Inside Zambia's Wheat Import Regime: Permits, Duty Suspensions and the Food-Security Trade-Off

• The deficit: wheat output fell from about 330,000 tonnes in 2015 to about 81,822 tonnes, leaving a deficit of about 358,318 tonnes in the 2026/27 food balance, even as maize shows a large surplus.

• The permit lever: wheat and wheat flour are scheduled goods under the Control of Goods Act, so imports need a Ministry of Agriculture permit. Imports were banned outright in 2015 and are now allowed through ad hoc permits.

• The duty lever: Zambia's tariff bands are 0%, 5%, 15% and 25%, with grains generally at 15%. Duty can be suspended by SI for named importers and quantities: 100,000 tonnes for 21 firms in 2024, and 300,000 tonnes for 26 firms in September 2026.

• The regional exception: originating SADC and COMESA wheat generally enters duty-free already, but still needs a permit.

• The legal tension: WTO rules give wide room for tariffs, but restrict discretionary import licensing and quantitative restrictions. The permit regime also risks being treated as a non-tariff barrier in SADC, COMESA and the AfCFTA.

• The policy goal: one million tonnes a year by 2031 under the Grow Zambia Agenda. A published tariff-rate quota, seasonal tariffs or rules-based suspensions would give farmers and millers a predictable framework.

A decade ago, Zambia was self-sufficient in wheat. Today it must import most of what it consumes.

What the numbers mean. Production has fallen by roughly three-quarters since 2015, while demand has grown with urbanisation and the rise of bread and other wheat products as daily staples. Most of Zambia's wheat requirement now has to be imported.

A contrast with maize. The same 2026/27 food balance shows a maize harvest of about 4.94 million tonnes and a large surplus, with about 2.49 million tonnes available for export. Zambia's food-security problem is therefore not a general cereal shortage. It is a crop-specific deficit in wheat, an irrigated winter crop that depends heavily on large commercial farms, financing and water infrastructure.

Why output has fallen. Farmer groups have pointed to weak smallholder participation in wheat and limited access to affordable finance, alongside the costs of irrigation. Wheat competes for land, water and capital with more profitable crops. When local supply falls short, millers turn to imports, and the trade regime decides how easily and cheaply they can do so.

Zambia manages wheat imports with two separate legal instruments, administered by two different ministries.

1. The permit: the Control of Goods Act

The Control of Goods Act lets the government prohibit, restrict or otherwise control imports and exports of scheduled goods by order. Under the Control of Goods (Import and Export) (Agriculture) Order, wheat, including wheat flour, is a scheduled good. No one may import it without a permit issued by the Ministry responsible for Agriculture. Permits are applied for through the Zambia Electronic Single Window.

The permit is the volume lever. In October 2015, with a domestic surplus, the government banned wheat imports outright, allowing them only once local supply was exhausted. Since then, the Ministry has periodically issued permits for specific quantities to cover shortfalls. Whoever holds a permit, and for how much, decides who can import at all.

2. The duty: the Customs and Excise Act

Customs duty is the price lever. Zambia's customs tariff, set in the First Schedule to the Customs and Excise Act, uses bands of 0%, 5%, 15% and 25%, broadly rising from raw materials to finished goods, and grains generally sit in the 15% band. The Act also lets the Minister of Finance suspend duty by statutory instrument for defined goods, periods, importers and quantities. That is the mechanism used for wheat in 2024 and again in 2026.

3. How the two interact

The suspension regulations link the two: duty relief applies only to a holder of a valid Agriculture permit, named in the schedule, within its quota. In effect, Zambia runs a discretionary, firm-specific tariff-rate quota for wheat, but without published criteria for how the quota is set or shared.

4. The regional exception

The duty lever only bites on wheat from outside Zambia's regional free trade areas. Goods that originate in COMESA and SADC free-trade-area partners and meet the rules of origin generally enter duty-free already. Duty suspensions therefore matter most for wheat bought from outside Africa, or for regional supplies that do not qualify as originating. The permit requirement, by contrast, applies regardless of origin.

The pattern. Each intervention has followed the same sequence: a shortfall, a Cabinet or ministerial decision, permits for specific firms, and a time-bound duty suspension for those firms. The scale has risen sharply, from 100,000 tonnes over five months in 2024 to 300,000 tonnes in a single month in 2026, while the time window has shrunk.

