Zambia Suspends Customs Duty on Wheat: What SI No. 65 of 2026 Allows, and Who Qualifies

• The instrument: SI No. 65 of 2026, the Customs and Excise (Suspension) (Wheat) (No. 2) Regulations, 2026, announced by ZRA on 11 September 2026.

• The relief: customs duty on wheat under tariff headings 1001.19.00 and 1001.91.90 suspended to 0%.

• The window: deemed effective from 1 September 2026; the Regulations stand revoked on 30 September 2026.

• The conditions: a valid Ministry of Agriculture import permit, being one of 26 companies named in the Schedule, and staying within each company's approved quantity. The total is 300,000 tonnes.

• Not a blanket waiver: all other wheat imports pay the ordinary customs duty.

• Why: the 2026/27 National Food Balance shows wheat production of about 81,822 tonnes and a deficit of about 358,318 tonnes to be met by imports.

• Watch: refunds for qualifying duty paid from 1 to 11 September, whether the window is extended, and how allocation criteria are applied in future.

On Friday, 11 September 2026, the Zambia Revenue Authority (ZRA) announced that the government had temporarily suspended customs duty on specified wheat imports. The instrument is Statutory Instrument No. 65 of 2026, the Customs and Excise (Suspension) (Wheat) (No. 2) Regulations, 2026.

Not a general waiver. ZRA stressed that the suspension is not a general duty waiver for all wheat importers. Only imports that meet every condition of the SI receive the zero rate. An importer not named in the Schedule, or one without a valid permit, pays the ordinary customs duty. So does a named importer that exceeds its allocation or imports outside the window.

A September-only window. The Regulations cover imports within a single calendar month and lapse on 30 September 2026. ZRA urged eligible importers to monitor their approved quantities closely and complete their imports within the prescribed period.

A suspension, not an amendment. The duty is suspended by regulations made under the Customs and Excise Act (Chapter 322), rather than by an amendment to the customs tariff. That distinction matters. A suspension switches off the duty only for a defined period and on defined conditions, and then falls away. On 1 October 2026, the ordinary tariff applies again without any further legislation.

Three cumulative conditions. An import qualifies for the zero rate only if all three are met:

1. Permit: the importer holds a valid import permit issued by the Ministry responsible for Agriculture. Agricultural import permits, including Control of Goods import permits, are applied for through the Zambia Electronic Single Window (ZESW).

2. Named importer: the importer is one of the 26 companies listed in the Schedule to the Regulations.

3. Quota: the quantity imported falls within that company's approved allocation in the Schedule.

The structure works like a duty-free tariff-rate quota confined to named beneficiaries. Any wheat outside those limits pays full duty.

Retrospective commencement. The Regulations were announced on 11 September but are deemed to have taken effect on 1 September. Because the change favours importers, retrospective operation raises few fairness concerns. It does have a practical consequence, however. A qualifying importer that cleared wheat between 1 and 11 September and paid duty at the ordinary rate may be entitled to recover it, subject to ZRA's refund procedures and proof that all three conditions were met at the time of import.

Documentation at the border. ZRA has asked importers and clearing agents to present all supporting documents, including the import permit, at clearance, so that the zero rate can be applied at entry.

The numbers. Zambia's National Food Balance for the 2026/27 marketing season, based on the Ministry of Agriculture and ZamStats Crop Forecasting Survey, shows a staple cereal surplus overall but a large wheat gap:

The 300,000 tonnes of duty-free wheat under SI No. 65 therefore covers most of the national shortfall.

A declining crop. Wheat output has fallen for several seasons. It dropped by 35% in 2024/25, from about 198,886 tonnes to about 129,524 tonnes, and the latest forecast is lower still. Zambian wheat is almost entirely irrigated and grown over the winter season. It depends heavily on large commercial farms, and farmer groups have linked the decline to weak smallholder participation and limited access to financing.

Bread on the table. Bread and other wheat products have become daily staples in urban Zambia. When local supply falls short, imported wheat costs, which carry the duty, freight and exchange-rate risk, feed quickly into bread prices. Suspending duty for approved millers is meant to cushion that pass-through and keep mills supplied until local stocks recover.

A familiar tool. The government has used this mechanism before. In 2024, it suspended customs duty on 100,000 tonnes of wheat allocated to 21 named companies between 1 April and 30 August, after the drought hit local production. The 2026 instrument is three times larger and shared among more companies, but it runs for only one month. The "(No. 2)" in its title shows it is the second wheat suspension regulation of 2026.

