‘FBR’s masterclass in policy uncertainty’: a rejoinder by Pakistan Customs
KARACHI: This is apropos a Business Recorder editorial “FBR’s masterclass in policy uncertainty” of 6 November 2026.
- “Pakistan Customs has read with care the Business Recorder’s editorial of 6 November 2026. The editorial raises three customs-side matters — the Faceless Customs Assessment (FCA) system, the establishment of the Central Appraising Unit (CAU) at Islamabad, and the revision of duty drawback rates — and draws from them a broader conclusion about consultation and predictability. Customs welcomes scrutiny of its reforms and places the following facts on record. Matters relating to sales tax fall outside the scope of this response.
Faceless Customs Assessment
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“Under FCA a goods declaration is assessed by an officer who is assigned the declaration by the system at random, who does not know the identity of the importer or clearing agent, and who has no physical interface with either. The reform was introduced for one reason: the assessment of a consignment should depend on what is declared and what the law provides, not on who is clearing it or whom they know. That is the integrity reform the editorial itself asks for, and it is already in operation.
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“The clearance figures cited by FBR — a fall in average clearance time from 40.2 hours to 20.57 hours, with 83 percent of consignments clearing within 48 hours — are not estimates. They are computed from system time-stamps recorded in WeBOC for every declaration, and the underlying data can be examined by any trade body that wishes to do so. The editorial accepts that these figures show progress. Customs does not claim they resolve every grievance; it claims they establish that the system, taken as a whole, is clearing cargo faster than the one it replaced.
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“The invitation to trade bodies to furnish specific goods declaration numbers is not a deflection. Every declaration leaves a complete and auditable trail in the system: when it was filed, when and to whom it was assigned, whether a valuation query or laboratory referral was raised and on what ground, how long each stage took and who decided it. Specific cases are the only means by which a systemic cause can be separated from a case-specific one. Where the cases furnished reveal a pattern — in referral parameters, in risk rules, in assessment practice — the correction is made at the system level and applies to all declarations, not to the complainant’s alone. An aggregate assertion that delays are occurring cannot be tested in that way; a set of declaration numbers can.
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“On consultation, FCA was not introduced overnight. It was piloted at a single collectorate, extended in phases, and adjusted at each phase on the basis of operational data and the representations of chambers, exporters’ associations and clearing-agent associations, who have been engaged throughout. The review mechanism available to a trader who disagrees with an assessment remains intact and operates within the same system. Customs does not regard criticism as obstruction; it regards unspecific criticism as something it cannot act upon.
Central Appraising Unit, Islamabad
6.?“The editorial’s central objection is that separating assessment from the port will cause delays and coordination problems. This objection misreads what FCA already is. Under FCA the assessing officer at the CAU in Karachi already assesses declarations filed at Lahore, Port Qasim, Peshawar, Quetta, Faisalabad and every other customs station in the country. Assessment has been separated from the physical location of the cargo since the day FCA went live. The distance between the assessing officer and the port is, in a faceless system, zero or irrelevant — the officer works from the declaration, the documents, the images and the examination report, all of which are in the system wherever he or she sits.
7.?“Physical examination remains, and must remain, where the goods are. Examination staff at the ports will continue to examine consignments and upload their reports into the system for the assessing officer, exactly as they do today. Nothing in the relocation changes the examination function, the port operations or the responsibilities of the field collectorates at Karachi.
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What the relocation does change is the capacity and resilience of the assessment function. A national assessment facility concentrated at one location, dependent on a limited cadre of appraising officers working office hours, is a single point of failure for the country’s entire import, export and transit pipeline. The Islamabad CAU is designed to operate round the clock, staffed by 280 Goods Evaluators engaged on contract, each for a specified area of goods, recruited from the market through a competitive, independently administered selection process and trained at Karachi — with live system exposure and attachment to the existing CAU — before they assume assessment duties. This will allow Customs to clear goods on a 24/7 basis for every customs station in the country, in a standardised manner, under a single set of assessment practices. It will thereby remove the variation in assessment practice from one customs station to another that has long been the trade’s own complaint and the single largest source of unpredictability in customs clearance. This operating model has not been improvised; it has been developed with international experts on the basis of global benchmarking of centralised, faceless assessment in comparable customs administrations.
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“The transition is deliberate and gradual. Both CAUs will operate in parallel for a transition period of several months, with workload shifted to Islamabad in stages as its capacity is demonstrated — lower-risk streams first — so that no consignment is exposed to an untested facility. The description of the decision as irreversible refers to its strategic direction: that assessment will be performed by a professional, centralised, faceless unit. The operating procedures, service standards and transition sequencing remain open to the trade’s input and are being developed with it. A settled direction and an open implementation are not in contradiction; they are how any large institutional change is responsibly carried out.
Duty drawback
10.?“Duty drawback is a refund of customs duty actually paid on imported inputs consumed in exported goods. It is therefore inseparable from the documentation of those inputs; a drawback paid without reference to inputs is not drawback but a subsidy, and would be treated as such by Pakistan’s trading partners. The revised rates reflect updated input-output determinations and current duty structures. For exporters availing standard rates, the system computes and credits drawback automatically on the export declaration; no separate claim is filed. Customs will examine any specific instance in which the revised schedules have been found unworkable in practice and will correct it.
Integrity and predictability
- “The editorial observes that allegations of corruption erode FBR’s standing when it demands transparency of taxpayers. Customs does not dispute that integrity is the test of its own credibility. It would note that FCA, the random system assignment of declarations, the removal of the physical interface, the recruitment of assessors from the market under a strict code of conduct, and the centralisation of assessment away from the port are, together, the most far-reaching structural response to that concern that Pakistan Customs has undertaken. These measures reduce discretion and remove the interface in which discretion is traded. They are also, not coincidentally, the measures the editorial finds most disquieting.
12.?“Customs shares the editorial’s view that investors require predictable rules and procedures. Predictability is precisely what a uniform, faceless, system-driven assessment delivers — the same declaration assessed by the same rules regardless of the port, the officer or the agent — and what a discretionary, port-bound, officer-dependent assessment never could.
13.?“Customs remains ready to engage. Trade bodies that have concerns about FCA are invited to furnish the specific declarations that give rise to them, through their collectorates or directly to FBR, so that each can be traced and the system corrected where it is found wanting. The Business Recorder’s editorial board is likewise invited to visit the CAU and see for itself how a declaration moves through the system, from filing to clearance.”
Copyright Business Recorder, 2026
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