In the debate over the impending mandatory Smart Port Note (SPN) system by the Ghana Shippers’ Authority, data analyst David O.G. Abbots presents a technically narrow defence that, while coherent in theory, fails to withstand scrutiny against the practical realities of Ghana’s shipping industry and its existing digital infrastructure. His central argument—that SPN and ICUMS serve different purposes at distinct stages—ignores the fundamental fact that ICUMS is already designed to receive and process advance cargo information. Countering his points requires a grounded look at how data actually flows in modern shipping.
- The False Dichotomy: SPN vs. ICUMS
Mr. Abbots claims SPN operates “before cargo is shipped,” while ICUMS operates “after cargo arrives.” This is a misleading simplification. ICUMS is not just a clearance system; it is Ghana’s Single Window Inventory Management System. By design, a Single Window is meant to be the one stop point for all trade-related data, including pre-arrival and pre-shipment information. The Single Window environment aims to expedite and simplify information flows between trade and government and bring meaningful gains to all parties involved in cross-border trade. In a theoretical sense, a Single Window can be described as a system that allows traders to lodge information with a single body to fulfil all import- or export-related regulatory requirements. In practical terms, a Single Window environment provides one “entrance” for the submission and handling of all data, and documents related to the release and clearance of an international transaction. This “entrance” is managed by one agency, which informs the appropriate agencies, and/or directs combined controls. Shipping lines and agents are already required to submit advanced manifest data (e.g. the Cargo Declaration Forms) into ICUMS before a vessel arrives. This gives Customs, the Ghana Shippers’ Authority, and all other agencies weeks of advance notice for risk profiling and planning.
The WTO Trade Facilitation Agreement (Article 10.4) encourages members to establish a single window, aiming to reduce duplication. A separate, mandatory SPN contravenes this efficiency principle. Creating a separate, parallel portal for importers to upload the same commercial documents (invoices, packing lists, etc.) fragments the data ecosystem. It creates two potential sources of data, increasing the risk of discrepancies, rejections, and delays. The real need is to enhance and better utilise ICUMS’s pre arrival modules, not to build a new silo.
- Repeating a Rejected Idea: The SPN Ignores Ghana’s Own Lessons on Integration
History offers a clear lesson we would be wise to remember. The implementation of an Advance Shipment Information system in Ghana is not a new concept; it was first introduced by the Ghana Shippers’ Authority itself in 2015. Critically, that initiative was rightly postponed with the explicit understanding that such a system should not operate in isolation. The prudent decision was to delay implementation until the advance notification functionality could be fully integrated into the national Single Window platform—at that time, the system operated by West Blue Consulting and GCNet. This postponement was an official acknowledgment of a fundamental operational truth: that creating a separate, parallel system for pre-shipment data is inefficient and creates fragmentation. The correct path was always integration. The ECTN/SPN resurfaced in 2023 under the auspices of the Ministry of Finance and Economic Planning (MOFEP), again as a standalone system. Following justified and vigorous agitation from trade stakeholders who recognised its redundancy, the proposal was abandoned.
Now, merely two years later, it has reappeared under the banner of the Ghana Shippers’ Authority. This cycle of introduction, backlash, and suspension reveals a fundamental flaw in the proposal itself: it addresses no genuine gap in our ecosystem. Today, ICUMS is our national Single Window, and it is specifically designed with robust pre-arrival and pre-shipment modules capable of receiving all necessary advance data. To now revert to the old, discarded model of a standalone platform—the very approach deemed imprudent a decade ago—is to ignore our own hard-learned lessons and to waste scarce resources reinventing a wheel we have already successfully built.
This pattern is not unique to Ghana; across Africa, from Nigeria to Sudan to Tanzania, similar ECTN regimes have faced vehement opposition, legal challenges, and repeated suspensions due to their burdensome and duplicative nature. This troubling history is not a coincidence—it is a consensus. It is a clear signal for all concerned authorities in Ghana to finally subject this concept to a dispassionate, critical review and to conclusively determine if this is a tool Africa truly needs, or a bureaucratic relic we have long outgrown.
- The Reality of Pre-Shipment Intelligence in Ghana Today Abbots argues that modern ports need pre-shipment data, implying Ghana lacks it. This is incorrect.
