Stakeholders Welcome Suspension of 4% FOB Levy, Call for 1% CISS Reinstatement
By Francis Ugwoke
The Sea Empowerment and Research Center (SEREC), a group made up major stakeholders in the shipping industry, on Wednesday applauded the federal government for the suspension of the 4percent Free-on-Board (FOB) levy.
The group however called for the reinstatement of the 1% Comprehensive Import Supervision Scheme (CISS) levy as an interim measure.
In a press statement signed by the Head of Research, Fwdr. Eugene Nweke, Rff, the group noted that the directive amounts to only a temporary pause since the levy remains enshrined in the Nigeria Customs Service Act, 2023.
Nweke said that to ensure clarity and stability in trade administration, the federal government should reinstate the 1% CISS levy as an interim measure, and engage the National Assembly to amend the law and align statutory provisions with stakeholder-accepted revenue options.
He said that clear and consistent directives will safeguard revenue, build stakeholder trust and strengthen Nigeria’s trade environment.
He argued that the “suspension highlights a classic clash between law and policy, where fiscal needs, trade facilitation and inflation management intersect.
“While the FMF has provided short-term relief, the underlying legal provision ensures that the debate over the 4% FOB levy will persist until a sustainable and equitable funding alternative is institutionalized”, he said.
He noted that the Federal Ministry of Finance (FMF) which announced the suspension of the FOB has the statutory supervisory and coordinating authority over the Nigerian Customs Service (NCS).
The SEREC statement added: “the suspension directive reflects political sensitivity to the impact of the 4% FOB levy on import costs, inflation, and business competitiveness.
“ It signals government responsiveness to stakeholder pushback—importers, trade groups, and consumers.
“ Legal / Institutional Dimensions:
“ The Customs Service Act, 2023 (Section 18(1)(a)) provides for “not less than 4% of FOB” as a statutory funding source for NCS.
“ The Minister of Finance (also Board Chair) holds overriding powers under the Act (Part III, Section 12) to direct, regulate, and suspend implementation.
“ This creates a legal paradox:
“ On one hand, the levy is enshrined in law.
“ On the other, the Minister can suspend its implementation (not repeal it).
“ Thus, the suspension is administrative, not legislative—temporary, pending a broader review”.
Nweke noted that the suspension is positive for traders/importers as relief from an additional cost burden amid high inflation and forex volatility.
On the short-term revenue gap for Customs, he said the suspension could strain operational finances unless alternative funding is provided.
He pointed out that this will help ease inflationary pressure and prevent passing extra costs to consumers.
He also described the policy uncertainty risk, adding traders may perceive regulatory flip-flops as a risk to business planning.
Part of the statement reads:
AN ADVISORY NOTE ON THE SUSPENSION OF 4% FOB LEVY BY THE FEDERAL MINISTRY OF FINANCE.
Dated: 17th September, 2025
Following the directive of the Honourable Minister of Finance and Coordinating Minister of the Economy, in his capacity as Chairman of the Board of the Nigeria Customs Service (NCS), to suspend the implementation of the 4% Free-on-Board (FOB) levy, the Sea Empowerment and Research Center (SEREC) offers the following advisory observations for policy clarity and operational consistency:
1. Nature of the Directive:
The Ministry’s order amounts to an administrative suspension of the 4% FOB levy. However, since the levy is provided for under Section 18(1)(a) of the Nigeria Customs Service Act, 2023, it remains legally in force until amended by the National Assembly. Hence, the use of such choice administrative word as “suspension” and not removal.
2. Policy Coordination Gap:
Historically, the NCS had imposed both the 1% Comprehensive Import Supervision Scheme (CISS) levy and the 4% FOB. Following stakeholder outcry, adjustments were made—first suspending the 4%, later replacing the 1% CISS with 4% FOB. The current suspension of 4% FOB, without reinstating the 1% CISS, creates a policy vacuum that may disrupt revenue flow and confuse stakeholders, as the an official suspension circular from the NCS management team to area comptrollers and their respective area project manager – APM /technical supervisors -TS has not been communicated.
3. Recommended Consistent Approach:
Officially reinstate the 1% CISS levy as an interim funding mechanism, given that industry stakeholders have expressed no objection to it.
Initiate legislative engagement with the National Assembly to review and amend the NCS Act, thereby aligning statutory provisions with practical and stakeholder-accepted revenue measures.
Communicate clearly with the trading community to avoid uncertainty, sustain trust, and ensure smooth Customs modernization efforts.
4. Conclusion:
While the suspension reflects government responsiveness to stakeholder concerns, coherent fiscal administration requires that revenue directives be consistent, transparent, and legally grounded.
A synchronized approach—suspending 4% FOB, reinstating 1% CISS, and initiating statutory amendment—will preserve policy credibility, support Customs modernization, and enhance Nigeria’s trade environment.
Thank you for your attention.
