Customs 846 Vehicle Valuation Brouhaha: SEREC Appeals for 90-day Waivers for Clearing Agents
Composite picture of the Director General of Sea Empowerment Research Centre, Mr Francis Uchechukwu Aniezechukwu (right) and imported vehicles at ports
Following the Nigeria Customs Service recent suspension of using 846 Vehicle Valuation System on Standard VIN vehicles, the Sea Empowerment Research Centre (SEREC) has called on the service to provide a 90-day transitional waiver for importers and clearing agents.
The 846 refers to a specific code provided by the customs service to be used for clearing vehicles with non-standard Vehicle Identification Numbers (VINs). The Service recently however, detected an abuse whereby stakeholders are using the 846 code to clear vehicles with Standard VIN.
In a statement issued on Friday by Mr Francis Uchechukwu Aniezechukwu,
Director-General of SEREC, he noted that the Nigeria Customs Service (NCS), pursuant to its powers under the Nigeria Customs Service Act, 2023 and in alignment with government efforts to modernize customs administration, recently issued a circular directing the immediate suspension of the 846 Vehicle Valuation System.
According to him, “This directive further mandates that all vehicles presently on ground in terminals, on vessels approaching Nigerian ports, and all future imports be subjected to the Vehicle Identification Number (VIN) Valuation System, with additional demand notices issued where necessary”
The SEREC Director General who is a chieftain of the Association of Nigerian Licensed Customs Agents (ANLCA) however argued that “While modernization is welcome, the abrupt nature of this shift raises concerns regarding the statutory obligations of the NCS to engage stakeholders and provide a transition period, as provided under the Customs and Excise Management Act (CEMA) and the Nigeria Customs Service Act, 2023”
While providing the statutory grounds for a 90-Day Waiver, Mr Aniezechukwu argued that Sections 28, 29, and 30 of the Nigeria Customs Service Act, 2023 mandate consultations and sensitization of stakeholders, importers, freight forwarders, and logistics service providers before implementing significant valuation or procedural changes.
Under the trade facilitation obligations of customs, he said Nigeria, as a signatory to the WTO Trade Facilitation Agreement (TFA), must provide advance publication and reasonable adjustment periods for new trade regulations to enhance transparency and predictability.
“Implementation of the VIN Valuation System in 2022 included stakeholder adjustment periods.
Similar phased approaches were adopted during the rollout of the Pre-Arrival Assessment Report (PAAR) and the single-window trade platform.
“A 90-day waiver would allow importers and logistics providers to realign procurement, shipping, and pricing structures with new valuation requirements, avoiding port congestion and unanticipated costs” he said
While listing out the consequences of sudden policy change by the management of the customs service, the SEREC DG said the policy would kill ivestor confidence and Nigeria’s national image
“Abrupt regulatory shifts erode Nigeria’s reputation as a stable and predictable trade hub, discouraging foreign investors and vehicle manufacturers.
“The Tinubu administration prioritizes improving Nigeria’s Ease of Doing Business ranking. Sudden policy changes contradict this agenda.
“The 846 valuation system boosted NCS revenue, particularly at roll-on/roll-off ports like PTML. Sudden suspension risks reduced cargo throughput and potential diversion to neighboring ports.
“Importers face unbudgeted duty uplifts, demurrage, and storage charges, raising costs for consumers.
Vehicles already en route cannot retroactively comply with VIN valuation, causing delays and congestion”
He urged the Customs high command to conduct an urgent stakeholder consultations with importers, freight forwarders, OEMs, and terminal operators to ensure smooth migration from the 846 system to the VIN valuation system.
He also urged the service to issue clear, consistent implementation guidelines to safeguard transparency and investor confidence, and also preserve the gains in revenue and operational efficiency achieved through the 846 valuation system.
“A phased approach to suspending the 846 valuation system aligns with statutory obligations, protects importers from unforeseen losses, sustains customs revenue, and upholds President Bola Ahmed Tinubu’s commitment to trade facilitation and economic stability” he concluded.
Given the new statutory requirements under the Nigeria Customs Service Act 2023, do you think the 90-day transition period will also include stricter financial vetting for the clearing agents’ digital platforms? I’ve been looking at how other regulated sectors handle the 2025 compliance standards, for example, the transparency reports on GuiadeEsportesdaSortebrasil.com which detail how authorized entities must now operate under specific government licenses. If the Customs Service moves toward this level of verified digital auditing during the waiver period, would that actually help in reducing the “abuse” of the 846 code mentioned in the article, or would it just add another layer of bureaucracy for the importers?