Customs valuation, publican AI, future of Ghanaian industry

Ghana has repeatedly searched for a credible answer to one persistent question: how should the state determine the true value of imports without undermining legitimate international trade? 

From manual assessment after independence, through pre-shipment inspection, destination inspection, the GCNet/National Single Window era, the Pre-Arrival Assessment Report System (PAARS), the Integrated Customs Management System (ICUMS) and now Publican AI, each reform has promised greater accuracy, speed and revenue assurance. 
Publican AI should, therefore, be seen not as an isolated controversy, but as the latest chapter in a long struggle over customs valuation.

The recent debate has understandably been framed around technology. Importers and freight forwarders worry about opaque algorithmic assessments; the Ghana Revenue Authority (GRA) argues that stronger tools are needed to address under-declaration, misclassification and incorrect country-of-origin claims.

Yet, beneath the technology question lies the older and more difficult issue of valuation method: when should customs accept declared transaction values, when should it question them and how should reference data or AI-assisted risk indicators be used without becoming arbitrary assessments?

These concerns deserve attention. But the deeper problem is not simply technological.

It is institutional.

Valuation tools have changed over the decades, but many underlying behaviours have remained stubbornly familiar.

The apparent tension between importers and customs often masks a more complex reality: dutiable value negotiation, political influence and varying levels of import documentation scrutiny. 

Large importers may have the resources, relationships and transaction volumes to contest valuations more effectively.

Smaller enterprises, by contrast, often face the full force of customs vigilance with less bargaining power and weaker capacity to absorb processing delays or value uplifts.

Transaction value dilemma

This matters for enterprise and entrepreneurial development in Ghana.

Customs valuation is not a narrow border procedure. It shapes landed cost, selling price, working capital, market entry decisions and the entrepreneur’s assessment of whether a business opportunity is viable. 

When identical or similar goods attract widely different assessed values within comparable timeframes, the effect is unfair competition.

At the centre of the problem lies the WTO principle of “transaction value”.

In simple terms, imported goods should normally be valued based on the price actually paid or payable when sold for export, subject to permitted adjustments.

The principle is intended to support a fair, neutral and uniform valuation system, while preventing arbitrary or fictitious values.

Ghana’s difficulty is that the transaction value principle has collided heavily with widespread under-invoicing.

In my 2024 doctoral fieldwork on import valuation and firm-level entrepreneurship, customs respondents estimated that a very high proportion of commercial import declarations were inaccurate. 

They also contrasted Ghana’s situation with more compliant trading environments, citing South Korea as an example where, in their view, only a small share of declarations becomes contentious.

The figures may be debated, but the reality is familiar to many actors at the port: Customs is overwhelmed by suspicious declarations and, therefore, leans heavily on a database of reference values.

Reference values are not inherently improper.

The World Customs Organisation (WCO) recognises valuation databases as useful risk-assessment tools.

The problem arises when they become substitutes for transaction value, minimum thresholds or an unexplained basis for value uplift.

In practice, traders may experience the system as a “black box” of sorts: import invoices are accepted in some cases, uplifted in others and the reasons are not always clear enough to command confidence.

Publican AI may help Customs detect questionable values and reduce valuation inconsistency.

But it will succeed only if it produces transparency rather than a more sophisticated “black box”. 

The issue is not whether Ghana should use technology at the ports.

It is whether technology can support rules-based valuation governance: one that confronts under-invoicing without creating arbitrary assessment, preferential treatment or renewed uncertainty for legitimate enterprise.

The writer, (PhD), is a business executive, entrepreneur, consultant focused on customs valuation, trade facilitation and enterprise development.