The Nigerian Upstream Petroleum Regulatory Commission (“NUPRC”) has issued the Guidelines for the Operationalisation of the Advance Cargo Declaration Regulation 2025 (the “Guidelines”) pursuant to Regulation 8 of the Nigerian Upstream Advance Cargo Declaration Regulation 2024 (the “Regulations”), and the Petroleum Industry Act 2021 (the “PIA”).
The Guidelines outline the procedures for implementing the digital cargo clearance process established under the Regulations. The Guidelines apply to all crude oil, natural gas liquids, condensates, and petroleum product exports from terminals and export points in Nigeria.
Key Provisions of the Guidelines
- Export Permits, Vessel Clearance and Unique Identification Number
Before any export of petroleum products, a licensee, lessee or exporter must:
- Apply for an export permit through the NUPRC’s Crude Oil Export Permit (“COTEX”) platform. The Regulations define an export permit as one issued by the Federal Ministry of Industries, Trade and Investment for the export of crude oil, liquefied natural gas, liquefied petroleum gas, condensates and refined products;
- Apply for vessel clearance via the Advance Cargo Declaration Portal (the “Portal”) using a Documentary Instruction (i.e., the Advance Cargo Declaration Form which is available on the Portal); and
- Procure a Unique Identification Number (“UIN”) applicable to the cargo, issued by the NURPC and embedded in the vessel clearance notification.
The NUPRC will only issue a clearance if it can verify the identity of the export permit holder and confirm that the export volume is within the permitted range. The UIN must be embossed on the Certificate of Quantity and Quality and related shipping documents, including the Bill of Lading, Certificate of Origin, and Cargo Manifest. The requirement for a UIN is rooted in Regulation 5 of the Regulations, which prohibits export of petroleum from Nigeria without a UIN issued and electronically imprinted on the export documents.
- Digital Submission and Documentation
All applications are processed via the Portal, which integrates with existing government systems through Application Programming Interfaces (“APIs”). Terminal operators and exporters will receive clearance notifications electronically, and the NUPRC will upload relevant documentation including the Certificate of Quantity and Quality within 24 hours of cargo loading.
- Rejection and Revision of Applications
The NUPRC may reject vessel clearance applications for incomplete, false, or inadequate documentation. Applications may be resubmitted without fee or penalty, except where the rejection was due to submission of false information. Exporters may update submitted applications (including export volume) upon payment of a revision fee, and where the UIN had already been issued, the same UIN must be retained for documentation continuity.
- Fee Structure
Exporters are required to pay the following fees to a designated NUPRC account:
- Vessel Clearance Fee: USD 0.03 per barrel processed
- Application Revision Fee: USD 100.00 per revision
Conclusion
The issuance of the Guidelines strengthens regulatory visibility over upstream petroleum exports by operationalising a digital, verifiable clearance regime. By requiring exporters to route all cargo documentation including volume validation and quality certification through the Portal, the NUPRC enhances transparency, standardisation of Nigeria’s crude and gas export processes via a verifiable technology-enabled platform. The embedding of a UIN across all export documentation also reduces the risk of diversion, unauthorised lifting, or underreporting of export volumes.
In operational terms, lessees and licensees will need to update internal compliance and documentation protocols to align with these electronic and pre-clearance requirements. Failure to comply may result in delays or administrative penalties, including fines for false submissions, failure to obtain a UIN, or co-loading contrary to the Regulations.
For more information on how we can support your compliance with these Guidelines, please contact aoenergy@aluko-oyebode.com
