NTFF urges Customs to reconsider ICT fee on DGMS-registered Sea Cargo Manifest Reporting Users

• Moots rationalisation of Import Manifest Amendment penalties 

The National Trade Facilitation Forum (NTFF), representing stakeholders across Sri Lanka’s maritime, shipping and logistics trade, has appealed to Sri Lanka Customs Director General for the consideration and review of the new Customs ICT Fee applicable to DGMS-registered Sea Cargo Manifest Reporting Users under Gazette Extraordinary No. 2493/02, effective 1 July 2026, together with the existing manifest amendment penalty framework under Section 29 of the Customs Ordinance.

Industry cost burden and its link to State revenue

NTFF said manifest reporting is a private-sector function performed in the public interest: accurate advance manifest data is the primary input Customs uses for revenue protection, risk targeting, and detection of misdeclaration before cargo lands. The 833 DGMS-registered reporters carrying this function are not incidental intermediaries, they are the first-line data source underpinning Customs' own revenue and risk systems. Therefore, we respectfully submit that an increase of this scale, implemented within a short timeframe, warrants further consideration given its potential impact on landed import costs and export competitiveness across the wider economy.

The quantified increase

The DGMS annual licence fee to operate as a Service Provider is Rs. 12,000/year. To report manifests, users must now additionally pay a new recurring ICT Fee of Rs. 5,000/month (Rs. 60,000/year) a six-fold increase in fixed annual cost per provider. Applied across all 833 registered reporters, this moves the sector's total fixed annual compliance cost from approximately Rs. 10 million to approximately Rs. 60 million, an increase of roughly Rs. 50 million per annum, imposed with immediate effect and no transition period.

A mandatory statutory charge with no mechanism for cost recovery

The ASYHUB platform is a mandatory statutory reporting mechanism, rather than a discretionary commercial service. Sea-cargo manifest reporting arises under the Customs Ordinance (Chapter 235) and the applicable Electronic Cargo Manifest reporting framework, and is a necessary prerequisite to the subsequent Customs declaration and clearance process. It therefore constitutes a compulsory regulatory function for which users have no alternative service provider. Critically, without a valid Customs receipt for the ICT fee, service providers cannot legitimately recover the charge as a disbursement, leaving it as a non-recoverable regulatory overhead borne by the reporting entity.

Proposed alternative: A per-manifest charge

NTFF has requested that Customs consider restructuring this charge on a per-manifest/per-transaction basis rather than a flat recurring fee. A transaction-linked charge would scale fairly with actual usage, would be inherently receiptable and billable back against the specific shipment it relates to, and would directly reflect the value each manifest submission delivers as an input to Customs' revenue collection and risk management functions, rather than falling as a fixed cost regardless of volume.

The unresolved manifest amendment penalty

This compounds a longstanding, unresolved issue. Sri Lanka Customs’ own 2013 letter to CASA prescribed penalties of up to Rs. 100,000 per manifest amendment. In 2018, CASA, SLFFA, SLANA and CEYFFA jointly proposed a more proportionate framework, with a maximum penalty of Rs. 25,000 for major post-registration amendments. SLFFA reiterated this request in 2021, noting that excessive penalties could encourage manipulation detrimental to Government revenue integrity and legitimate trade. With manifest reporters now required to bear the additional recurring ICT Fee, we respectfully submit that the case for adopting the 2018 industry proposal is stronger than ever, providing a fairer and more proportionate amendment framework while encouraging accurate and transparent manifest reporting.

NTFF has requested the following:

• Reconsider the ICT Fee structure, moving from a flat recurring charge to a per-manifest/per-transaction basis;
• Issue an official receipt for any such charge, to enable legitimate cost recovery from shippers/consignees;
• Adopt, with immediate effect, the 2018 joint-association proposal to reduce manifest amendment penalties from the 2013 scale;
• Consult the NTFF and trade associations before further changes of comparable scale.

 NTFF said it fully supports Customs’ objective of maintaining secure and efficient digital systems and respectfully seek a fair, transparent and proportionate funding mechanism. Consistent with WTO TFA Article 6.2, fees for Customs processing should be limited to the approximate cost of the services rendered, while Article 6.1 calls for transparency and periodic review of fees and charges. The WCO RKC reflects the same cost-of-service principle for specified Customs services. We therefore respectfully request that the ICT Fee be reviewed to ensure it is cost-reflective, transparent and practically recoverable, and would welcome direct consultation with Customs on an equitable way forward, NTFF added.