A policy rejected by Ghana’s presidency in 2018 is back, this time wearing three different brand names and being pushed by two separate private-sector interests, triggering a fresh confrontation between trade stakeholders and the country’s customs establishment over who pays the bill.
Two proposals are currently in circulation. One comes from Inter-Ocean Maritime and Logistics Institute Limited, promoting Electronic Cargo Tracking Note and Smart Port Note technologies. The other is from Rock Africa, which is advancing an Advance Cargo Information platform involving CargoX, TradeWindow, TradeXchange, and FX3D. Both claim to strengthen revenue assurance, customs risk management, and foreign-exchange monitoring. Critics say both describe functions the state already performs.
A policy brief reviewed by industry observers, titled “An Unjustified Cost Burden on Consumers and Businesses,” argues that charges associated with such systems are not absorbed by foreign exporters at the point of origin but flow down the supply chain, landing on Ghanaian importers and, ultimately, on consumers.
The 2018 presidential directive — issued after a meeting between the Ghana Revenue Authority and the Association of Ghana Industries, chaired by then Vice-President Mahamudu Bawumia — concluded that cargo manifest information was already available through existing customs channels, making a separate Cargo Tracking Note layer pure duplication. That finding sits at the centre of the current debate.
The technical case against the proposals rests on what Ghana’s Integrated Customs Management System already does. Following the integration of an electronic cargo tracking system with ICUMS, Ghana’s customs revenue surged from GHS 30.6 billion in 2023 to approximately GHS 443 billion in 2024, according to Ghana Revenue Authority data, while average clearance times fell from 11 days to 9.22 days. For proponents of a new private-sector tracking layer, those numbers present an inconvenient baseline.
A technical note reviewed by trade practitioners states that if any additional pre-clearance or pre-manifest capability is required beyond what ICUMS currently provides, that capability is already available within the system and ready to deploy.
The governance dimensions of the push are drawing equal scrutiny. Four questions are emerging among trade practitioners and policy observers: whether any new cargo-tracking system has been subject to competitive procurement; whether the Ministry of Transport holds the legal authority to approve a mandatory fee-bearing trade information system; whether the private sector and affected stakeholders have been meaningfully consulted; and whether any approved system would duplicate functions already embedded in ICUMS and funded through existing public expenditure.
The reappearance of the same concept under successive names — CTN, ECTN, SPN, ACI — has reinforced the perception among industry participants that what is being pursued is a revenue stream for private operators rather than a solution to a documented trade facilitation problem.
One estimate puts the annual cost of a Smart Port Note scheme to Ghanaian shippers at tens of millions of US dollars, depending on container and general cargo volumes. Importers already carry customs duties, taxes, levies, terminal charges, shipping line fees, inspection charges, and port fees before goods clear. Business groups argue that another mandatory layer would push those costs into the prices of food, pharmaceuticals, spare parts, and construction materials.
Proponents maintain that pre-shipment data verification catches under-invoicing and improves valuation accuracy. Critics accept those are legitimate goals but argue that ICUMS already provides customs authorities with price-verification databases and valuation tools adequate to the task.
Neither Inter-Ocean Maritime and Logistics Institute Limited nor Rock Africa had responded to requests for comment at the time of publication.
