Nigeria Import Documents Explained: Form M, PAAR and SONCAP

It helps to sort Nigerian import paperwork by who produces it. The importer, through an authorised dealer bank, produces Form M. The overseas supplier produces the proforma invoice at the start and, after shipment, the commercial invoice, the packing list and the combined certificate of value and origin, usually shortened to CCVO. The carrier issues the bill of lading for sea freight or the air waybill for air freight. A Nigerian-registered insurer issues the marine or cargo insurance certificate. Regulators issue product approvals: the Standards Organisation of Nigeria, through its accredited inspection firms, issues SONCAP certificates for the products it regulates, and NAFDAC issues registrations and import permits for food, drinks, drugs, cosmetics, medical devices and chemicals. Other agencies have their own permits for specialised goods. Finally, the Nigeria Customs Service issues the PAAR and, after duty is paid and the goods are examined, the customs release. Almost everything is now submitted electronically through government trade and customs platforms, and those platforms have been changing as customs modernises its systems, so rely on your bank and your licensed customs agent for the current procedure instead of on screenshots from an old shipment.

Form M is a mandatory declaration of your intention to import a specific consignment. It records who is importing, who is supplying, what the goods are, their HS code, quantity, value, country of origin and supply, the port of discharge and how the supplier will be paid. It serves two purposes: it lets the Nigeria Customs Service know about the shipment in advance, and it is the basis on which foreign exchange for the transaction is handled under Central Bank of Nigeria rules. You open it through an authorised dealer bank, meaning a commercial bank licensed to deal in foreign exchange, which reviews and submits it, after which customs registers it. The bank will ask for your company registration documents, Tax Identification Number, the proforma invoice, an insurance certificate, and any regulatory certificate or permit that the product requires. Form M should be opened and approved before the goods are shipped, and the shipping documents should carry its number. It is valid for a limited period and can be amended or extended through the bank if details change. Treat the proforma invoice with care, because every later document will be compared against what was declared on Form M.

SONCAP stands for the Standards Organisation of Nigeria Conformity Assessment Programme. It applies to imported products that SON regulates, a wide list covering items such as electrical and electronic goods, building materials, automotive parts, toys, household goods and many other manufactured products. Its purpose is to confirm, before goods leave the country of export, that they meet the applicable Nigerian Industrial Standards or approved equivalents. There are two certificates and they come at different stages. The product certificate is obtained first. The exporter works with an inspection and certification firm accredited by SON in the country of export, which assesses the product through testing, documentation or factory assessment. The product certificate is what your bank needs in order to process Form M for a regulated product. The second document, the SONCAP certificate, is issued for each individual shipment once the goods are ready and the final documents are available, and it is needed for the PAAR and for clearing. Some categories are outside SONCAP because another regulator handles them, notably food, drugs and other products under NAFDAC. If you are unsure whether your product is regulated, ask SON or an accredited firm before you order.

The National Agency for Food and Drug Administration and Control regulates the import of food, packaged water and drinks, drugs, cosmetics, medical devices, detergents and chemicals. As a rule, a regulated finished product must be registered with NAFDAC before it can be imported for sale, and the registration is granted for a specific product from a specific manufacturer to a Nigerian applicant. A foreign manufacturer cannot register directly and must act through a Nigerian company. Registration involves documentation from the manufacturer, product samples, laboratory analysis and label review, and it takes time, so start well before you plan to ship commercial quantities. Chemicals and some raw materials are handled through import permits instead of product registration. At the port, NAFDAC officers inspect regulated consignments and endorse the release, and goods without the right approval can be detained or destroyed. The registration number must appear on the product label. For importers this means the NAFDAC process is the first step in the sequence, not something to sort out while the container is at sea. Confirm current requirements with NAFDAC directly, because guidelines are revised.

The Pre-Arrival Assessment Report is issued by the Nigeria Customs Service. It replaced the earlier risk assessment report when customs took over destination inspection from private service providers. After the goods are shipped, the supplier sends you the final documents: the commercial invoice, packing list, bill of lading or air waybill, and the CCVO, together with the SONCAP certificate or other regulatory documents where they apply. You pass these to your bank, which checks them against the Form M and submits them electronically to customs. Customs then reviews the classification, the declared value and the origin, and issues the PAAR, which states the HS code and value it accepts for assessing duty. Your licensed customs agent uses the PAAR to lodge the customs declaration. Duty and levies are then assessed and paid through a bank, the consignment is selected for scanning or physical examination, the relevant agencies give their releases, and customs releases the goods. Only then will the shipping line and terminal operator release the container against payment of their own charges. If customs disagrees with your value or classification, the difference is raised as an additional assessment that must be settled before release.

Put together, the sequence runs like this. First, confirm the product is not on the import prohibition list, identify the HS code and find out which regulator, if any, covers it. Second, make sure your business is ready: registration with the Corporate Affairs Commission, a Tax Identification Number and a relationship with an authorised dealer bank. Third, obtain the product approval, meaning NAFDAC registration or permit, or the SONCAP product certificate. Fourth, agree the order and obtain a detailed proforma invoice, arrange insurance with a Nigerian insurer, and open Form M through your bank. Fifth, once Form M is approved, the supplier produces and ships the goods, and for SON-regulated goods the shipment-level SONCAP certificate is issued. Sixth, the supplier sends the final documents, your bank submits them and customs issues the PAAR. Seventh, your customs agent lodges the declaration, you pay duty, the goods are examined and released by customs and the other agencies. Eighth, the shipping line and terminal release the container and you truck it to your warehouse and return the empty container. Keep copies of everything. Banks, customs and tax authorities can all ask for the file later.

Two clocks start when a container lands. The shipping line allows a set number of free days for use of its container, after which demurrage is charged, and the terminal operator allows a free storage period, after which storage or rent is charged. Both rise the longer the cargo stays, and a delayed container can wipe out the profit on a shipment. Most delays trace back to paperwork. Form M opened after shipment, or not approved by the time the vessel arrives, is a frequent cause. So are mismatches between Form M and the final documents in value, quantity, description, supplier name or HS code, each of which can require an amendment through the bank. A missing SONCAP certificate or NAFDAC approval will stop release. Disputes over classification or valuation lead to additional assessments. Original documents that arrive late, duty funds that are not ready, and an agent who has not been briefed all add days. Outside your control there can also be port congestion, system downtime and examination backlogs. The defence is preparation: check draft documents against Form M before the supplier finalises them, give your agent copies before the vessel sails, keep funds ready, and follow up daily once the vessel berths.