…scheme previously shelved now routed through Transport Min

A renewed attempt to introduce a cargo-tracking regime in the country has triggered fresh concerns within the trade and logistics sector, after documents suggested that a policy concept previously unable to gain traction at the Ministry of Trade, Agribusiness and Industry is now being pursued through the Ministry of Transport.

At the centre of this renewed push is a proposed Advance Cargo Information (ACI), Electronic Cargo Tracking Note (ECTN) or Smart Port Note (SPN) system, which industry sources say could introduce additional mandatory charges across the import and export chain - affecting importers, exporters, freight forwarders, shipping lines and ultimately consumers.

Persons familiar with the matter indicate that an earlier attempt to implement a similar cargo-tracking framework through the trade ministry did not proceed. The same policy idea, they say, is now being revived via the Ministry of Transport with Inter-Ocean Maritime and Logistics Institute Limited reportedly seeking official backing for a cargo-tracking service in partnership with international technology providers.

Documents reviewed by B&FT show that the company describes itself as collaborating with Antaser International “to provide worldwide services of Electronic Cargo Tracking Notes (ECTN) or Smart Port Notes (SPN) technologies”.

Some of its materials also reference a Ghana-specific notice dated April 9, 2025, in which the Ministry of Trade, Agribusiness and Industry “reaffirms mandatory ECTN/SPN for all shipments, including transit cargoes entering Ghana”.

The development has revived a central policy question within the logistics community around whether the country requires a third-party cargo information system when it already operates the Integrated Customs Management System (ICUMS), the country's established national single window for Customs administration.

ICUMS already does what proponents promise, technical note argues

ICUMS already receives electronic manifests for sea, air and road cargo; processes exemption letters, permits and licences digitally; and hosts all ministries, departments and agencies involved in cross-border trade within a unified platform. A technical note reviewed by this paper asks pointedly whether there is any need for a third party to supply advanced manifest or secured documentation services when the capability already exists within ICUMS at no additional cost to any user or government.

The implication is significant, as what proponents are marketing as a trade intelligence upgrade would, in the assessment of industry critics, simply add a mandatory fee layer on top of infrastructure that already performs the same functions.

The aforementioned technical note states that if any additional pre-clearance or pre-manifest capability is required beyond what ICUMS currently provides, this capability is already available within the system and ready to deploy.

“Certainly, being given different names (Smartport, CargoX, ACI) by different proponents would only add unnecessary costs to the business community or to government without any real value addition.”

Additionally, a policy brief reviewed by this paper - titled ‘An Unjustified Cost Burden on Consumers and Businesses’ - argues that ACI-type charges are not absorbed by foreign exporters at the point of origin but flow down the supply chain, landing on Ghanaian importers and, through them, on consumers.

The brief estimates that a Smart Port Note scheme could cost Ghanaian shippers tens of millions of US dollars annually, depending on container and general cargo volumes.

Consequently, the importer and ultimately the consumer pays. The brief describes the cargo-tracking proposal - variously named Smartport, CargoX and ACI by different proponents - as capable of adding only unnecessary costs to business and government without any real value addition.

For an import chain already burdened by port charges, taxes, levies, exchange-rate pressures and financing costs, that assessment carries immediate practical weight.

Proponents of ACI-style regimes typically argue that early cargo information strengthens risk management, reduces under-invoicing, enhances Customs valuation and improves trade intelligence.

Those arguments are not without merit in markets where pre-shipment data capture is weak. But critics argue that the Ghanaian context is fundamentally different: ICUMS already ingests electronic manifest and declaration data; and all relevant government agencies already operate within the single window environment.

The question is not whether ACI systems can add value in principle; it is whether they add value in a market that has already built the infrastructure those systems are meant to provide.

The historical record compounds that scepticism. In February 2018, the Office of the President directed Ghana Revenue Authority to suspend implementation of the Cargo Tracking Note, determining that the information CTN sought to provide was already available on import manifests and the scheme would increase cost of doing business at Ghana's ports, contrary to the administration's competitiveness objectives.

That presidential intervention is now being cited by opponents of the current proposals as evidence that the underlying policy question has already been tested and conclusively rejected at the highest level of government.

The reappearance of the same concept under successive names CTN, ECTN, SPN, ACI has reinforced the perception among industry participants that what is being pursued is a revenue stream for private operators rather than a solution to a documented trade facilitation problem.

The governance dimensions of this current push add a further layer of concern. Four questions in particular are emerging among trade practitioners and policy observers: whether any new cargo-tracking system has been subject to competitive procurement; whether the Ministry of Transport holds the legal authority to approve a mandatory fee-bearing trade information system; whether the private sector and affected stakeholders have been meaningfully consulted; and whether any approved system would duplicate functions already embedded in ICUMS and funded through existing public expenditure.

There are also data-sovereignty concerns the technical note reviewed by this paper raises the prospect of Ghana's sovereign trade data being stored on servers in foreign jurisdictions and potentially accessible to third parties without adequate safeguards.