Post Customs Clearance Audits: how to avoid penalties

Preparing for an upcoming customs audit is one way to minimize, if not to avoid, the risk of having deficiency assessments. Section 235 of EACCMA provides that: the proper officer may, within five (5) years of the date of importation, exportation, or transfer, or manufacture of any goods; require the owner of the goods or any person who is in possession of any documents relating to the goods:

  1. Produce all books; records and documents relating in any way to the goods and answer any questions in relation to those goods.
  2. To make declaration with respect to the weight, number, measure, strength, value, cost, selling price, origin of the goods etc.
  3. In case of any errors noted, related taxes and penalties are assessed.

According to Mr. Peter Kyambadde, KPMG, Customs taxes applied at the point of importation of goods into the country is not only a responsibility of the clearing agents. Importing companies are therefore obliged to keep, at their principal place of business, all their records pertaining to the ordinary course of business within five years from the date of final payment of duties and taxes or customs clearance. To avoid audit penalties, below is what to look out for;

  1. Propper documentation must be maintained at tall times to support the customs transactions. This includes invoices, supplier contracts, customs entries, bank statement showing payments.
  2. Periodic reconciliation between returns and entries as well as management accounts.
  3. Where stock is short laned, communication between supplier and company should be maintained. URA musts also be informed about this.
  4. Where stock is to be destroyed, a communication with URA in writing must be available and a URA officer may be present when stock is being destroyed.


Common Customs Compliance Pitfalls

Mrs. Anna Kakuba, a Tax Expert at KPMG, noted some of the common customs compliance pitfalls found by the tax man in Post Customs Clearance Audits to include;

  1. Errors in evaluation of items where some items like sea freight insurance and proceeds from the sale that are due to the seller among others.
  2. Classification errors where a wrong HS Code is used which affects taxes calculated.
  3. Misuse of rules of origin where we have preferential treatment with trade partners within COMESA, EAC and other trade blocks.
  4. Misuse of customs procedure codes especially CPC 458 for VAT deferment CPC 492 for exemption from taxes at importation.
  5. Excess or double claim of input VAT where there are errors in the input VAT amount or claiming VAT on the same entry more than once in different tax periods.
  6. Imported services misdeclaration; where there are post importation, services provided such as installation of imported goods, maintenance of machinery by a non-resident service provider etc.
  7. Quantity issues relating to stock reconciliation where there is a mismatch in imported stock and the quantities as per the company stock records.
  8. Concealment of small volume imports such as spare parts and under declaration of export sales.


Triggers for Customs Audit include;

  1. Mismatch between import purchases, export sales and ASYCUDA information.
  2. Goods in transit and Cut off period for annual financial reporting: It is common for goods to be entered into the ASYCUDA prior to arrival in tax payer stores. This can cause a variance since the company may have a cut off period and not consider these goods as purchases and received for a certain financial year.
  3. Mismatch between Property, Plant and Equipment in income tax returns and ASYCUDA information
  4. Use of Duty Remission Schemes
  5. Tax payers whose gods enjoy duty remission pay less duty than tax payers importing the same goods but are not on the duty remission scheme list. E.g; sugar ordinarily is subjected to 100% import duty. However, if imported by a tax payer who is on duty remission list, the import duty rate is at 10%.
  6. Tax Payers Considered as Authorized Economic Operators (AEO)
  7. Businesses heavily dealing in physical imported stock with variances in expected closing stock and actual closing stock in the financial statements could lead to additional queries and tax liabilities.
  8. Mismatch between the declarations as per the Value Added Tax and Excise Duty returns.
  9. Mismatch between the exports as per the Value Added Tax returns, Income Tax returns and ASYCUDA
  10. Variances in cost of goods within the industry
  11. Reconciliation of IM7 (warehousing entry): goods can be warehoused for a maximum of 9 months before they are treated as abandoned. The IM7 should be reconciled with the subsequent import entries (im4) or re-export entries. Variances could lead to audit queries.
  12. Mismatch between the VAT claimed in Value Added Tax Returns and ASYCUDA
  13. Risk management alerts from Ministries, Government Departments and Agencies, and whistle blower information.

















UMA partners with FUE to promote Human Resources best practices. 

Uganda Manufacturers Association (UMA) joined the Federation of Uganda Employers (FUE), in a collaborative partnership to strengthen Human Resources Policies and other related activities for UMA members.

The agreement will promote decent employment among manufacturers through adherence to the provisions of the employment laws of Uganda and recommend best practices for the world of work.

