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The New Import Guide in Saudi Arabia: When Does Your Shipment Become a Customs Case?

Importing goods into the Kingdom of Saudi Arabia is no longer simply a matter of reaching an agreement between an importer and a supplier, shipping the goods, and waiting for the shipment to arrive at the customs port.

In certain cases, goods are subject to prior requirements or licenses issued by the competent government authority. Failure to satisfy these requirements may result in clearance delays, refusal of entry, disputes over liability, and, in some circumstances, the initiation of customs-related procedures or disputes.

This is where the importance of the New Import Licensing Guide becomes apparent. The Guide has been updated to regulate the importation of restricted goods into the Kingdom and to identify, for each category of goods, the competent authority, required documents and conditions, licensing procedures, application processing periods, and applicable objection procedures.

The importance of the Guide is not limited to importers seeking to bring a particular shipment into Saudi Arabia. It extends to every company that relies on imports as part of its commercial activities.

A single mistake in determining the nature of the goods, identifying the competent authority, or obtaining the required license at the appropriate time may result in more than a shipment delay. It may cause financial and commercial losses and potentially lead to disputes between the importer, supplier, carrier, or customs broker, depending on the circumstances of each case.

So, what has changed? What should importers know? And when can a shipment problem become a customs case?

First: What Is the New Import Licensing Guide?

The Import Licensing Guide was published in the Official Gazette on 2 October 2026. It is based on the Import Licensing Procedures issued by a Council of Ministers resolution and was updated in coordination with several government authorities responsible for regulated and restricted goods.

The Guide covers multiple government authorities, including:

Ministry of Interior.
Ministry of Environment, Water and Agriculture.
Ministry of Energy.
Ministry of Industry and Mineral Resources.
Ministry of Commerce.
Saudi Food and Drug Authority.
Communications, Space and Technology Commission.
General Authority for Media Regulation.
National Center for Environmental Compliance.
National Center for Wildlife Development.
Other relevant authorities.

This means that imports cannot be governed by one uniform rule applicable to all goods.

Each category of goods has its own characteristics, and certain goods are subject to specific requirements because of their nature, intended use, or potential impact on health, the environment, security, or other regulated areas.

Accordingly, the question that should be asked before shipping the goods is not simply:

How much will the shipment cost?

It should also be:

Are these goods restricted? Which authority is responsible for issuing the required license or approval? And what documents must be obtained before shipment?

This step alone can prevent many problems before they arise.

Second: Why Should Companies Pay Attention to the New Guide?

Because an import problem may begin long before the shipment reaches Saudi Arabia.

An importer may enter into an agreement with a foreign supplier, pay for the goods, arrange the shipment, and only discover after the goods arrive in the Kingdom that the products require a permit, approval, or registration with a competent authority.

In some cases, the situation may be more complicated, particularly where the actual goods do not correspond to the information stated in the documents or license.

The Zakat, Tax and Customs Authority (ZATCA) has clarified that importers are required to submit essential documents, including the commercial invoice and bill of lading, in addition to any documents required depending on the nature of the imported goods, such as certain certificates or product registrations with the relevant authorities.

ZATCA also recommends initiating customs clearance procedures and creating the customs declaration at least 48 hours before the shipment arrives at the port.

Therefore, successful importing begins before the goods are shipped.

This is particularly important for companies handling large volumes or frequent shipments. Repeated imports do not make compliance errors less significant.

On the contrary, the larger the company’s import operations, the greater the potential financial and commercial impact of a single procedural error.

Third: Not All “Restricted Goods” Are Subject to the Same Requirements

One common mistake is to treat all restricted goods as if they were subject to the same procedures.

The reality is different.

The competent authority varies according to the nature of the goods. The required documents, application processing period, licensing conditions, and applicable procedures may also differ.

The new Guide provides greater clarity by identifying these requirements according to the relevant goods and competent authorities.

For example, certain goods may be subject to requirements administered by the Ministry of Environment, Water and Agriculture, while others may fall under the Saudi Food and Drug Authority or different security or regulatory authorities.

Therefore, it is not sufficient for an importer to say:

“I have imported the same type of goods before.”