For: Sea Empowerment and Research Center (SEREC)
Fwdr. Eugene Nweke, Rff
Head of Research.
The Sea Empowerment and Research Center (SEREC), a group made up major stakeholders in the shipping industry, on Wednesday applauded the federal government for the suspension of the 4percent Free-on-Board (FOB) levy.
The group however called for the reinstatement of the 1% Comprehensive Import Supervision Scheme (CISS) levy as an interim measure.
In a press statement signed by the Head of Research, Fwdr. Eugene Nweke, Rff, the group noted that the directive amounts to only a temporary pause since the levy remains enshrined in the Nigeria Customs Service Act, 2023.
Nweke said that to ensure clarity and stability in trade administration, the federal government should reinstate the 1% CISS levy as an interim measure, and engage the National Assembly to amend the law and align statutory provisions with stakeholder-accepted revenue options.
He said that clear and consistent directives will safeguard revenue, build stakeholder trust and strengthen Nigeria’s trade environment.
He argued that the “suspension highlights a classic clash between law and policy, where fiscal needs, trade facilitation and inflation management intersect.
“While the FMF has provided short-term relief, the underlying legal provision ensures that the debate over the 4% FOB levy will persist until a sustainable and equitable funding alternative is institutionalized”, he said.
He noted that the Federal Ministry of Finance (FMF) which announced the suspension of the FOB has the statutory supervisory and coordinating authority over the Nigerian Customs Service (NCS).
The SEREC statement added: “the suspension directive reflects political sensitivity to the impact of the 4% FOB levy on import costs, inflation, and business competitiveness.
“ It signals government responsiveness to stakeholder pushback—importers, trade groups, and consumers.
“ Legal / Institutional Dimensions:
“ The Customs Service Act, 2023 (Section 18(1)(a)) provides for “not less than 4% of FOB” as a statutory funding source for NCS.
“ The Minister of Finance (also Board Chair) holds overriding powers under the Act (Part III, Section 12) to direct, regulate, and suspend implementation.
“ This creates a legal paradox:
“ On one hand, the levy is enshrined in law.
“ On the other, the Minister can suspend its implementation (not repeal it).
“ Thus, the suspension is administrative, not legislative—temporary, pending a broader review”.
Nweke noted that the suspension is positive for traders/importers as relief from an additional cost burden amid high inflation and forex volatility.
On the short-term revenue gap for Customs, he said the suspension could strain operational finances unless alternative funding is provided.
He pointed out that this will help ease inflationary pressure and prevent passing extra costs to consumers.
He also described the policy uncertainty risk, adding traders may perceive regulatory flip-flops as a risk to business planning.
Part of the statement reads:
AN ADVISORY NOTE ON THE SUSPENSION OF 4% FOB LEVY BY THE FEDERAL MINISTRY OF FINANCE.
Dated: 17th September, 2025
Following the directive of the Honourable Minister of Finance and Coordinating Minister of the Economy, in his capacity as Chairman of the Board of the Nigeria Customs Service (NCS), to suspend the implementation of the 4% Free-on-Board (FOB) levy, the Sea Empowerment and Research Center (SEREC) offers the following advisory observations for policy clarity and operational consistency:
1. Nature of the Directive:
The Ministry’s order amounts to an administrative suspension of the 4% FOB levy. However, since the levy is provided for under Section 18(1)(a) of the Nigeria Customs Service Act, 2023, it remains legally in force until amended by the National Assembly. Hence, the use of such choice administrative word as “suspension” and not removal.
2. Policy Coordination Gap:
Historically, the NCS had imposed both the 1% Comprehensive Import Supervision Scheme (CISS) levy and the 4% FOB. Following stakeholder outcry, adjustments were made—first suspending the 4%, later replacing the 1% CISS with 4% FOB. The current suspension of 4% FOB, without reinstating the 1% CISS, creates a policy vacuum that may disrupt revenue flow and confuse stakeholders, as the an official suspension circular from the NCS management team to area comptrollers and their respective area project manager – APM /technical supervisors -TS has not been communicated.
3. Recommended Consistent Approach:
Officially reinstate the 1% CISS levy as an interim funding mechanism, given that industry stakeholders have expressed no objection to it.
Initiate legislative engagement with the National Assembly to review and amend the NCS Act, thereby aligning statutory provisions with practical and stakeholder-accepted revenue measures.
Communicate clearly with the trading community to avoid uncertainty, sustain trust, and ensure smooth Customs modernization efforts.
4. Conclusion:
While the suspension reflects government responsiveness to stakeholder concerns, coherent fiscal administration requires that revenue directives be consistent, transparent, and legally grounded.
A synchronized approach—suspending 4% FOB, reinstating 1% CISS, and initiating statutory amendment—will preserve policy credibility, support Customs modernization, and enhance Nigeria’s trade environment.
Thank you for your attention.
For: Sea Empowerment and Research Center (SEREC)
Fwdr. Eugene Nweke, Rff
Head of Research.
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