In this new partnership, the Federation of Uganda Employers (FUE) will offer free Human Resource related consultancy services to all UMA members; covering; a) Human Resource Manual Updating, b) Human Resource Manual Review, c) Human Resource Manual Development, d) Human Resource Planning, e) Review of Human Resource capacity development policies, f) Streamlining recruitment policies and processes, g) Review, development and streamlining termination policies and procedures, h) Understanding Labour Laws, and any other Human Resource related service as per member requirement.  


All the above will be offered by FUE at NO COST to UMA members.


Uganda Manufacturers Association will promote competitiveness through lobbying and advocacy for a conducive business environment by undertaking collaboration in research, generating policy updates and proposals from manufacturers, for consideration by the Government of Uganda.


Federation of Uganda Employers (FUE) is the voice of employers on social and economic issues.


To benefit from this offer, please contact , . Or call on +256703842870.


UMA Moves To Assess Compliance Of Members Towards Implementation Of Covid-19 Standards

Uganda Manufacturers Association (UMA) recently embarked on a tour to its members to assess their readiness as far as implementation of Covid19 Standard Operating Procedures (SOPs) is concerned.

During this visit Daniel Birungi the Executive Director of UMA revealed that one of the main objectives is this process being conducting in conjunction with Ministry of Health is to identify a training and certification programme for manufactures.

“Those who have observed the directives on top of putting in place right safety measures will receive recommendation ad act as examples to the others.”

 “We have recognized that it is our role as a body that brings together manufacturers to first of all assess our readiness as manufacturers for managing Coovid-19.”

Birungi pointed out that since covid19 infection in the country is at community level the employees have high chances of being exposed from their communities and thus calling for a need to have proper channels of handling such emergencies.

Dr Aggrey Batesaaki, Assistant Commissioner in charge of inspection, Standards and Compliance in Ministry of Health pointed out that during the tour they identified some gaps that need to be worked on to ensure a safe environment.

“Their environment is not talking Covid-19 for example they did not have much posters and I have advised them to put them in place so that anybody walking into the factory can be reminded about the SOPs” advised Dr. Aggrey.

Mr Deo Kayemba, the Vice Chairman of UMA was impressed by the preparedness exhibited by Manufacturers and he called upon them to continue putting employees’ life at the fore front.

Mr Edwin Kenneth Kalungi, in charge of safety and ISO systems at Steel & Tube Industries Ltd informed the visitors that they screen temperature for all visitors before going through full body disinfection.

“All person’s records are taken to monitor their location, names and temperature. Upon entering to every office, one has to follow the guidelines of the walkways. They are restricted from interacting with any staff besides the one you intend to visit to minimize on contacts.”

According to Simon Kaheru, the Public Affairs and Communication director Coca-Cola Beverages Africa, they identified that the key element in managing Covid-19 was communication to change behavior. “In every single meeting, all staff are required to recite a pledge; I am my brother’s keeper; I am my sister’s keeper; I am my family’s keeper as a constant reminder of implementing the Covid-19 guidelines” he added.


After the visit, UMA promised to set up a Covid-19 task force for manufacturers who will draft Standard Operating Procedures (SOPs) to guide Ministry of Health as it sets these guidelines for manufacturing firms.

Prior to this visit, manufacturers held a virtual meeting in which they interfaced with various key players and experts in numerous sectors on how they can improve on working conditions of workers and clients in observance of set guidelines.

While addressing fears of closing companies, Dr. Aggrey Batesaaki, noted that Closing off a company because of a confirmed Covid-19 case does not stop the spread of the virus but warned manufacturers to be extra vigilant in maintaining SOPs.

“Once a company registers a case, Ministry of health is available to work with companies to weigh the options of curbing further spread of the virus within the premises without a total shut down” he added.

“Government is passionate about moving our economy further, and that his ministry is not happy to close the economy considering the vital role manufacturing plays in keeping our economy moving in such unprecedented times.”

Currently the Ministry of Health is in process of developing Consolidated Standard Operating Procedures for Manufacturing.

The companies inspected included Steel & Tube Industries Ltd, Coca-Cola Beverages Africa and Cipla Quality Chemicals.






Manufacturers; Nice House of Plastics with Coca-Cola Beverages Africa joined Stanbic Bank Uganda, in a collaborative partnership to promote responsible use and recycling of plastic waste as a means of sustaining environmental protection. Under this partnership, Coca-Cola Beverages Africa’s recycling industries will collect and supply PET flakes as raw materials for Nice House of Plastics to create finished products. 

Manufacturers; Nice House of Plastics with Coca-Cola Beverages Africa joined Stanbic Bank Uganda, in a collaborative partnership to promote responsible use and recycling of plastic waste as a means of sustaining environmental protection.

Under this partnership, Coca-Cola Beverages Africa’s recycling industries will collect and supply PET flakes as raw materials for Nice House of Plastics to create finished products.  

