Nohena Insights · Compliance
How a customs query impacts your PAAR and demurrage
A customs query stops your Pre-Arrival Assessment Report (PAAR) from being issued, which in turn halts the entire clearance process and starts the clock on costly demurrage and storage fees.
Nohena · 1 November 2026 · 9 min read
How a customs query stops clearance and starts the cost clock
A customs query halts the issuance of your Pre-Arrival Assessment Report (PAAR), which is the critical document required to proceed with clearance, directly causing delays that lead to demurrage and storage charges.
For any importer or licensed agent in Nigeria, the moment a customs query appears on a declaration is the moment the clearance process freezes. It signifies that the Nigeria Customs Service (NCS) requires more information or has identified a potential discrepancy. While a query is a standard part of the compliance process, its effect on your timeline and budget can be substantial. Understanding the connection between a query, the PAAR, and the demurrage clock is fundamental to managing import costs and client expectations.
This analysis breaks down the mechanics of a customs query, its direct impact on the PAAR, and the resulting financial consequences. We will examine the common triggers for queries and outline a framework for preparing declarations to minimize their occurrence and impact. For more analysis on trade compliance topics, you can explore our insights archive .
What triggers a customs query?
A customs query is typically triggered by inconsistencies, omissions, or suspected under-valuations detected by the Nigeria Customs Service during its automated and manual review of your Form M and supporting documents.
The NCS risk management system assesses every declaration against a complex set of criteria. When a declaration is flagged, it is routed for manual review by a customs officer, who may then issue a query. The goal of the query is to resolve ambiguity before a final duty assessment is made. The most common triggers fall into several distinct categories.
Valuation discrepancies. This is perhaps the most frequent cause. If the declared customs value of your goods is significantly lower than the value of identical or similar goods in the customs valuation database, a query is almost certain. This process is guided by the principles of the World Trade Organization's Agreement on Customs Valuation, which stipulates that the transaction value should be the primary basis for valuation, but allows customs administrations to challenge it under specific circumstances. A query may request further proof of payment, the commercial contract, or other evidence to substantiate the declared value.
HS code classification errors. The Harmonized System (HS) code determines the rate of duty applied to your goods. A mistake in classification can lead to a significant loss of revenue for the government. Queries often arise when the goods description seems inconsistent with the declared 10-digit HS code under the ECOWAS Common External Tariff (CET). For example, declaring a multi-function printer under the code for a simple scanner could trigger a query to clarify the item's principal function, as guided by the General Interpretative Rules (GIRs) of the HS nomenclature.
Incomplete or conflicting documentation. Every document in your submission pack must be consistent. A query can be raised for simple errors like a mismatch in the consignee's name between the bill of lading and the Form M, an invalid or expired SONCAP certificate for regulated products, or a failure to provide a NAFDAC permit for food and drug items. The use of vague descriptions like 'general goods' or 'parts' without further specification is also a common red flag.
Rules of origin and preferential trade. For goods imported under preferential agreements like the ECOWAS Trade Liberalization Scheme (ETLS) or the African Continental Free Trade Area (AfCFTA), strict rules of origin apply. A query may be issued to demand a valid certificate of origin or to challenge the certificate if the goods do not appear to meet the origin criteria, such as the minimum 40% regional value content required for many products under AfCFTA.
The direct financial impact of a customs query
The direct financial impact of a customs query comes from terminal handling, storage, and shipping line demurrage charges that accumulate for each day your cargo remains at the port beyond the free period.
When a container is discharged at a Nigerian seaport, a 'free period' begins. This is a limited number of days, typically three to seven, during which the terminal operator and shipping line will not charge for storage or container use. The goal is to complete clearance and take delivery of the container within this window. A customs query makes this goal exceptionally difficult to achieve.
The financial consequences multiply quickly:
Shipping line demurrage. This is a fee charged by the shipping company for the continued use of their container beyond the free days. It is intended to incentivize the quick return of equipment. Demurrage is often charged on a progressive scale; for example, days 1-5 past the free period might be N20,000 per day, while days 6-10 could escalate to N30,000 per day.
Port storage charges. This is a separate fee charged by the terminal operator for occupying space on their premises. Like demurrage, it is calculated daily and often increases over time. These charges begin accumulating as soon as the terminal's free days expire.
