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SEREC position paper on regulation of customs agents license

By Fwdr Eugene Nweke RFF
Sequel to the ongoing industry discussions on the proposed increment of Customs Agents, Chandlers and Bonded Terminal Operations Licenses by the Nigeria Customs Service; the Sea Empowerment and Research Center – SEREC wishes to provide inputs  on these emerging development especially on the basis of ensuring effectiveness and efficiency of license regulations for customs agents.
As stakeholders in the maritime industry, conversant with customs clearance process, we believe that a well-structured licensing framework is crucial for promoting professionalism, efficiency, and compliance.
 Key Recommendations:
Balanced Licensing Fees: Licensing fees should be set at a level that balances the need for regulatory oversight with the need to promote competition and efficiency in the customs clearance process. A possible solution could be to implement a fee structure that is based on the type of service or level of license, with smaller businesses and new entrants paying lower fees.
Categorization Based on Services: Licenses could be categorized, based on the type of services offered, such as import/export, customs brokerage, and freight forwarding.
Tiered Licensing System: A tiered system could be implemented, with different levels of licenses based on factors such as experience and specialization.
Competency-based Licensing: Licensing requirements should focus on demonstrating competence in customs procedures, tariff classification, valuation, and origin determination.
Ongoing Training and Professional Development: License holders should be required to undergo ongoing training and professional development to maintain their licenses.
Fair and Reasonable Fee Increment: We advise against exorbitant fee increments in the current port system, given the already challenging environment. Instead, we recommend a fair and reasonable increment that takes into account the needs of small and medium-sized enterprises.
Alternative Approaches to Licensing Reform: We caution against recapitalization, consolidation, or merger/acquisition of customs licenses as a method of ensuring effective licensing regulations, as this may entail lengthy processes and timing. Instead, we recommend a more streamlined and efficient approach to licensing reform.
Stakeholder Consultation: We recommend that the NCS consults with a broad range of stakeholders, including the Nigeria Shippers Council (NSC) and professional regulatory council ( CRFFN), in any decision-making process related to fee increments or licensing reform. This will help ensure that the interests of all stakeholders are taken into account and that the industry is not unduly burdened
Suggested Solution:
To balance regulatory oversight with industry needs, we suggest implementing a licensing framework that includes the following elements:
A tiered licensing system with different levels of licenses based on experience and specialization.
A competency – based licensing requirement that focuses on demonstrating competence in customs procedures and regulations.
Ongoing training and professional development requirements for license holders
A fee structure that is balanced and takes into account the needs of small and medium-sized enterprises.
Regular review and update of the licensing framework to ensure it remains effective and efficient.
Fair Compensation for Agents: Agents or brokers should receive a fair allocation of a certain percentage of total duty collected, to incentivize compliance and reduce the likelihood of collusion with traders to circumvent duties.
Suitable Categories of Licenses:
– Standard License: A standard license for general customs clearance services.
– Advanced License: An advanced license for agents handling complex customs clearances, such as those involving specialized commodities or high-value goods.
– Specialized License: A specialized license for agents handling specific types of commodities, such as hazardous materials or controlled substances.
– Brokerage License: A brokerage license for agents providing customs brokerage services, including tariff classification and valuation.
– Multi Tasking Operational: This is a higher risk and compliant levels Licenses for Bonded Warehouse/Terminal Operator, Specialized Economic Zone Operator, Fast-Track Statute Operator, Authorized Economic Operator (AEO), etc.
Benefits of a Well-Structured Licensing Framework:
Promote Professionalism: A well-structured licensing framework can promote professionalism and efficiency in the customs clearance process.
Enhance Compliance: Licensing can help ensure compliance with customs regulations, reducing the risk of delays, fines, and penalties.
Economic Benefits: By promoting a professional and efficient customs clearance process, licensing can contribute to increased economic competitiveness and growth.
Conclusively, SEREC believe that a collaborative and inclusive approach to licensing reform can benefit all stakeholders, including the NCS, Customs Agents, and the trading public. We look forward to working with the NCS to implement a licensing framework that balances regulatory oversight with industry needs.
Fwdr Eugene Nweke Rff
@ HOR – SEA EMPOWERMENT AND RESEARCH CENTER – SEREC.
11th August, 2025.
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