- Global Shipping Lines are Data Hubs: Maersk, MSC, and others operate sophisticated global tracking systems. When a Ghanaian importer books a shipment, the shipping line’s system generates a Bill of Lading (B/L) with all consignee, description, and origin data. This data is transmitted electronically to the line’s local agent in Ghana well before shipment departure and is integrated into port and customs systems.
- The Role of Freight Forwarders and Customs Brokers: These professionals already prepare and submit a plethora of pre-arrival documentation on ICUMS based on shipping instructions and commercial invoices received from their clients. They are the human intelligence layer that verifies data before it enters official channels.
- The assertion that “without advanced data, digital and AI tools cannot function” is true—but this data already exists and flows through the aforementioned channels. The challenge has rarely been a lack of data but rather inter-agency coordination, analysis, and enforcement within the existing data pool. SPN does not solve this core challenge.
- Legal Mandate vs. Practical Reality
The Ghana Shippers’ Authority’s primary legal defence for the SPN, per the notice, rests on the Ghana Shippers’ Authority Regulations, 2012 (L. I. 2190), which mandates an Advanced Shipment Information system. However, this argument exposes the very core of the problem: enforcing a dormant, 13-year-old regulation in a trade ecosystem that has dramatically evolved past it is not progress—it is regression. The fact that this regulation has remained practically unenforced for over a decade is not an accident; it is a testament to its incompatibility with the modern, efficient direction Ghana chose for its ports.
Ghana has consciously and successfully transitioned to a Destination Inspection Regime, governed by the Ghana Revenue Authority (GRA). This shift was a strategic move to
- Reduce bottlenecks at origin.
- Consolidate inspection and revenue assurance at the point of entry. ● Align with international trade facilitation best practices.
It is a universal truth that legislation often lags behind technological and operational innovation. The law is a slow adapter; commercial practice and technology are swift. Ghana’s shipping industry has not waited for L.I. 2190 to be activated. It has moved forward, developing sophisticated data flows between shippers, global shipping lines, freight forwarders, and ICUMS. The solution to this gap is not to arrest this organic progress and force the ecosystem to conform to an outdated legal clause. The solution is to update the law to reflect contemporary reality.
- The Pilot Phase and the Cost Question
Dismissing cost concerns because the supposed pilot is “free” is naive. The involvement of a private service provider (IOMLI) signals a fee-based model for the future. Ghana’s trading community is weary and chronically fatigued of new “facilitation” platforms and systems that evolve into permanent, non negotiable cost and bureaucratic lines. Each new layer, no matter how small the fee, increases the cumulative cost of doing business, opposing the Ghanaian government’s pain point to reduce the cost of doing business at the ports and eventually eroding Ghana’s competitiveness.
- Stakeholder Consultation and Real-World Workflow
Abbots mentions that stakeholder engagement remains open, but the fundamental complaint is that the system’s design logic was conceived without deep integration into the existing workflow of importers, freight forwarders, and customs brokers. For an importer, being forced to upload documents to a new platform before shipment is a disruptive, manual task that duplicates what their freight forwarder already does within established channels. It shows a lack of understanding of the supply chain’s own efficient, private-sector data flows.
Conclusion: We Need to Look Towards Enhancement of Existing Structures, Not Duplication
Ghana’s trade digitalisation journey should be about integration, not addition. The resources and political will required to enforce SPN compliance would be far better directed at
- Fully unlocking ICUMS’s potential as the true Single Window, ensuring all agencies use it effectively for pre-arrival risk assessment.
- Mandating and improving API integrations between shipping lines’ global systems and ICUMS for seamless, automatic data transfer.
- Empowering the GSA to use existing data and resources to aggressively tackle the real, documented exploitative charges faced by shippers.
The GSA’s core mandate is to protect shippers from exploitative charges and practices by shipping service providers, particularly shipping lines. It is paradoxical to introduce a new mandatory system that, according to the fears of traders, may itself become a cost and bureaucratic burden. The GSA’s energy would be better spent using its new regulatory power under Act 1122 to audit and reject unjustified fees like demurrage, detention, and arbitrary surcharges already plaguing importers.
The SPN, in its proposed form, is a technically redundant system that addresses a problem already solved by existing infrastructure and
commercial practice. It risks becoming a bureaucratic impediment that increases costs and complexity, under the guise of trade facilitation. Before February 2026, a genuine, humble reassessment is required—one that starts not by asking “how can we add a new tool?” but rather “how can we make the tools we already have work better for everyone?”
-The convener for the Coalition of Concerned Exporters, Importers and Traders.
