From PAARS to Publican AI: Ghana's Long Battle to Get Customs Valuation Right

Every few years, Ghana introduces a new system at the ports and declares that the problem of customs valuation has finally been solved. The names change — pre-shipment inspection, GCNet, PAARS, ICUMS, and now Publican AI — but the fundamental tension remains: how does the state determine the true value of imported goods without creating an arbitrary, opaque or easily manipulated process? The latest controversy surrounding Publican AI is not a new story. It is, in many ways, the same old story wearing newer clothes.

What the Publican AI debate is really about

On the surface, the dispute over Publican AI looks like a technology argument. Importers and freight forwarders have raised concerns about algorithmic assessments that are difficult to scrutinise or challenge. The Ghana Revenue Authority (GRA), for its part, maintains that more powerful tools are necessary to tackle persistent problems of under-declaration, misclassification and false country-of-origin claims — all of which cost the state significant revenue each year.

But experts who have studied the issue closely argue that the technology is not the root of the problem. The deeper issue is institutional. The core principle at stake is the World Trade Organisation's concept of transaction value — the idea that imported goods should be assessed based on the price actually paid or agreed upon at the point of export, with limited adjustments permitted. This principle is designed to ensure fair, neutral and predictable valuation across borders.

Ghana's challenge is that transaction value has repeatedly collided with a well-documented culture of under-invoicing. Doctoral fieldwork conducted in 2024 on import valuation and firm-level entrepreneurship found that customs officials themselves estimated that a very high proportion of commercial import declarations were inaccurate. One comparison made by respondents was instructive: they contrasted Ghana's situation with trading environments like South Korea, where contentious declarations are reportedly far rarer. Whether or not those specific figures are precise, the broader picture is widely recognised by anyone familiar with operations at Tema Port — customs officials are overwhelmed by suspicious documentation and have therefore come to rely heavily on internal reference value databases to guide their assessments.

Reference databases are not inherently improper. The World Customs Organisation acknowledges their usefulness as risk-assessment tools. The problem arises when they quietly replace transaction value as the default measure, effectively becoming minimum thresholds that traders must meet regardless of what their actual invoices say. When that happens, the system stops being rules-based and starts feeling, to those on the receiving end, like a black box.

Why it matters for Ghana's businesses and entrepreneurs

This debate might seem like a technical matter confined to port operations, but its consequences ripple far beyond the harbour gates. Customs valuation directly shapes the landed cost of goods, and landed cost determines selling prices, working capital requirements and the fundamental question of whether a business idea is worth pursuing in the first place.

When two importers bring in identical goods within a similar period and receive markedly different assessed values — with no clear explanation — the result is unfair competition. Larger, well-connected importers often have the resources, legal expertise and established relationships to contest unfavourable valuations. Smaller businesses and entrepreneurs, particularly those entering the market for the first time, typically absorb whatever assessment they are given or walk away from the trade entirely. This dynamic quietly distorts market entry, raises barriers for small enterprises and concentrates advantage among those with the most leverage at the port.

For a country that frequently speaks about supporting small businesses and expanding the manufacturing base, a customs valuation environment that disadvantages smaller traders is a serious structural concern.

What a credible reform would look like

Publican AI has real potential. If deployed thoughtfully, it could reduce the inconsistencies and human discretion that have long made customs valuation unpredictable. It could flag genuinely suspicious declarations more efficiently and free up officers to focus scrutiny where it is most warranted.

But the technology will only fulfil that promise if it produces greater transparency, not a more sophisticated version of opacity. Traders must be able to understand why a value has been queried or uplifted. There must be a clear, accessible appeals process. And the system must be governed by rules that apply equally regardless of the size or connections of the importer.

• Ghana's customs reforms span decades, from manual assessment to AI-assisted valuation tools.
• Under-invoicing remains widespread, pushing customs to rely on reference databases over declared values.
• Smaller importers bear a disproportionate burden when valuation assessments are inconsistent or opaque.

The question Ghana must answer is not whether to use technology at the ports — that debate is settled. The question is whether Publican AI will be deployed as a genuine governance tool or simply become the latest mechanism through which the same old problems persist under a new name.