Customs delay penalties start 1 October 2026: the four heads, and whose clock is running
From 1 October 2026, delays in clearing imports and loading exports at Pakistan's ports carry daily penalties. The rates step up after the first five days and each head is capped at one million rupees.
The instrument is SRO 1346(I)/2026, dated 13 August 2026, made under sub-section (1) of section 82 of the Customs Act, 1969, and in supersession of SRO 1387(I)/2025. Everything below is read from that notification.
The penalties fall on importers and exporters. They do not fall on the clearing agent. But every one of the four is triggered by a date — and the calendar that keeps a consignment on the right side of those dates is run from the agent's desk.
The four heads
| S. No. | Violation | Next five days | Each subsequent day |
|---|---|---|---|
| 1 | Goods declaration not filed for home-consumption, warehousing or transshipment within twenty days of the arrival of goods at a customs station | Rs25,000/day | Rs50,000/day |
| 2 | GD filed prior to berthing and the goods are not removed from the customs station, after payment of leviable duty and taxes, within five days of completion of assessment and berthing | Rs15,000/day | Rs20,000/day |
| 3 | GD filed after berthing and the goods are not removed for home-consumption, warehousing or transshipment within five days of the clearance of the goods declaration | Rs10,000/day | Rs20,000/day |
| 4 | Goods not loaded on the conveyance for export within fifteen days of the entry in the port | Rs5,000/day | Rs15,000/day |
Each head is capped: the notification says the penalty "shall not exceed one million rupees in each case". The amounts are written in words in the instrument, not figures.
Paragraph 2 provides that the penalties are subject to adjudicating proceedings or voluntary deposit, as prescribed under the rules notified for the purpose under the second proviso to section 82(1).
Who pays, stated precisely
This matters enough to be exact about, because it is the part most likely to be repeated wrongly.
The penalty attaches to the violation, and the violations are the importer's and the exporter's. A clearing agent is not made liable for these amounts by filing or failing to file. If you are an agent and someone tells you that you are now personally exposed to a fifty-thousand-rupee-a-day fine, that is not what this notification says.
What an agent does carry is different in kind, and worth naming plainly rather than dressing up as a statutory risk:
- A commercial exposure. If a consignment runs past twenty days because a document sat in someone's inbox, the client's invoice arrives with a penalty on it and a conversation follows about whose delay it was.
- An evidential one. When a client disputes a charge, the agency that can show the arrival date, the filing date, the berthing date, the assessment date and who was waiting on what has a defensible position. The one working from memory and a WhatsApp thread does not.
Four clocks, and they do not start together
The reason this is an operational change rather than a pricing change is that the four heads run from four different events:
- Arrival at the customs station — twenty days to file the GD. This one runs whether or not anything else has happened.
- Completion of assessment and berthing — five days, where the GD was filed before the vessel berthed, and the trigger also requires that duty and taxes have been paid.
- Clearance of the goods declaration — five days, where the GD was filed after berthing. Note this is not measured from berthing; it runs from when the GD is cleared.
- Entry in the port — fifteen days to load an export consignment.
Two consignments landing the same morning can therefore be on entirely different clocks, depending on whether the GD went in before or after the vessel berthed — and in the second case the clock does not even start at the same kind of event. Any agency tracking "days since arrival" as a single number will not see heads two and three coming.
The practical implication is dull and unavoidable: arrival, filing, berthing, assessment and clearance dates have to be recorded per consignment, against the job, in something you can sort. Not because a system prevents a penalty — nothing does — but because the penalty is computed off dates, and so is any argument about it afterwards.
One instrument, not two
A separate notification, SRO 1347(I)/2026, also takes effect on 1 October 2026. It is the Overstayed Cargo Management Rules, 2026, and it deals with something else — the procedure when section 82(1) bites, and which goods are excluded from it. Two different notifications, consecutive numbers, same commencement date. They are being mentioned together in a lot of coverage this month and they are not the same thing. SRO 1346 sets penalties under section 82(1); it does not, on its face, state that it is the quantum notification referred to in the Overstayed Cargo rules, and we are not asserting that it is.
Before the 1st
Nothing here requires new software. It requires knowing, for every consignment currently on your desk, which of these events has already happened and when. If that information is spread across a spreadsheet, a notebook and a chat thread, the week before commencement is a reasonable time to put it somewhere you can sort by date.
Read from SRO 1346(I)/2026 as published by FBR — the notification PDF. The scan carries an imperfect text layer, so the table above was read from the page image rather than from extracted text. FBR's download paths carry an upload-id prefix and can change; if that link stops resolving, search the SRO number on fbr.gov.pk. Verify against the notification before relying on any figure here.