Nohena Insights · Compliance
How to resolve a PAAR customs query in 2026
Effectively navigating a PAAR-related customs query requires a systematic approach to validating your declaration data against the NCS risk engine's criteria before lodgement.
Nohena · 14 October 2026 · 10 min read
How to resolve a PAAR customs query in 2026
Effectively resolving a Pre-Arrival Assessment Report query in 2026 requires a systematic response grounded in verifiable documentation that directly addresses the specific objection raised by the Nigeria Customs Service.
The PAAR system remains a cornerstone of Nigeria's import process, serving as the primary tool for risk assessment and preliminary duty calculation. For clearing agents and importers, a query raised against a PAAR is a critical event that can introduce delays and increase costs. Understanding the mechanics of these queries and preparing a defensible position is not just good practice; it is essential for efficient and predictable import clearance. This guide provides a practical framework for navigating PAAR-related customs queries, grounded in the regulations and operational realities of 2026.
What is the role of the PAAR in 2026?
The Pre-Arrival Assessment Report is the official risk and duty assessment document generated by the Nigeria Customs Service based on documents submitted by an importer through an authorized dealer bank.
Before any non-prohibited goods can be imported into Nigeria, an importer must process a Form M through an authorized dealer bank on the Nigeria Single Window for Trade portal. The importer, along with their supplier, provides key documents such as the proforma invoice. Once these are submitted, the NCS generates the PAAR. This report contains several critical pieces of information that guide the entire clearance process:
Customs value assessment : The NCS's opinion on the dutiable value of the goods.
HS code classification : The 10-digit tariff heading the NCS assigns to the goods based on the information provided.
Duty and tax estimation : A preliminary calculation of the import duty, levies, and 7.5% Value Added Tax (VAT) payable on the consignment.
Risk profile : An indication of the inspection level the consignment will likely undergo (e.g., green lane, blue lane, red lane).
The PAAR is not the final declaration; that is the Single Goods Declaration (SGD), which the licensed agent prepares for lodgement. However, the PAAR sets the stage. Any significant deviation between the SGD and the PAAR is a primary trigger for a customs query.
Why PAAR-related customs queries arise
Customs queries on a PAAR or the subsequent declaration typically arise from perceived discrepancies between the importer's data and the information held within the customs risk engine.
The NCS B'Odogwu risk management system automatically flags declarations that deviate from established norms or contain inconsistencies. Understanding these triggers is the first step toward prevention. Common reasons for a query include:
Valuation disputes : This is the most frequent cause. A query is likely if the declared customs value on the commercial invoice is significantly lower than the reference values stored in the NCS database for similar items. While the WTO Agreement on Customs Valuation (to which Nigeria is a signatory) prioritizes transaction value, customs authorities retain the right to challenge values they suspect are not accurate.
HS code disagreements : The importer's agent may classify a product under a 10-digit HS code with a lower duty rate, while the customs officer, based on the product's description or technical specifications, believes a different code with a higher rate is more appropriate. The Nigerian tariff is based on the ECOWAS Common External Tariff (CET), which features duty bands from 0% to 35%.
Inconsistent documentation : Any mismatch of information across the commercial invoice, packing list, bill of lading, Form M, and the PAAR itself will raise a red flag. This includes differences in weight, quantity, product descriptions, or parties involved.
Rules of origin claims : For goods imported under preferential trade agreements like the ECOWAS Trade Liberalisation Scheme (ETLS) or the African Continental Free Trade Area (AfCFTA), a query may be raised to challenge the proof of origin. For AfCFTA, for instance, goods must meet specific criteria, often involving a regional value content of around 40%, to qualify for reduced or zero tariffs. Failure to provide a valid certificate of origin will lead to the application of standard MFN duty rates plus levies like the 0.5% ETLS levy.
Regulatory compliance gaps : If the imported goods require certification from a Partner Government Agency (PGA), the absence or invalidity of such a certificate will trigger a query. This includes SONCAP certificates for regulated products or NAFDAC permits for food, drugs, and cosmetics.
A systematic approach to resolving a customs query
A successful resolution to a customs query depends on a methodical, evidence-based response presented through official channels.
When a query is raised, panic or informal negotiations are counterproductive. A structured approach demonstrates professionalism and provides the best chance of a favorable outcome. Follow these steps:
Deconstruct the query : First, understand the exact nature of the objection. Is it about value, classification, quantity, or documentation? The query notice from the customs system should state the specific reason for the intervention. Do not guess.
