On January 1st 2018, the Federal Government of Nigeria commenced the implementation of the 2017 Revised Import1 and Export2 guidelines. The implementation of the guidelines is in line with the government's efforts to improve international trade whilst enhancing the ease of doing business in Nigeria.

The following are key provisions in the revised guidelines:

1. Reduction of Documentation

The required documentation for exports and imports has been reduced from ten (10) to seven (7) and from fourteen (14) to eight (8) respectively.3

2. Palletization of all Cargoes

2.1 Due to goods being shipped into Nigeria which are usually stacked haphazardly without pallets thereby making physical examination impractical or unduly tedious, the guidelines provides that shipping lines are required to ensure that containerized cargoes bound for Nigeria are palletized.4

2.2 Palletization is the process of placing or anchoring the consignment to a pallet or base made of wood or metal. Goods on a pallet may be secured with strappings, stretch wrap or shrink wrap. This method allows for easier handling and storage of the goods. The advantages are a drastic reduction in storage costs as well as a reduced time frame for loading and unloading operations which was otherwise popular in the era of containerization. Palletization also enables efficient examination of the consignments.

3. Complaints and Detriments of the Palletization Policy

3.1 Importers and stakeholders have expressed dissatisfaction regarding the new palletization policies. Some of these complaints are as follows:

  1. The Federal Government's new policy on cargo palletization could cost Nigerian importers $60 million dollars5 and cost the economy over N500 billion annually.6
  2. The palletization policy would increase rather than reduce the need for manual cargo examination due to the non-deployment of the required technological input to aid the palletization process. Such inputs include; scanning machines, automated customs processes and good access to the ports.7
  3. Palletization takes up a lot of space. Cargoes to be freighted in one container will have to be divided and importers will have to pay increased freight charges for fewer amounts of goods.8
  4. Fragile goods and liquids cannot be packed on wooden pallets and it may encourage the diversion of cargo to neighboring countries which will in turn, aid corruption.
  5. Palletization on wooden pallets could attract importation of strange organisms into Nigeria if not specially treated.
  6. It may lead to importers reverting to the era of Unimodal means of transportation thereby reducing the amount of cargoes that come through the Nigerian seaports.
  7. Loss of revenue for the Government.9

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* Adetola Ayanru, [Senior Associate], and Oluwasolape Owoyemi, [Associate] SPA Ajibade & Co., Lagos, NIGERIA.


1 http://www.finance.gov.ng/images/docs/ImportGuidelines2013.pdf ; and


2 http://www.finance.gov.ng/images/docs/EXPORTGUIDELINESNONOIL.pdf.

3 http://www.finance.gov.ng/images/docs/reductionImportExport.pdf.

4 Section H(5) Ministry of Finance Revised Import Guidelines, procedures and documentation requirements under the destination inspection scheme in Nigeria (December 2017).

5 http://punchng.com/cargo-policy-maritime-operators-fret-as-fg-threatens-defaulters/ accessed 19th February 2018.

6 https://guardian.ng/news/nigeria-may-lose-n500-billion-yearly-to-new-cargo-policy/ accessed 3rd February 2018.

7 https://guardian.ng/business-services/maritime/deficient-scanners-and-controversial-cargo-policy/ accessed 19th February 2018.

8 Ibid.

9 Ibid.

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