The Advance Cargo Declaration System and the Lingering Questions

Habiballah Abdelwahab
Follow-up to our previous article on the same subject
Let us recall that Sudan Customs has presented the Advance Cargo Declaration (ACD) system as a mechanism to simplify, facilitate, and accelerate procedures, in line with modern concepts and systems in global trade, as it has explained. The ACD is an electronic system that processes data submitted on shipments destined for Sudanese ports. As we are only days away from its implementation, many lingering questions crowd our minds, all seeking clear answers. These questions relate to the system’s usefulness, its ability to withstand the practical challenges it will face, and its capacity to meet the objectives and expectations set by the senior leadership of the Sudan Customs Authority.
Before reviewing these pressing questions, it is worth recalling—together with our readers—that over the past week a number of writers and media platforms have addressed this new system. They raised questions about the identity and nationality of the company that designed and implemented the platform in cooperation with Customs, as well as questions about the nature and role of the foreign companies that will issue ACD certificates on behalf of, and as agents for, shipping companies or exporters whose consignments are bound for Sudanese ports. Although some of these inquiries merit serious consideration, they remain somewhat distant from the core issue: the nature of this system itself, and its readiness to offer something genuinely new and modern in dealing with the complexities and pitfalls of international trade.
Let us therefore examine some of the most pressing questions, including the following:
Will Customs accept invoices submitted through the ACD system regardless of their stated value, or will they be subject to Customs’ existing value records?
In addressing the issue of invoicing, we know that the value of imported goods is ultimately determined by the agreement between the exporter and the (Sudanese) importer, as both parties are bound by a closed circle of shared interests. Consequently, the (Sudanese) importer can determine a price that suits him if he intends to evade customs duties and taxes. This is entirely possible and, unfortunately, common among those lacking scruples, especially since the importer can influence the shipper.
Here we approach the ACD system with a critical question: Will Customs accept the shipper’s or exporter’s invoice merely because it was issued by them, regardless of its value? Or will Customs be drawn into the labyrinth of verifying the invoice’s credibility—requiring authentication by a chamber of commerce or a ministry of trade in the country of origin, for example—before accepting it, flaws and all, with eyes half closed? Or will Customs subject the invoice to its own internal valuation records and decide whether it constitutes under-invoicing or aligns with those records?
In our view, if Customs accepts such invoices at face value, revenues will inevitably be lost. If it rejects them, the new system itself will be undermined. Which option, then, will Sudan Customs choose?
Does the ACD system possess a mechanism to verify the description of goods while they are still at the port of loading or en route at sea, or is it merely an electronic system that processes shipment data as declared by the shipper?
We are facing a real dilemma regarding the description of goods, one that Sudanese importers will have to contend with once the ACD system comes into force. It is worth noting that the shipper or exporter is, of course, responsible for stating the description of the goods on shipping documents (bill of lading, invoice, etc.) in accordance with what was agreed between them and the (Sudanese) importer. The platform will process this description as provided.
This gives rise to a cascade of interrelated questions: does the ACD system have a mechanism enabling it to identify and assess the description of the goods and verify its conformity with what is stated in the documents while the shipment is still at the port of loading or in transit at sea—so that Customs can rely on that description conclusively and release the goods immediately upon arrival once the customs clearance cycle is complete, without physical inspection? Or will Customs continue to examine the goods within the customs area, including laboratory testing where necessary, before deciding on their conformity with the documents and their suitability for consumption or use, as it has done in the past?
Will Customs dispense with the procedures and measures followed by the Sudanese Standards and Metrology Authority, which conducts field and physical inspections of goods upon their arrival at Sudanese ports?
In our view, the ACD system lacks mechanisms to verify or inspect goods prior to shipment or while they are in transit at sea. It is an electronic system that merely processes the data available in shipping documents as submitted; it has no remote-sensing capability. Given that Customs will certainly insist on exercising its responsibility to inspect goods upon arrival and will continue to enable the Standards Authority to fulfil its mandate, we will inevitably face a clear reality: the ACD system offers no practical guarantees regarding the description of goods and, in fact, conflicts with the rigorous and ideal standards applied by the current customs system.
Who bears the cost of issuing ACD certificates in foreign currency, and why is issuance restricted to foreign companies?
The uncomfortable truth, difficult to overlook, is that the ACD system imposes additional foreign-currency costs that will ultimately be borne by Sudanese citizens. The system imposes a high tariff on every tonne entering the country—by sea, air, or land—averaging around USD 4 per tonne. If we consider that Sudan’s imports in 2024, according to the Central Bank’s statistical presentation, amounted to approximately 4.3 million tonnes of various goods, then the foreign companies—and exclusively foreign companies—responsible for issuing these certificates will collect no less than USD 16 million annually.
While it is true that the shipper will pay these fees, they will inevitably be passed on as part of the goods’ cost. It is unrealistic to imagine that they would absorb them voluntarily. Here, questions multiply: why is the responsibility for issuing ACD certificates confined solely to foreign companies such as ITR Logistics Trade DMCC (Dubai), Sustain & Able, and others? Is it because national companies lack credibility in the eyes of the authorities? Are there truly no national companies with the technical capacity, expertise, and integrity to manage this system? Will Sudan Customs receive any share of these issuance fees, or will they be relinquished entirely to foreign companies?
Why the insistence on replacing the current customs system with an electronic system that offers no practical solutions?
From the questions raised and the analysis presented, our readers and we can arrive at some painful conclusions. The ACD system will clash with the revenue-collection system regarding the customs valuation of shipped goods if Customs accepts declared values as is. The system also offers no practical solutions for describing shipped goods, while imposing issuance costs borne by Sudanese citizens while the proceeds flow to foreign companies—on top of the complexity of the issuance procedures themselves. With these characteristics, the system may indeed achieve certain targets, but they will undoubtedly be counterproductive ones.

In whose interest is the capacity of Sudan Customs being ignored?
What we have consistently emphasised is that the current customs system is highly advanced and fully capable of meeting all the requirements of digital transformation, including network integration with all customs clearance partners—banks, ministries, authorities, clearing agents, and suppliers. It is also based on the latest protocol of the International Convention on the Simplification and Harmonisation of Customs Procedures, and it remains the strongest system in terms of revenue efficiency and consumer protection.
It is no secret that Sudan Customs employs highly qualified and experienced personnel. If there is a genuine practical need to establish an electronic platform to manage international trade operations, then let it be a purely national platform.
To be continued…
International Trade Expert

Shortlink: https://sudanhorizon.com/?p=9877