Compile your evidence : Gather all documents that support your original declaration. For a valuation query, this could include the commercial invoice, proof of payment (telegraphic transfer), the sales contract, and correspondence with the supplier that validates the transaction value. For a classification query, you may need technical datasheets, product catalogues, or a detailed breakdown of the product's composition and use.
Draft a formal response : Write a clear and concise letter addressed to the proper officer or customs command. Reference the query number, the declaration number, and the specific issue. State your position clearly and attach copies of all your supporting evidence. The goal is to make it easy for the officer to understand and accept your justification.
Communicate through the system : Submit your response and documentation through the official trade portal. This ensures there is a formal record of your correspondence. While direct communication with the officer handling the query may be necessary, it should supplement, not replace, the formal process.
Prepare for escalation : If the query is not resolved at the initial level, be prepared to escalate it to the next authority in the command structure, such as the Customs Area Controller. A well-documented initial response provides a strong foundation for any subsequent appeal.
Proactive strategies to minimise PAAR queries
The most effective way to handle a customs query is to prevent it from being raised in the first place through meticulous pre-lodgement preparation.
A proactive compliance strategy significantly reduces the likelihood of costly delays. By treating every declaration as if it will be audited, you can identify and resolve potential issues before they become problems. Consider these strategies:
Conduct a thorough pre-lodgement review : Before your agent prepares the SGD for lodgement, conduct a comprehensive review of all trade documents. Cross-verify the details on the Form M, commercial invoice, packing list, and transport document. Decision support platforms that analyze declaration data against customs risk parameters can provide foresight into potential flags. Find more analysis in our insights section .
Justify your valuation : If you are importing goods at a price that you know is significantly below market averages, prepare your justification in advance. This could be due to a bulk purchase discount, an end-of-line clearance sale, or a long-standing relationship with the supplier. Have the documentation ready to prove it. Remember to correctly account for all dutiable additions to the price, such as freight and insurance, as outlined in Article 8 of the WTO Valuation Agreement. If insurance is not specified, customs will apply a default of 1.5% of the invoice value.
Ensure correct and defensible classification : Invest the time to classify your goods correctly to the full 10-digit HS code level. If a product is complex or its classification is ambiguous, document your reasoning based on the General Interpretative Rules (GIRs), CET explanatory notes, and any available customs rulings.
Maintain complete documentation : Ensure all required certificates, permits, and proofs of origin are valid, complete, and readily available at the time of declaration. Pay close attention to the expiration dates and specific requirements of agencies like SONCAP and NAFDAC.
Decision framework: To accept an uplift or to contest
Deciding whether to accept a customs uplift or contest a query requires a careful evaluation of cost, time, and principle.
When customs challenges your declared value or classification, they will propose an alternative, which almost always results in a higher duty payment (an uplift). You have two choices: accept the uplift and get your goods released quickly, or contest the query and defend your declaration. Neither choice is universally correct; the right decision depends on your specific circumstances.
The following table provides a framework for making this decision:
Your decision should be a calculated one. If the uplift amount is small, the goods are urgently needed, and your supporting evidence is weak, accepting the uplift may be the pragmatic commercial choice. However, if the uplift is substantial, you have strong evidence, and the item is a regular import, contesting the query is crucial for establishing a correct and defensible long-term precedent. A service that prepares a lodgement-ready declaration pack gives the agent the foresight needed to make this decision from a position of strength.
FAQ
What is the primary cause of a PAAR query?
Discrepancies in customs valuation are the most frequent cause of PAAR-related queries. This happens when the declared value of goods is significantly lower than the reference values maintained in the Nigeria Customs Service database for similar products. HS code misclassification and incomplete or inconsistent documentation are also common triggers.
Can I amend a PAAR once it is issued?
No, an agent or importer cannot directly amend a PAAR after it has been issued by the Nigeria Customs Service. The PAAR is an assessment report from customs, not the agent's declaration. If you identify an error on the PAAR or need to make a correction, you must address it by raising a query or using the post-clearance amendment process, providing strong justification for the requested change.
How long does it take to resolve a customs query?
The time to resolve a customs query can vary significantly. A straightforward query with clear, readily available supporting evidence might be resolved within a few working days. However, more complex disputes, particularly those concerning valuation or tariff classification, can take several weeks, especially if the issue needs to be escalated through the customs command structure.
What is the difference between the PAAR and the SGD?
The PAAR (Pre-Arrival Assessment Report) is the risk and duty assessment document generated by the NCS based on your initial documents submitted via Form M. The SGD (Single Goods Declaration) is the formal, detailed declaration that your licensed clearing agent prepares and lodges with customs to process the clearance of your goods. The PAAR serves as a guide and risk indicator for the SGD, and discrepancies between the two often lead to queries.