The relevant considerations include the specific goods, their classification, customs tariff heading, requirements applicable at the time of importation, competent authority, and the nature of the shipment.

Likewise, the fact that a product is available in the Saudi market does not necessarily mean that importing it from abroad is free from special requirements.

Fourth: The Mistake That Can Turn a Shipment Into a Legal Problem

Consider a Saudi company that enters into an agreement with a foreign manufacturer to supply a large quantity of a particular product.

The contract is signed.

Part of the purchase price is paid.

The goods are shipped.

The shipment arrives in Saudi Arabia.

The company then discovers that the product requires approval or a license from a competent authority and that the submitted documents do not satisfy the applicable requirements.

This is where the problem may begin.

The shipment may be delayed. The company may incur additional costs and storage charges. The supplier may demand payment of the remaining contractual amount.

At the same time, the company may argue that it was unable to receive the goods because of the customs clearance requirements.

At this point, what initially appeared to be a “shipment problem” may develop into a potential commercial dispute.

Depending on the circumstances, the customs broker, carrier, or other parties may also become involved.

This is why customs disputes do not always begin with an obvious violation at the border.

Sometimes, they begin with a commercial decision made incorrectly before the goods were shipped.

Fifth: Does Obtaining an Import License Automatically Guarantee Customs Clearance?

Not necessarily.

Obtaining a license or approval does not eliminate the need to comply with the remaining import requirements.

The importer must satisfy the documents and procedures applicable to the nature of the goods. Where goods are subject to specific requirements, the relevant certificates, registrations, approvals, or other conditions must also be satisfied.

Similarly, the clearance of restricted goods through ZATCA is linked to the requirements imposed by the competent authorities, and the relevant release authorization is issued in accordance with the applicable procedures.

Accordingly, the import process should be viewed as an integrated compliance system:

Goods classification → Identification of the competent authority → Obtaining required approvals → Preparing documents → Creating the customs declaration → Completing customs clearance procedures.

A failure at any stage may result in delays or other complications.

Sixth: Differences Between the Goods and the License Can Create Serious Problems

One of the most important issues for an importer to consider is whether the actual goods correspond to the information on which the license or approval was issued.

A discrepancy does not necessarily mean that the importer intentionally committed a violation.

The error may have originated with the supplier, resulted from an incorrect invoice, involved a difference in the commercial description, quantity, or product classification, or arisen from another documentation error.

Nevertheless, the practical result may be the same: a compliance issue requiring immediate attention.

Certain requirements under the Import Licensing Guide provide for circumstances in which a release authorization may be cancelled where the names, information, types, conditions, or forms of the imported materials differ from those stated in the authorization, where the materials were not included in the import authorization, or where the actual quantity exceeds the quantity specified in the authorization.

This highlights the importance of reviewing and verifying documents before shipment, rather than after the goods arrive.

Seventh: Who Is Liable When the Supplier Made the Mistake?

This is one of the most common questions arising in import-related disputes.

The importer may say:

“The supplier sent the wrong goods.”

The supplier may respond:

“I shipped the goods specified in the contract.”

The customs broker may then state that it processed the shipment based on the documents and information provided by its client.

So, who is responsible?

There is no single answer applicable to every case.

Liability depends on the contract, correspondence, invoices, customs documents, nature of the error, contractual obligations of each party, and whether a particular party failed to perform its obligations or acted negligently.

For this reason, companies should treat import contracts as important legal documents, not merely commercial paperwork.

Import contracts should ideally address, among other matters:

Each party’s responsibility for obtaining required licenses.
The supplier’s responsibility for ensuring that the goods conform to specifications.
Required documents and supporting records.
Product information that must correspond to the actual shipment.
Responsibility for delays caused by missing or inaccurate documents.
Storage and re-shipping costs.
Conditions for rejecting the goods.
Dispute resolution mechanisms.

The clearer the contract, the easier it becomes to determine liability when a problem arises.

Eighth: A Customs Broker Does Not Replace the Importer’s Responsibility

Having a professional customs broker can significantly assist a company with clearance procedures. However, this does not mean that the importer can disregard its own obligations.