The long-term goal. Under its Grow Zambia Agenda, the government has set a target of one million tonnes of wheat production a year by 2031. Industry groups point to dam construction and bringing smallholders into wheat farming as the path there. Duty suspensions are a bridge to that goal, not a substitute for it.

1. Selective relief and competition. The zero rate is available only to 26 companies named in a Schedule. That is lawful, since the Regulations define their own scope, but it creates a competitive gap. Named millers can import duty-free up to their quotas, while other millers, bakers and traders pay full duty on the same product in the same month. ZRA's notice does not set out how the Ministry of Agriculture decided the allocations. Transparency about allocation criteria, and whether they reflect milling capacity or market share, is the policy question most likely to attract scrutiny. It also bears on competition law.

2. A one-month window for 300,000 tonnes. The Regulations were announced 11 days into a 30-day window. Moving 300,000 tonnes of wheat into a landlocked country within the remaining time is a substantial logistical task. Unless the Regulations are extended or replaced, allocations not imported by 30 September will not receive the zero rate, even if the permit and quota remain.

3. Retrospectivity and refunds. The deemed commencement of 1 September benefits qualifying importers. Any duty paid on qualifying wheat cleared between 1 and 11 September should, in principle, be recoverable. That makes accurate entry records and permit documentation essential.

4. Taxing inputs versus finished goods. The Zambia Association of Manufacturers used the announcement to renew its call for the government to tax finished products rather than the raw materials manufacturers need. The MTRS consultations launched the same month offer a formal channel for that argument. Any structural change to the tariff treatment of industrial inputs would come through the medium-term strategy or the budget, not through one-month suspensions.

5. Local farmers. Duty-free imports ease prices for consumers and millers, but they also compete with Zambian wheat. Farmer organisations have questioned the size of past import approvals and argued that local wheat is preferred by millers. Timing suspensions so they do not undercut the local crop is a recurring tension.

For the 26 named companies:

• Confirm that your Ministry of Agriculture import permit is valid and matches the importing entity named in the Schedule. A mismatch between the permit holder and the scheduled company can cost the zero rate.

• Track imports against your allocation consignment by consignment. Volumes above the quota pay ordinary duty.

• Clear goods on or before 30 September 2026. Entries after the Regulations lapse will be assessed at the ordinary rate unless the government extends or replaces the measure.

• Where duty was paid on qualifying wheat cleared from 1 September, before the SI was announced, assemble the entries, permits and proof of payment and pursue a refund with ZRA.

For clearing agents: Present the import permit and supporting documents at clearance, as ZRA has requested. Check each client against the Schedule before declaring the zero rate, since a wrongly claimed exemption exposes the importer to additional duty, interest and penalties on post-clearance audit.

For importers not in the Schedule: Full customs duty continues to apply. If you believe you should have been included, the practical routes are engagement with the Ministry of Agriculture on future permit allocations and submissions to the Ministry of Finance, including through the MTRS consultations.

For bakers, retailers and consumers: The measure aims to steady flour supply and prices. Its effect on bread prices will depend on how much of the 300,000 tonnes actually arrives within the window and whether millers pass on the duty saving.

What to watch after 30 September: whether the government extends the suspension, issues a (No. 3) regulation, or relies on the ordinary tariff as the local winter harvest comes in. Also watch the 2027 Budget's treatment of wheat and other industrial inputs.

What is SI No. 65 of 2026? The Customs and Excise (Suspension) (Wheat) (No. 2) Regulations, 2026. They suspend customs duty to 0% on wheat under tariff headings 1001.19.00 and 1001.91.90 for qualifying imports.

When does the wheat duty suspension apply? From 1 September 2026, the deemed commencement date, until 30 September 2026, when the Regulations stand revoked.

Who qualifies for zero duty on wheat? Only the 26 companies named in the Schedule, holding a valid Ministry of Agriculture import permit, and importing within their approved quantities. Together, those allocations total 300,000 tonnes.

Is this a general duty waiver for all wheat importers? No. ZRA has stressed that importers outside the SI's conditions continue to pay the applicable customs duty.

What if a qualifying importer paid duty before the SI was announced? Because the Regulations are deemed effective from 1 September, a qualifying importer that paid duty on eligible wheat from that date may seek a refund from ZRA, with supporting documents.

Why did Zambia suspend the wheat duty? To boost supply and stabilise prices. The 2026/27 National Food Balance projects a wheat deficit of about 358,318 tonnes against local production of about 81,822 tonnes.