EXIM Frozen Foods Association Opposes Proposed Reintroduction of Smart Port Note System

Michael Obiri-Adjei, EFFAG Executive Secretary

The Exim Frozen Foods Association of Ghana (EFFAG) has urged the Ministry of Transport to reject any efforts to reintroduce the Cargo Tracking Note (CTN), also known as the Smart Port Note (SPN), arguing that the system would impose significant additional costs on businesses and consumers.

In a statement signed by its Executive Secretary, Michael Obiri-Adjei, the association questioned a recent campaign by a group identified as the Concerned Traders Association of Ghana, which has reportedly advocated for the return of the CTN/SPN regime.

EFFAG described the group as unfamiliar to the wider trading community and challenged its support for a system that, according to the association, has faced opposition from importers, exporters, freight forwarders, logistics operators and civil society groups for more than a decade.

Association Raises Concerns Over Additional Costs

The association argued that the CTN/SPN system would introduce new charges and administrative requirements for traders without delivering measurable benefits to cargo clearance or trade facilitation.

According to EFFAG, the primary purpose of the proposed system is to collect shipping data for the Ghana Shippers’ Authority (GSA), a function it says should be financed through the authority’s existing internally generated funds rather than through additional fees imposed on importers and exporters.

The group further questioned the reported partnership between the GSA and the Inter-Ocean Maritime and Logistics Institute (IOMLI), arguing that the arrangement appears inconsistent with the authority’s mandate to protect the interests of shippers.

EFFAG contended that the CTN/SPN initiative appears to be designed primarily as a revenue-generating mechanism rather than a trade-facilitation tool.

Projected Economic Impact
The association estimated that implementation of the CTN/SPN could cost Ghanaian shippers between €187.2 million and €382.8 million annually.

According to EFFAG, the estimate is based on Ghana’s 2024 container traffic volume of 1.7 million Twenty-Foot Equivalent Units (TEUs) and fee structures previously proposed during earlier attempts to introduce the system.

The association noted that the calculation only considers full-container-load cargo and excludes other cargo categories, suggesting that the overall economic impact could be higher.

EFFAG argued that the additional costs would ultimately be transferred to consumers through higher prices for imported goods.

Concerns Over Duplication and Bureaucracy

The association maintained that the Smart Port Note duplicates functions already performed by existing systems, including the Integrated Customs Management System (ICUMS) and the Ghana Integrated Cargo Clearance System (GICCS).

It warned that reintroducing the system could add administrative layers to cargo clearance procedures, increase transaction costs and create opportunities for delays.

"The CTN/SPN does not solve any identifiable problem within Ghana’s port ecosystem," the statement said, adding that the proposal risks reversing progress made in modernising trade and logistics operations.

Trade Facilitation Concerns
EFFAG further argued that the proposed system is inconsistent with international trade facilitation objectives, including those promoted under the African Continental Free Trade Area (AfCFTA) and the World Trade Organization’s Trade Facilitation Agreement.

The association cautioned that additional clearance requirements could weaken Ghana’s competitiveness as a regional trade hub, particularly in comparison with neighbouring ports in Togo and Côte d’Ivoire.

Calls to Government
The association called on Minister of Transport Joseph Bukari Nikpe to reject any proposal to revive the CTN/SPN system and instead focus on strengthening existing digital platforms and addressing long-standing concerns raised by traders.

Among its recommendations, EFFAG urged the government to:

• Resist pressure to reintroduce the CTN/SPN;
• Support internal digitalisation initiatives within the Ghana Shippers’ Authority;
• Enforce measures aimed at eliminating what it described as illegitimate port-related charges;
• Continue strengthening existing systems such as ICUMS for cargo tracking and revenue assurance.

Focus on Existing Trade Challenges
The association concluded by encouraging stakeholders to focus on broader challenges affecting traders, including reducing port bottlenecks, eliminating unlawful charges and improving operational efficiency across the trade and logistics sector.

EFFAG said it remains willing to collaborate with industry groups and policymakers on reforms that reduce costs and improve the ease of doing business but reiterated its opposition to the proposed reintroduction of the CTN/SPN system.