Customs Registration and Licensing — BPN, Importer, Clearing Agent, Warehouse Keeper

Before you can clear a single shipment through ZIMRA, somebody in the chain must be registered. The importer must hold a valid Business Partner Number (BPN). The clearing agent acting on the importer's behalf must hold a clearing-agent licence. The bonded warehouse must be licensed as a customs warehouse. Each role has its own registration path with its own application form, fees and renewal cycle.

This lesson explains the registration framework for the four roles a private-sector taxpayer is likely to encounter: importer, exporter, clearing agent, and warehouse keeper. It also covers the related agent-appointment process whereby an importer authorises a clearing agent to act on its behalf.

• Customs and Excise Act [Chapter 23:02] — Part XII (clearing agents), Part XIII (warehousing licences).
• Revenue Authority Act [Chapter 23:11] — ZIMRA's enabling Act, BPN provisions.
• Customs and Excise (Licensing of Clearing Agents) Regulations — SI prescribing fees, qualifications, bond requirements.
• Companies and Other Business Entities Act [Chapter 24:31] — for the underlying corporate registration.
• Income Tax Act [Chapter 23:06] — section 34C TCC framework (a TCC is needed for many customs interactions).

1. The BPN — the entry ticket

Every taxpayer in Zimbabwe receives a Business Partner Number on registration with ZIMRA. The BPN is the identifier used by TaRMS, ASYCUDA and every customs interaction. Customs registration is essentially adding the "Customs" tax type to your existing BPN profile.

To do this in TaRMS:

1. Log in to the Self-Service Portal.
2. Go to Profile → Add Tax Type.
3. Select "Customs" and complete the form (your business address, nature of trade, expected import volumes).
4. Submit and await ZIMRA verification (usually 2-5 working days).

2. Importer registration

For commercial importers, no separate "importer's licence" is required — the BPN with Customs activated is sufficient. However, certain controlled goods need additional permits before import (covered in Module 7).

3. Clearing-agent licensing

To clear shipments on behalf of others, you must be a licensed clearing agent. Requirements:

• Registered Zimbabwean company or sole trader.
• Pass the ZIMRA clearing-agent examination.
• Lodge a surety bond (typically USD 50,000+ depending on volume).
• Pay the annual licence fee.
• Maintain a valid TCC.

The licence is renewable annually. ZIMRA can suspend it for non-compliance, fraudulent declarations or failure to maintain the bond.

4. Warehouse keeper licensing

To operate a private bonded warehouse for storing duty-unpaid goods, you need a Customs Warehouse Licence under Part XIII. Requirements include physical security, ZIMRA-approved layout, separate accounting for bonded vs. non-bonded stock, and bond cover.

5. Agent appointment by importer

An importer authorises a clearing agent through a Power of Attorney lodged on TaRMS. This is reciprocal — the clearing agent accepts the appointment and can then transact on the importer's behalf.

Scenario 1: SME importer doing it themselves

A Harare florist imports cut flowers from Kenya by air, twice a month. They:

1. Register their company at the Companies Registry, get a BPN.
2. Activate Customs tax type in TaRMS.
3. Use their own staff (or a casual contract clearing agent) to file each ASYCUDA declaration.

Scenario 2: Manufacturer using a clearing agent

A Bulawayo manufacturer imports raw materials weekly from China. They:

1. Hold a BPN with Customs tax type.
2. Appoint a licensed clearing agent (e.g. one of the major Beitbridge-based agents) via a TaRMS Power of Attorney.
3. Send the agent the commercial invoice, packing list, bill of lading and any required permits.
4. The agent files the ASYCUDA declaration in the manufacturer's name (using the manufacturer's BPN).
5. The manufacturer pays ZIMRA via the Single Account.
6. The agent collects clearance from ZIMRA and arranges onward transport.

• Personal liability of clearing agents — ZIMRA can recover unpaid duty from the clearing agent personally if the agent declared the goods knowing the value was understated. Bond can be called to satisfy the debt.
• Suspension of licence — clearing agents have been suspended for repeat offences. The Fiscal Appeal Court has upheld suspensions where ZIMRA followed proper procedure under Part XII.
• Importer's principal liability — the importer (BPN holder) remains primarily liable for duty even where a clearing agent files the declaration. The agent is jointly and severally liable in fraud cases.

1. Trading on someone else's BPN. Common in the informal sector — and a serious offence. The duty falls on the BPN holder, not the actual importer.
2. Letting a clearing-agent licence lapse. Suspension is harder to lift than to avoid. Renewal reminders are easy to miss.
3. Inadequate bond cover. ZIMRA can call the bond if duties go unpaid. Maintain bond cover well above expected liability.
4. No agent appointment on file. If the agent acts without a documented Power of Attorney, the declaration can be invalidated.
5. Stale company details. Director changes, address changes and bank-account changes must be updated on TaRMS within 14 days.

Q1: C — The Business Partner Number

The BPN is ZIMRA's universal taxpayer identifier, issued to companies, sole traders, partnerships and individuals upon registration. Customs is one of several tax types that attach to a BPN.

Q2: B — Importer primarily; agent jointly in fraud cases

The importer (the BPN holder under whose name the goods were declared) is primarily liable for any duty shortfall. The clearing agent becomes jointly and severally liable where they participated in fraud or knew the declaration was false.

Q3: D — Clearing-agent licence is not needed for warehouse operation

A bonded warehouse needs the Customs Warehouse Licence, bond, and proper accounting. Clearing-agent licensing is a separate system needed only if you transact on others' behalf.

1. BPN with Customs activated = entry ticket for any importer or exporter.
2. Clearing agents need a separate licence, bond cover, and TCC.
3. Bonded warehouses need a separate Part XIII licence.
4. Agent appointment via TaRMS Power of Attorney; reciprocal acceptance needed.
5. Importer = primarily liable; clearing agent = jointly liable in fraud cases.
6. Update profile within 14 days of any change.

Next lesson: Documentation & Bills of Entry — the actual paperwork that flows into ASYCUDA at clearance.