A renewed attempt to introduce Advance Cargo Information (ACI), Electronic Cargo Tracking Note (ECTN), Smart Port Note, and related cargo-manifest technologies into Ghana’s international trade architecture has triggered fresh concerns among trade stakeholders, who argue that the proposals risk reintroducing a policy framework that was expressly suspended by the Presidency in 2018 due to duplication and increased costs to businesses.
Documents reviewed by the News Centa Newspaper suggest that, despite differences in branding and technological presentation, the latest cargo-information initiatives raise many of the same policy concerns that led the government to halt the implementation of the Cargo Tracking Note (CTN) system eight years ago.
At the centre of the debate are proposals being advanced by two separate private-sector interests.
One involves Inter-Ocean Maritime and Logistics Institute Limited, which is associated with Electronic Cargo Tracking Note and Smart Port Note technologies.
The other involves Rock Africa, which is promoting an Advance Cargo Information platform involving CargoX, TradeWindow, TradeXchange, and FX3D.
While proponents argue that the systems would strengthen revenue assurance, customs risk management, foreign-exchange monitoring, and trade intelligence, critics insist the proposals amount to a costly duplication of functions already being performed by Ghana’s existing customs infrastructure.
The 2018 presidential directive still looms large
The strongest argument against the proposed systems comes from the government’s own policy history.
A letter dated February 16, 2018, from the Office of the President directed the suspension of the Cargo Tracking Note policy after a high-level meeting between the Ghana Revenue Authority and the Association of Ghana Industries, chaired by then Vice-President Dr Mahamudu Bawumia.
The Presidential directive stated clearly that the information expected to be generated through the Cargo Tracking Note system was already available through cargo manifests accompanying imports into Ghana.
As a result, the government concluded that introducing a separate CTN platform would amount to duplication rather than value addition.
Instead of creating a new system, the Presidency directed that manifest information should be made available during both pre-arrival and arrival stages of customs processing to strengthen controls and improve declaration validation.
The decision reflected a fundamental policy principle that remains relevant today: where information already exists within the customs architecture, creating an additional layer merely increases complexity without necessarily improving efficiency.
Threat to Ghana’s business-friendly agenda
Beyond duplication, the Presidency also cited cost as a major reason for suspending the CTN policy.
The 2018 directive warned that introducing CTN would increase the cost of doing business and would contradict the government’s objective of making Ghana the most business-friendly country in Africa.
Trade experts argue that the same concern applies to current proposals for ACI, Smart Port Note, and ECTN systems.
According to documents reviewed by this paper, charges associated with cargo-tracking and advance-information schemes ultimately become additional costs borne by businesses and consumers.
While individual transaction fees may appear insignificant, their cumulative effect across Ghana’s annual import volumes could be substantial.
One policy analysis reviewed by this paper estimates that a Smart Port Note arrangement alone could cost Ghanaian shippers tens of millions of dollars annually.
Critics argue that such costs cannot simply disappear.
Instead, they are likely to be transferred throughout the supply chain until they eventually reach consumers through higher prices.
Consumers would ultimately pay the price
Trade stakeholders warn that any additional cargo-tracking charge introduced into the import process would eventually affect the cost of living.
Importers already face customs duties, taxes, levies, terminal charges, shipping line fees, inspection charges, port fees, and numerous statutory payments before goods leave the ports.
Adding another mandatory cargo information fee would increase import costs further.
Business groups argue that the consequences would extend beyond the ports.
Food products, pharmaceuticals, spare parts, machinery, construction materials, household goods, and industrial inputs could all become more expensive as importers pass on additional costs to consumers.
At a time when businesses continue to struggle with exchange-rate volatility, high financing costs, and multiple taxes, critics question whether introducing another layer of fees is economically justifiable.
ICUMS already performs the same functions
Perhaps the most significant technical objection relates to Ghana’s Integrated Customs Management System (ICUMS).
Trade experts argue that Ghana already possesses a comprehensive national single-window platform capable of handling precisely the functions being promoted under ACI and CTN-style systems.
According to technical documents reviewed by this paper, manifests for sea, air, and road cargo are already submitted electronically through ICUMS.
The system also facilitates electronic issuance of permits, licences, and exemptions.
Furthermore, all government agencies involved in cross-border trade already process documentation through the same platform.
ICUMS also enables electronic attachment of supporting documents throughout the clearance process.
Given these capabilities, critics ask a simple question: why should importers pay a third party to provide information that the government already receives through ICUMS?
Questions over valuation and verification
Another major concern relates to customs valuation.
Supporters of ACI systems argue that pre-shipment document verification can help identify under-invoicing and improve revenue collection.
However, technical experts maintain that ICUMS already provides customs authorities with multiple price-verification tools and databases.
According to documents reviewed by this paper, Ghana’s customs clearance architecture already operates as an end-to-end digital system with access to all major valuation sources.
Critics, therefore, question the need for an additional private-sector valuation layer.
They argue that introducing parallel verification mechanisms risks creating confusion, delays, and overlapping responsibilities within the clearance process.
Risk of creating a parallel bureaucracy
Trade stakeholders also warn against creating a parallel customs process outside the national single window.
According to critics, systems such as Advance Cargo Information could require importers to submit the same information multiple times through different platforms.
This would increase compliance requirements and administrative burdens without necessarily delivering measurable improvements in risk management.
The fear is that Ghana could end up operating multiple overlapping cargo-information systems simultaneously, creating inefficiencies rather than eliminating them.
The central policy question
Supporters of Advance Cargo Information continue to argue that pre-shipment verification can improve risk detection, foreign-exchange governance, and revenue protection.
However, opponents insist the real issue is not whether those objectives are desirable.
Rather, the question is whether Ghana needs another mandatory private-sector cargo-tracking layer when the government already operates a national digital trade platform performing similar functions.
For many businesses, the debate ultimately returns to the same conclusion reached by the Presidency in 2018: if the information already exists within the customs system, introducing a parallel cargo-tracking mechanism may simply duplicate functions, increase costs, and undermine Ghana’s competitiveness as a trading hub.
As policymakers revisit the issue, stakeholders say the burden of proof now rests on proponents of ECTN, Smart Port Note, and ACI systems to demonstrate why Ghana should reverse a policy position that was previously rejected on grounds of duplication, higher costs, and potential harm to the country’s business environment.