Nice house of plastics managing director, Ms Barbara Mulwana said that “Recycled PET is one of the major raw materials that we use. We have previously imported some of it and this collaboration will go a long way in solving our raw material problem while promoting a safe environment.”

The companies also agreed to engage plastic manufacturing companies to set up plastics collection centres in the communities as part of an extended producer responsibility to increase the amount of plastics collected for the recycling project.

Stanbic’s role in the new collaboration will be in providing the necessary finance and advisory expertise to promote sustainable waste management of plastics.

Stanbic Chief Executive Anne Juuko said, “This is a first of its kind in the country, where private sector players will collaborate to promote sustainable recycling of plastics through an ecosystem underpinned by value addition to create end products and ultimately protect the environment.”



Manufacturers have called upon the Public Procurement and Disposal of Public Assets Authority (‘PPDA’) to standardize the bidding requirements across all sectors of the economy to eliminate irregularities in public procurement. This request was conveyed in a meeting held between manufacturers and representatives from PPDA on 17th June 2020.

The meeting deliberated on hindrances to manufacturers’ full participation in the public procurement process and sought to identify actions through which PPDA could improve the local content in public procurement.

Globally, the COVID-19 pandemic has awakened economies to the importance of import substitution as they navigate through the shocks of the pandemic with public procurement emerging as a key vehicle for the economic recovery of countries through implementation of preference and reservation schemes that promote the utilization of local labor, goods, and services.

Manufacturers’ Remarks

  1. UMA noted that the liberty given to MDAs, local government and other public entities to determine the technical requirements for bids was often abused to eliminate the local manufacturers and suppliers through unnecessary bidding requirements. For instance transformer manufacturers are required to have had their companies established for more than 10 years, a requirement that technically throws them out because the local transformer industry has been in existence for less than10 years.
  2. UMA called upon PPDA, as the regulator to determine the nature of bidding requirements against the reservation guidelines cutting across to all government ministries, departments, agencies and local government and highlighted the need for a robust PPDA armed with powers to enforce against errant accounting officers if the guidelines were to be respected
  3. Noting the successes arising out of the Reservation Guidelines thus far, UMA informed the PPDA team that new capacities had emerged that required mainstreaming into the Guidelines further proposing that a standard review process be instituted to ensure that emerging capacities were recognized and the sectors included periodically. UMA noted that sectors with emerging capacities included furniture, paint, transformers, steel, printing, mattresses and foam products, and tiles among others, and that UMA would formally engage PPDA to include these into the next reservation guidelines.
  4. Responding to a question on available local capacity to supply, UMA noted that capacity was a function of market access and that in light of the manufacturing operating at only 56% of installed capacity, existent capacity was expandable based on need. UMA noted that in the absence of orders from government for sectors such as transformers where government is the only procurer, it was unfair to expect sector players to demonstrate high levels of prior supplies as a pre-condition for bidding.

Remarks from PPDA;

  1. The Executive director of PPDA, Mr. Benson Turamye, pointed out that PPDA plays an oversight role of the procurement process to ensure transparency and fairness since the PPDA Act, 2003 decentralized public procurement and assigned the roles of procurement planning, bidding, award and implementation of contracts to Ministries, Departments and Agencies (MDAs) and Local Governments.
  2. The ED, PPDA presented a paper on the contribution of public procurement in the implementation of the Buy Uganda Build Uganda policy, and re-echoed PPDA’s commitment towards advancing the BUBU policy.
  3. He highlighted additional PPDAs openness to new sectors for inclusion in the reservation guidelines and tasked UMA to coordinate submit the areas of emerging capacity for consideration by the procurement body.
  4. He also urged the manufacturers association to clearly define what qualifies to be a locally manufactured product as they looked into adding more capacities to the reservation guidelines.

Way forward;

  1. UMA to develop a comprehensive document detailing the challenges faced by local suppliers with proposed interventions that are expected from PPDA.
  2. UMA to submit a formal request for additional sectors for recognition in the reservation guidelines with justifications for each emerging sector.
  3. PPDA and UMA to work together in exploring modalities of unbundling Engineering, Procurement and Construction contracts that served to lock out local capacities under the strict contract clauses.
  4. PPDA and UMA to work together to influence negotiated terms with development partners
  5. PPDA to enforce the implementation of the guidelines and ensure that action is taken against MDAs that fail to comply with the set guidelines.
  6. PPDA to revise the current reservation thresholds to create flexibility for emerging capacities that have evolved since the earlier reservation guidelines.
  7. PPDA and UMA to hold quarterly meetings to track progress on agreed points 

For more information please contact  

UMA’S Persistent Lobbying Yields Results

It is increasingly clear that government is appreciating UMA’s lobbying and advocacy through taking steps to make the ‘Buy-Uganda Build-Uganda’ mantra a reality.