The farmer–miller tension. The regime tries to serve two constituencies with opposing interests:

• Farmers want imports restricted around the local harvest, so that domestic wheat sells at a fair price. Farmer organisations have questioned the size of past import approvals.

• Millers and bakers want reliable, affordable supply year-round, and argue that shortages and duty raise bread prices. The Bakeries Association of Zambia called for action in 2024 as wheat and bread prices climbed.

The permit and suspension system lets government move between the two positions season by season. The cost is unpredictability: neither farmers nor millers can plan far ahead when the rules change by statutory instrument every few months.

Who gets the permits. Allocations go to named companies, mostly millers, in quantities set by government. The criteria for choosing beneficiaries and sizing quotas are not published alongside the instruments. Because duty-free access lowers input costs only for those named, that discretion has real competitive consequences in milling.

1. WTO: tariffs yes, discretionary licensing much harder

Zambia has wide room to use tariffs on agricultural goods. Its WTO tariff profile shows a simple average bound rate of about 123% on agricultural products, far above the duties actually applied. In WTO terms, it could raise or lower wheat duty within that ceiling with little legal risk.

The permit system is a different matter. The WTO Agreement on Agriculture requires members not to maintain or revert to measures that were converted into ordinary customs duties during the Uruguay Round, including quantitative import restrictions and discretionary import licensing. GATT Article XI generally prohibits import restrictions other than duties. A regime under which wheat can be imported only with a permit, issued at the government's discretion for set quantities, sits uneasily with those disciplines. Its strongest defence lies in GATT's general exceptions, such as sanitary and phytosanitary grounds, which are a different rationale from managing supply and price.

Small-scale agricultural licensing in developing countries rarely leads to formal WTO disputes. But the legal exposure exists if a trading partner chose to raise it, and it weakens Zambia's position when it objects to other countries' non-tariff barriers.

2. SADC and COMESA

Zambia belongs to both the SADC Free Trade Area and the COMESA Free Trade Area. Both commit members to duty-free trade in originating goods and to removing non-tariff barriers, including quantitative restrictions, subject to defined exceptions and safeguard procedures. Two practical consequences follow:

• Duty: originating regional wheat is generally duty-free already, so suspensions mainly benefit imports from outside the region.

• Permits: applying the permit requirement to regional suppliers is the more likely source of regional friction. Neighbours with exportable wheat surpluses could treat it as a non-tariff barrier through SADC or COMESA reporting mechanisms.

3. AfCFTA

Zambia has ratified the African Continental Free Trade Area Agreement and submitted its tariff schedule. As AfCFTA tariff cuts phase in, more African-origin wheat and flour could qualify for preferential access. The continental agreement also includes a non-tariff barrier mechanism, which applies to discretionary permit requirements as much as to border delays.

4. The legal-design lesson

International trade law points the same way as good domestic policy. A transparent tariff (or a published, rules-based tariff-rate quota with clear allocation criteria) is easier to defend than an open-ended discretionary permit system. It is also more predictable for farmers, millers and traders.

The production target. Under its Grow Zambia Agenda, the government has set a goal of one million tonnes of wheat a year by 2031, more than ten times the latest harvest forecast. Grain traders have pointed to dam construction for irrigation and bringing smallholder farmers into wheat as the main routes to get there. If the target is approached, Zambia would move from a large import dependence back towards self-sufficiency, and possibly an exportable surplus.

The trade-policy dilemma that creates. Building domestic wheat production requires stable, attractive prices for farmers, which argues for limiting cheap imports. Feeding urban consumers affordably argues for easy imports. The current regime manages that tension through discretion. A credible path to one million tonnes may instead require a predictable rule, for example:

• a published tariff-rate quota: a fixed duty-free or low-duty volume each year, allocated by transparent criteria, with the ordinary tariff above it;

• seasonal tariffs that rise around the local harvest and fall in the lean months, set in advance; or

• rules-based duty suspensions triggered automatically by published food-balance thresholds and open to any permit holder on equal terms, instead of firm-by-firm schedules. Variable levies and price bands are best avoided: WTO rules prohibit them for agricultural goods.

