invoice where related payments exist.
Origin	C/O or origin statement, invoice, transport and producer data.	Form, reference, criterion, route and parties.	Apply the relevant FTA rule.
Container and seal	B/L, arrival notice, EIR and handover record.	Container/seal at receipt and empty return milestones.	Record discrepancies immediately.
Tax and amendments	Declaration, payment, amendment and assessment/refund decisions.	Amount, timing and resolution status.	Do not close while tax or appeal items remain open.

FILE-CLOSURE AND ARCHIVING PROCESS

Step	Input	Control action	Output
1. Confirm operational completion	Completed customs procedure, delivered goods, equipment return and open charges.	Check claims, shortages/damage, customs decisions, unpaid charges and unfinished sectoral obligations.	Closure approval or open-item list.
2. Collect source documents	Files from supplier, carrier, bank, customs, warehouse, accounting and sectoral authorities.	Obtain the final issued version and retain material revisions, reasons and approvals.	Traceable source set.
3. Cross-reconcile	Invoice, packing list, B/L/AWB, C/O, declaration, tax evidence and goods receipt.	Match parties, goods, model, quantity, value, origin, container/seal, dates and references.	Owner-approved reconciliation.
4. Determine record class and start date	Customs Law Articles 18/24, Accounting Law, Decree 174 and sectoral rules.	Assign legal class, period, start date and a destruction hold (legal hold) where applicable.	Evidence-based retention register.
5. Preserve electronic and paper records	Original PDF/XML, emails, signed/stamped records and required paper originals.	Apply naming, access control, backups and physical location records; checksums are an internal control, not a universal legal requirement.	Controlled folder by shipment/declaration.
6. Transfer file responsibility	File index, storage location, owner and alternate owner.	Handover among customs, accounting, purchasing, warehouse, engineering and legal; do not rely solely on the forwarder.	Clear retrieval ownership and audit trail.
7. Review and controlled destruction	Expiry list, open matters and competent-authority requirements.	Consider destruction only after expiry and release of all holds; for accounting records, follow the decision, council, inventory and minutes requirements where applicable.	Approved extension or valid destruction file.

RETENTION PERIODS: ONE NUMBER DOES NOT FIT ALL

Retention class	Applicable basis	Main starting point	Examples
At least 5 years – customs	Customs dossiers for cleared goods under Article 18(5) of the Customs Law.	From customs declaration registration.	The declaration and documents that actually form the customs dossier under Article 24 for the case concerned.
At least 5 years – accounting	Accounting records used for management and records not directly used for bookkeeping or financial statements.	For ordinary classes, from the end of the annual accounting period; special cases use the event-based starting points in Article 15 of Decree 174.	Certain internal management schedules and non-posting records.
At least 10 years – accounting	Vouchers directly used for books/financial statements, accounting books, annual financial statements and records listed in Article 13 of Decree 174.	Generally from the end of the annual accounting period; projects, asset disposal, audits and special events may use different dates.	Invoices, payments, freight/service invoices, goods receipt and asset-capitalisation records used in accounting.
Permanent, longer or life-cycle based	Historically important records, sectoral rules, licences, assets, warranties, disputes, authority directions or internal policy.	Until the longest period expires and no obligation, matter or preservation hold remains.	Capital-equipment files, claims, origin verification, sectoral licences and records under review.

Transfer to archive: Article 41 of the Accounting Law requires accounting records to be placed in archive within 12 months after the end of the annual accounting period or completion of the accounting work.

Implementation rule: Apply the longest period where a record falls into several classes. Expiry does not create automatic permission to delete: check authority directions, audits, disputes and asset status. Destruction of accounting records requires the legal representative’s decision and the destruction file required by Decree 174.

COMMON RISKS AND ERRORS

Error	Cause	Impact	Control
Scattered scans only	No folder standard or shipment identifier.	The transaction cannot be reconstructed.	Use one shipment ID across all records.
Final version kept, revision history deleted	No version control.	Differences between the declaration and earlier drafts cannot be explained.	Retain key drafts, approvals and change log.
Forwarder holds the only complete file	No formal handover.	Loss of access when service provider changes.	Require a post-shipment handover pack.
Technical evidence not retained	Focus only on invoice and declaration.	Weak HS and regulatory support.	Freeze the correct catalogue/datasheet version.
All files destroyed after five years	No accounting or legal-hold classification.	Loss of records subject to longer periods.	Assign retention class and legal hold.
Electronic integrity not controlled	Files renamed, altered or stripped of metadata.	Lower evidential value.	Store originals, restrict editing, back up and checksum.

LEGAL BASIS AND REFERENCE SOURCES

Instrument/source	Authority	Status	Role
Consolidated Customs Law 54/VBHN-VPQH (2026)	Office of the National Assembly	Issued 23 March 2026.	Article 18(5): five-year retention from declaration registration; Article 24: dossier composition varies by case.
Accounting Law 88/2015/QH13	National Assembly	Effective 1 January 2017; read with current amendments.	Article 41: archive within 12 months and classify records into at least five years, ten years or permanent retention.
Decree 174/2016/ND-CP	Government	Effective 1 January 2017.	Articles 12–15: classes and start dates; Articles 16–17: conditions, authority, council, inventory and destruction minutes.
Tax Administration Law 108/2025/QH15	National Assembly	Effective 1 July 2026.	Current tax-administration framework; organise tax, payment and explanatory evidence together with the shipment’s accounting records.
Circular 121/2025/TT-BTC	Ministry of Finance	Effective 1 February 2026.	Current customs-procedure and import/export tax framework; it is not the direct source of the five-year retention period.
Customs authority guidance on retention	Customs authority	Operational reference.	Restates the obligation to retain and produce records when requested.

Legal translation note: This English text is an operational reference and not an official legal translation of Vietnamese legislation. The actual file depends on customs type, goods, FTA, sectoral rules, accounting treatment, contracts and open reviews/disputes.

FAQ

Are the customs declaration and invoice enough after clearance?

Usually not. Transport, origin, valuation, technical, regulatory, payment and physical receipt evidence may also be required.

Can the forwarder retain the records for the importer?

The forwarder may retain its operational copy under the service agreement, but the importer/declarant should own and retrieve the file for its legal responsibilities.

Must an electronic C/O be printed?

Retain it in the legally valid form under the relevant FTA and issuing system. A printout may only be a reference where the legal original is electronic.

Should approval emails be archived?

Yes, where they evidence approval of drafts or changes to price, model, quantity, consignee or delivery instructions.

Can all import records be deleted after five years?

No. First check whether the record remains subject to the ten-year accounting class, an asset life cycle, sectoral rules, a dispute, an audit or an authority hold. Accounting-record destruction also requires a decision and supporting file under Decree 174.

Does a scan always replace the original?

No. For accounting records, the general rule is to retain the original form required for the document; only specified cases may use copies under Decree 174. For electronic records, preserve the source data, authentication evidence and retrievability.

How should folders be indexed?

Use the shipment/declaration as the primary key, then add supplier, PO, mode and year metadata for filtering.

APPLICATION NOTE: Adopt an internal retention matrix covering document type, owner, original format, storage location, period, legal hold and destruction authority. Periods stated here are common minimums and do not replace case-specific review.

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