Increased operational costs. Resolving a query requires time and effort from your licensed agent, which may translate into higher service fees. It also consumes the importer's own administrative resources, diverting attention from core business activities.
Consider a shipment that receives a query on day two after discharge. If it takes seven days to gather the necessary documents, submit a response, and have the query resolved by customs, the PAAR might not be issued until day nine. By then, the free period has likely expired, and several days of both demurrage and storage charges have already accrued before you can even pay duties and position the container for examination.
How a customs query freezes the PAAR process
A customs query places a hold on your PAAR application within the Nigeria Single Window for Trade, preventing the issuance of the assessment report needed to pay duties and proceed to examination.
The PAAR is the central control document in Nigeria's modern clearance process. It is an electronically issued report that contains the final determination of the NCS on three key elements of your import:
The customs value of the goods.
The final HS code classification.
The resulting duties and taxes to be paid, including import duty (ranging from 0% to 35% under the ECOWAS CET), 7.5% Value Added Tax (VAT), and other applicable levies like the 0.5% ETLS levy.
Without an issued PAAR, you cannot generate the Single Goods Declaration (SGD) for duty payment. The process is strictly sequential:
The importer or agent submits a Form M and all supporting documents (proforma invoice, insurance certificate, etc.) through the trade portal to apply for a PAAR.
The NCS PAAR Ruling Centre reviews the submission. If a discrepancy is found, a customs query is issued, and the application's status is put on hold.
The agent or importer is notified and must submit a response to the query through the same portal, often with additional supporting evidence.
The NCS officer reviews the response. If it is satisfactory, the query is resolved, and the PAAR is generated and issued. If not, the officer may ask for more information or make a final determination, which could include an 'uplift' in the customs value.
Only after the PAAR is issued can the agent proceed to the next stage: capturing the SGD, making the final duty payment to the bank, and scheduling the physical examination of the cargo.
A query, therefore, acts as a complete stop. The entire clearance chain is paused, while the demurrage and storage clocks at the terminal continue to run.
Proactive steps to prepare for query-prone declarations
To minimize the risk of a customs query, practitioners should conduct a thorough pre-lodgement review of all documentation, focusing on valuation justification, HS code accuracy, and document consistency.
While no process can guarantee a query-free declaration, a structured and defensive approach to preparation can significantly lower the probability. This involves anticipating the questions a customs officer might ask and having the answers ready. A rigorous pre-lodgement review, using decision support to see the declaration as a risk engine might, is the most effective defense.
Consider adopting a two-tiered approach to your declaration preparation, distinguishing between standard and high-risk shipments.
By identifying potentially high-risk declarations upfront, you can invest the necessary time to build a defensible document package. This proactive stance does not just prepare you to respond to a query quickly; it often prevents the query from being raised in the first place.
Nohena prepares a lodgement-ready declaration and document pack; the licensed agent lodges.
FAQ
What is the difference between a customs query and an alert?
A customs query is a formal stoppage of the declaration process that requires a direct response from the agent or importer to proceed; it prevents the PAAR from being issued. An alert, on the other hand, is a flag raised by the system that may not halt the PAAR but will likely subject the consignment to a higher level of scrutiny, such as 100% physical examination, after duty has been paid.
How long do I have to respond to a customs query?
There is no single statutory deadline for responding, but from a practical and financial standpoint, the response should be immediate. Every day of delay directly translates into accumulating demurrage and storage costs. The Nigeria Single Window for Trade provides the platform for the response, and agents should treat it with the highest urgency.
Can I contest a PAAR uplift after a query?
Yes, an importer has the right to formally appeal an uplift in customs value or a re-classification of the HS code. However, this is typically a post-clearance action that can be complex and time-consuming. To avoid incurring further demurrage, the common practice is to pay the assessed duties to secure the release of the cargo and then pursue the dispute resolution process with the NCS afterwards.
Does using a licensed customs agent prevent all queries?
Engaging a competent and experienced licensed customs agent significantly reduces the likelihood of errors that lead to queries, as they are professionals trained in tariff, valuation, and customs procedures. However, it does not offer a complete guarantee. The ultimate responsibility for providing complete and accurate information rests with the importer, and even the most diligent agent can face a query on a particularly complex, novel, or contentious shipment.