Each option is easier to reconcile with WTO and regional rules than discretionary permits, and gives investors in irrigation and milling a clearer basis for planning.

The fiscal angle. The Medium-Term Revenue Strategy consultations launched in September 2026 aim at a broader, more predictable tax system, with less reliance on ad hoc relief. Repeated duty suspensions for named companies sit awkwardly with that aim. Manufacturers' calls to tax finished products rather than inputs add pressure for a structural rethink of how staple-food inputs are taxed.

The 2027 Budget. With SI 65 of 2026 expired, the 2027 Budget is the natural point to decide whether wheat import policy stays discretionary or moves to rules.

Millers

Today: access to imported wheat depends on holding a Ministry of Agriculture permit and, for duty relief, being named in a suspension schedule. Millers outside the schedule pay full duty on non-regional wheat and face a cost disadvantage. What to do: keep permits current, document milling capacity and supply needs to support future allocations, consider sourcing from SADC and COMESA suppliers whose wheat meets origin rules and enters duty-free, and press, through industry associations, for published allocation criteria.

Wheat farmers and commercial growers

Today: the permit system can protect farmers around harvest, but frequent large import windows, such as 300,000 tonnes in one month, can depress prices if poorly timed. What to do: engage the Ministry on the timing of permits against the local harvest calendar, and support moves towards predictable seasonal rules. Investors in irrigation and expansion should factor import-policy risk into financing plans.

Smallholder farmers

Today: wheat remains largely a commercial crop, and the policy push to bring smallholders in depends on irrigation, finance and stable prices. What to do: watch for government and donor programmes tied to the Grow Zambia Agenda, and for any guaranteed-offtake arrangements with millers.

Bakers, food manufacturers and retailers

Today: flour and bread prices track the availability and cost of imported wheat. Short duty windows can bring temporary relief, but not stable prices. What to do: build supply contracts with millers that address duty changes, and push for policy that delivers year-round predictability.

Grain traders and importers

Today: the trade is controlled at both ends, by permits for volume and suspensions for duty. Opportunities appear and disappear by statutory instrument. What to do: track Agriculture permit rounds and Finance suspension SIs closely, verify origin documentation for regional supplies, and avoid buying ahead of a permit.

Regional exporters (SADC and COMESA)

Today: originating wheat and flour enjoy duty-free access in principle, but still need Zambian import permits. What to do: report persistent permit refusals or delays as non-tariff barriers through SADC, COMESA or AfCFTA mechanisms.

Consumers

Today: bread has become a staple in urban Zambia, and its price depends on import policy. The expiry of SI 65 and the return of fuel taxes both add cost pressure in late 2026. What it means: sustained affordability depends on either more local wheat or a more predictable import regime.

Government

The challenge: balancing food security, farmer incentives, fiscal revenue and trade obligations. Discretion offers flexibility but costs credibility, and moving to transparent rules would strengthen investment in wheat production.

Lawyers and trade advisers

The work includes permit and suspension compliance, origin certification for regional imports, competition and administrative-law questions around allocations, and submissions to the 2027 Budget and the MTRS on a rules-based wheat regime.

Do you need a permit to import wheat into Zambia? Yes. Wheat, including wheat flour, is a scheduled good under the Control of Goods (Import and Export) (Agriculture) Order, and imports require a permit from the Ministry of Agriculture.

What customs duty applies to wheat imports? Zambia's tariff uses 0%, 5%, 15% and 25% bands, and grains generally fall in the 15% band. Originating wheat from SADC and COMESA free-trade-area partners generally enters duty-free. Duty on other wheat can be suspended by statutory instrument, as in 2024 and September 2026.

Why does Zambia import so much wheat now? Production has fallen from about 330,000 tonnes in 2015 to about 81,822 tonnes in the latest forecast, leaving a deficit of about 358,318 tonnes in the 2026/27 food balance.

Is Zambia's wheat permit system consistent with WTO rules? It is open to question. WTO agriculture rules restrict discretionary import licensing and quantitative restrictions, while giving wide room to use tariffs within bound rates. A transparent tariff or published tariff-rate quota would be easier to defend.

What is Zambia's wheat production target? One million tonnes a year by 2031, under the Grow Zambia Agenda.