The importer has a direct interest in bringing the goods into Saudi Arabia and must ensure that its activities and imports comply with applicable requirements.

ZATCA recommends verifying the requirements applicable to the goods through the customs tariff or by consulting the customs broker.

Accordingly, companies should treat the customs broker as part of the overall compliance system, rather than as the party to whom all legal and regulatory responsibility is transferred.

The information provided to the customs broker should also be accurate and complete, because incorrect information may affect the procedures followed in relation to the shipment.

Ninth: When Does a Clearance Problem Become a Customs Case?

Not every customs clearance delay constitutes a customs case.

Likewise, not every missing document necessarily amounts to a serious offense or violation.

However, the situation becomes more serious when the circumstances go beyond a simple administrative deficiency, such as:

Materially inaccurate information.
Importing restricted goods without satisfying the applicable requirements.
A material discrepancy between the documents and the actual goods.
Violations involving prohibited or restricted goods.
Circumstances that may require regulatory or customs enforcement action.

The applicable consequences and procedures vary depending on the nature of the violation, the goods, the competent authority, and the circumstances surrounding the matter.

Therefore, a company facing a customs issue should not assume in advance that the outcome will be the same in every case.

The entire file should be examined, including:

What are the goods?
What is the applicable customs tariff classification?
What documents were submitted?
Was approval obtained from the competent authority?
Was the approval valid?
Do the actual goods correspond to the submitted information?
Is there a contract with the supplier?
Is there correspondence establishing the source of the error?
Can the actual financial losses be established?

These questions may materially change the legal assessment of the situation.

Tenth: The New Guide Means That Importing Requires Better Legal Risk Management

Companies that rely on imports should not view customs procedures as the sole responsibility of the procurement or logistics departments.

Importing involves contracts, payments, obligations, licenses, documents, deadlines, and potential legal disputes.

For this reason, companies should establish a clear internal system for reviewing shipments.

Before Contracting

The company should identify the requirements applicable to the goods and confirm that they can legally be imported.

Before Shipment

Licenses, approvals, and supporting documents should be reviewed, and their consistency with the actual goods should be verified.

Before the Shipment Arrives

The company should ensure that the necessary customs clearance procedures and documentation are complete.

When a Problem Arises

The incident should be documented immediately, and all relevant correspondence, documents, notices, and decisions should be preserved.

Waiting until the shipment arrives before looking for a solution can be costly.

Eleventh: What Should a Company Do If Its Shipment Is Held Due to a Licensing Issue?

The first step is simple:

Do not take immediate action before identifying the reason for the hold.

The company should determine precisely what is causing the problem:

Is the issue related to the license?
Is it a documentation problem?
Is the goods classification incorrect?
Is there a discrepancy between the invoice and the actual goods?
Does the shipment require an additional approval?
Is there missing shipment information?

Once the cause has been identified, the company should collect all documents relating to the shipment, including:

The contract.
Commercial invoice.
Bill of lading.
Certificate of origin, where required.
Licenses and approvals.
Customs declaration.
Correspondence with the supplier.
Correspondence with the customs broker.
Any notices or decisions issued by the competent authorities.

The situation should then be legally assessed before the company enters into a dispute with the supplier or any other party.

The appropriate solution may simply be to complete a missing document.

In another case, the information may need to be corrected.

There may also be a genuine dispute regarding liability.

In some circumstances, it may be necessary to file an objection or take legal action, depending on the circumstances.

Twelfth: Why Should Everything Be Documented?

In commercial and customs disputes, documents may be more important than verbal accounts.

If the company claims that the supplier made a mistake, what evidence supports that claim?

If the company claims that the customs broker was aware of the shipment requirements, where is the correspondence?

If the company claims that the goods conform to the contract, are written specifications available?

If the company claims that the delay caused financial losses, can the amount of those losses be established?

Companies should therefore avoid relying solely on telephone conversations.

Important instructions, approvals, objections, demands, and communications should preferably be documented in writing.

Documentation does not necessarily prevent a dispute, but it can help establish what actually happened and determine the responsibility of each party.

