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KARACHI: All Pakistan Paper Merchants Association (APPMA) has accused shipping lines, agents, and freight forwarders of imposing multiple illegal charges on importers while criticizing the Federal Board of Revenue (FBR) for failing to take action against these practices.

In a letter to Daily Business Recorder, Muhammad Anis, Senior Vice Chairman, APPMA, outlined what he described as exploitative practices that violate Pakistan’s Customs Rules 2001 and international maritime law.

The letter alleged that importers are being charged Terminal Handling Charges three times on C&F CY to CY cargo. According to the Bill of Lading terms, shipping companies are contractually responsible for lifting containers from the port of loading and delivering them to the destination yard.

READ MORE: Shipping lines charging rates as per official exchange rates: FBR

“Despite this clear contractual obligation, shipping companies again impose Terminal Handling Charges at the destination, while terminal operators simultaneously levy the same charges,” the letter said, calling it “blatant double and triple charging” that constitutes an unlawful financial burden on lawful trade.

APPMA questioned the legal status of various charges being collected, including Delivery Order fees, late Delivery Order charges, LOLO charges, insurance fees, equipment charges, DCI and ISC charges, Research and Development fees, and ISPS charges.

The association claimed these charges are imposed without legal or contractual basis, violating Customs Rules issued under SRO 450(I) 2001.

Under Rule 665(q), shipping companies are charging between $100 and $150 per twenty-foot container per day for detention after free days expire. The APPMA described these charges as excessive and unethical, arguing they lack prescribed caps, notified tariffs, or regulatory oversight.

The association also alleged that Rule 665(r), which requires security deposit refunds within 15 days, is routinely violated, with deposits often returned only after 45 to 60 days.

The APPMA argued that current practices violate international maritime conventions, including the Hague Rules, Rotterdam Rules, and the United Nations Convention on the Carriage of Goods by Sea.

According to the association, Rule 665(p) of Customs Rules 2001 permits shipping companies to recover only charges expressly stated on the Bill of Lading. Article 23 of the UN Convention on Carriage of Goods by Sea declares void any contractual clause that contradicts the Convention.

“All charges lawfully recoverable by a shipping company form part of freight and must be fully and transparently declared on the Bill of Lading,” Senior Vice Chairman, APPMA said, adding that any charge not included cannot be lawfully recovered from importers.

Despite repeated complaints from the business community, APPMA claimed the FBR has failed to take meaningful action. The association accused authorities of making critical regulatory decisions favoring shipping companies without proper consultation with trade bodies.

The letter further said that current practices amount to “statutory failure and regulatory abdication” that violates constitutional guarantees of equality before law and enables abuse of dominant position by shipping companies.

APPMA has urged the FBR and Pakistan Customs to immediately prescribe fixed, reasonable, and transparent maximum detention charges after consultation with trade stakeholders. The association also demanded amendments to prevent shipping companies from en-cashing security deposits.

The organization called for urgent review and amendment of Customs Rules 2001 to ensure compliance with internationally recognized laws, arguing that current enforcement disproportionately benefits shipping companies while imposing unjustified financial burdens on importers.

Copyright Business Recorder, 2026

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