Government recently announced the tax policy changes in the customs following amendments regarding customs duties and laws for the financial year 2019/2020 that saw an increase in import taxes of certain products that were causing unfair competition for local manufacturers as listed in the Downloadable document Here.

The changes that are expected to take effect on July 1, will incentivise local manufacturers by creating a levelled playing field against imports, while signalling investments into production of such goods which mainly take up local raw materials.


Manufacturers of products such as toilet paper, exercise books, toothbrushes, biscuits, shoe polish, sugar, carton boxes, iron sheets or steel wool, mattresses among others are some of the direct beneficiaries of UMA’s persistent lobbying.

In a bid to promote the growth of local manufacturers in the various sectors, UMA has been lobbying government through Ministry of Finance, Planning and Economic Development to make necessary tax policy adjustments specifically regarding customs duties as an offer of market space to the local industry.  Such a move will allow suppliers of raw materials to get market, while industries expand, grow capacity and employ more people thus defining what industrialisation for job creation and shared prosperity is all about.

Even as we celebrate this milestone, we are unwavering in our commitment towards promoting and protecting interests of all manufacturers through coherent policy advocacy with focus on the mainstreaming of Local Content in all sectors; lobbying for sanctions against accounting officers who fail to adhere to the terms set out in the PPDA reservation guidelines with continuous lobbying of government to fast-track the local content bill which will facilitate the increment in procurement of locally produced goods.




President Yoweri Museveni has assured manufacturers that all of them, including small and micro enterprises, will get electricity at a cheaper cost. However, the tariffs reduction would be implemented in phases, starting with large industries that are getting electricity at five US cents.

 The President said with the refinancing of the Bujagali power project, electricity tariffs have to go down. This was contained in Museveni's speech delivered by the finance minister, Matia Kasaija, at the opening of the 26th International Trade fair yesterday. The event is taking place at the UMA showground at Lugogo, Kampala.

"Unfortunately, affordable power for all manufactures was delayed by people who could not understand centrality in our transformation. As I indicated to you earlier, the cost of power shall continue to reduce until we realise five US cents per kilowatt hour for all manufacturers," said Museveni.

He added that so far, big manufacturers have accessed cheaper power. With enough power, the government will achieve its priorities in manufacturing under the Vision 2040, where the Government wants to ensure that 50 of Uganda's exports are manufactured goods. The President said that is why the Government is supporting the Buy Uganda Build Uganda (BUBU) campaign. He said he had already instructed the Public Procurement and Disposal of Public Assets Authority to work with manufacturers to create reservation guidelines that support local sourcing. Museveni said such a move would increase foreign earnings for the country and also create employment for the youth.

He pointed out that recently; he commissioned a Chinese manufacturing facility in Kapeeka, which will save Uganda $35m annually in addition to earning Uganda $15m in exports. Museveni revealed that a spinning mill would soon be established in Uganda, which will consume about 20 of Uganda's cotton that now stands at 150,000 bales.

"This means I  need additional four such factories to consume more cotton and lint to guarantee a decent farm gate price for all cotton farmers now aggregating 2.5 million," he said.


The trade minister, Amelia Kyambadde, said from the time the BUBU policy was launched, a lot has been achieved in terms of creating market opportunities for locally produced products. She said new regulations are being developed on a reservation scheme that will make it mandatory for all government ministries, departments and agencies (MDAs) to procure products made in Uganda.

Through the BUBU policy,' Sinohydro Corporation Limited, which is undertaking the construction of Karuma hydropower project, is now procuring all cement and iron bars from local manufacturers.

Hima Cement alone has a contract to supply cement worth $5,667,056 (about sh20.7b). She added that in the last financial year, the government MDAs bought furniture worth over sh350m from the Uganda Prisons furniture workshop.


The furniture was purchased by State   House,Equal Opportunities Commission," the finance ministry, works ministry and the Standard Gauge Railway project.


Furthermore, Picfare/Nytil has signed a contract with the Uganda National Medical Stores to supply uniforms to all government hospitals, Kyambadde said. In the services sector, through the Petroleum Authority of Uganda, local companies have supplied local products and services worth $37.24 m (about sh141b).


The supplies have been in form of food, beverages, drilling and production materials as well as construction materials. There also services such as catering, transport, security, land surveying, clearing and forwarding.






Sector Statistics



UMA has over 1221 Members in all Categories
Industry Contribution To GDP21%


Electricity Consumption 66%

Uganda Manufacturers’ Association
P.O Box 6966, Lugogo Show Grounds
Tel: +256 414 221 034 /287615
Fax: +256 414 220 285

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