Thirteenth: What About Objecting to Decisions?

One important feature of the Import Licensing Guide is that it does not merely identify the relevant authorities, requirements, and processing periods. It also addresses the applicable objection procedures.

This is important for importers because a decision concerning a shipment does not necessarily mean that all avenues of recourse have been exhausted.

However, an objection is not simply a letter stating that a decision is incorrect.

The decision should be carefully reviewed, including:

The competent authority.
The applicable deadline.
The relevant legal basis.
The supporting documents.
The appropriate procedural route.

Companies should also avoid missing statutory or regulatory deadlines because they expect the issue to be resolved informally.

Engaging legal counsel when a dispute arises may help the company identify the appropriate course of action within the required timeframe.

Fourteenth: The Biggest Mistake Is Learning the Rules After the Shipment Arrives

There is a simple rule in the world of importing:

A problem that can be solved before shipment may become a costly problem after the goods arrive.

Before shipping the goods, the company can:

Verify the product classification.
Identify the competent authority.
Obtain the required approval.
Amend the contract.
Require the supplier to correct the documents.
Verify that the goods match the relevant documentation.

Once the shipment arrives, however, additional costs may arise, sales operations may be disrupted, contractual obligations toward customers may be affected, and disputes may develop with the supplier, carrier, or other parties.

Therefore, proactive compliance is not merely an administrative requirement; it is a means of managing legal and commercial risk.

Fifteenth: What Should Companies Do Now?

In light of the updated Import Licensing Guide, companies that rely on imports should review their internal procedures rather than wait for a problem to occur.

Begin by preparing a list of all goods imported by the company.

For each product, identify:

What is its classification?
Is it restricted?
Which authority is competent?
What license or approval is required?
What documents are required?
Is there a specific validity period for the license?
What procedures must be completed before shipment?
What procedures must be completed before the shipment arrives?
What are the legal and commercial risks of failing to satisfy the applicable requirements?

This information should then be incorporated into a clear internal compliance system accessible to the procurement, logistics, finance, and legal departments.

Most importantly, the information should be reviewed periodically, as regulatory requirements may change.

Conclusion: A Shipment That Begins as a Transaction May End as a Dispute

The New Import Licensing Guide highlights an important reality:

Importing into Saudi Arabia is not merely a commercial transaction; it is an integrated legal and regulatory process.

Restricted goods are subject to specific competent authorities and requirements. Importers therefore need to understand those requirements before making financial commitments and shipping their goods.

The new Guide identifies the relevant authorities, licensing requirements, processing periods, and objection procedures, helping importers better understand what is expected of them.

ZATCA also emphasizes the importance of completing the required documentation and procedures according to the nature of the goods and initiating customs clearance procedures before the shipment arrives. Importers can also verify the applicable requirements through the customs tariff or with the assistance of a customs broker.

But knowing the rules is not enough.

That knowledge must be converted into practical internal procedures:

Review before contracting.

Verification before shipment.

Confirmation of licenses and approvals.

Matching the documents with the actual goods.

Documenting communications.

And obtaining prompt legal review when a dispute arises.

A problem may begin with a missing document, develop into a delay, lead to financial losses, and eventually become a dispute with the supplier or a financial, commercial, or customs claim.

That is why the best time to deal with a customs problem is before it becomes a case.

If the company has already reached the stage of receiving a decision, claim, or dispute, the appropriate response is not to act impulsively or rely solely on verbal communications. Instead, the company should review the documents and facts, determine its legal position, and then select the appropriate course of action in accordance with the applicable laws and procedures.

In the world of trade and importing, knowing the right procedure before shipping a container may be the difference between avoiding substantial losses and dealing with them after the shipment arrives.

Suliman Al-Omari Law Firm

Attorneys and Legal & Sharia Consultants

📞 Contact: +966 53 777 8130
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Disclaimer

This article is provided for general legal information and educational purposes only and does not constitute a substitute for specialized legal advice. The legal consequences and applicable procedures may vary depending on the nature of the goods, the facts of each case, the documents submitted, the competent authorities, and the laws and regulations in force at the relevant time.