Government data attracted far more attention last week after the release of the latest GDP numbers than it normally does. For advocates of greater use of administrative data for evidence-based policy-making, this attention is welcome, particularly if it helps concerned citizens draw the right lessons from the unsavoury debates dished out by the mainstream media.
Richard Thaler’s Misbehaving: The Making of Behavioural Economics, described as “wildly disruptive” by Michael Lewis, contains numerous insights. But the central takeaways from the book are these two mantras:
- We can’t do evidence-based policy without evidence
- If you want to encourage someone to do something, make it easy.
In the same week, Jawaharlal Nehru Custom House, or JNCH, released its Time Release Study 2026: Bottlenecks to Breakthroughs, following the release of the National Time Release Study 2026, covering fifteen major customs ports in the country, by the Central Board of Indirect Taxes and Customs not very long ago.
Indian Customs has been conducting these annual port-specific and national studies, presenting cargo release times, since 2017 and 2021, respectively, using a methodology developed by the World Customs Organization, which has also been acknowledged as a preferred performance measurement tool in the Trade Facilitation Agreement (TFA) of the World Trade Organization.
Trade Facilitation
The National Time Release Study has evolved as an excellent tool for annual assessment of the performance consequences of the government’s initiatives to promote trade facilitation, proxied by continuously improving cargo release times.
Relevant to the debate regarding data quality, it is interesting to recall that the Indian Time Release Study has preferred to rely solely on electronic data sourced from the customs automated system and digital platforms of the custodians, as distinct from the manual survey method recommended by the WCO.
The decision to place reliance on administrative data, made possible by nearly 100% automation of the cargo clearance process in the country, was also in some sense a push-back against the findings of perception-based surveys like the World Bank’s Ease of Doing Business (EODB) and OECD's Trade Facilitation Index (TFI).
More specifically, EODB 2018 reported JNCH average import release time for 2017 at 267 hours, based on a perception-based survey relating to the import of auto-components from South Korea. TRS 2018, based on more robust administrative data, reported that the average import release time for all commodities imported during the sample first week of the calendar year was 181 hours.
For imports of all auto-components, it was much lower at 92 hours, albeit higher at 127 hours for auto-components imported from South Korea, perhaps due to higher scrutiny arising from Free Trade Agreement (FTA) benefits. Over the years, the robustness of NTRS data has become well accepted.
The early JNCH TRSs identified the “Path to Promptness”, comprising TFA measures that helped expedite import clearances, viz. pre-arrival processing, enabling documentary processes to start even before the vessel has docked at the port; risk-based decisions to either check documents or, in very limited cases, subject the consignment to physical examination; and the provision of even higher levels of facilitation to trusted Authorised Economic Operators (AEO), a global best practice as well. Continuing to track the progress in the implementation of these measures, TRS 2026 reports that the overall average import release time improved from 181 hours in 2017 to a very commendable 66 hours this year, while recognising that it still falls short of the Government target of 48 hours.
Along with tracking the progress of good practices, which were found to be insufficient to achieve the quantitative targets, the NTRS proceeded to identify “impact dissipating actions”, such as amendments by traders to self-declared details, and sometimes piecemeal and ambiguous queries by departmental officers, as well as the lukewarm response to schemes such as the AEO programme. Based on these findings, the Government has taken various steps, particularly to reduce the time taken in payment of duty, a step where maximum delays have persisted, by allowing duty deferment, subject to certain conditions and for select importers, and allowing suo motu release to become effective immediately on payment of duty.
Make It Easy
In devising the next round of measures, Thaler’s second mantra must be given the highest priority. For example, the role of the AEO programme in improving import release time is well established, with JNCH reporting an average release time of 41 hours, almost half that for non-AEO bills of entry at 77 hours.
However, NTRS has reported that only 42% of bills of entry at seaports are those submitted by AEOs. Though significantly higher than 32–33% in the earlier years, there is a lot of scope to increase this share, if only the processes of enrolment, validation, review and renewal are made easy.
A more detailed review of these reports shows the immense potential of privileged administrative data for regular performance measurement that can support specific public policy goals, which can be as varied as evaluation, control, budgeting, motivation, promotion, celebration, learning and improvement.
These studies also show the limitations of trade facilitation in improving export release time, which is essential, if not more so than streamlining import processes, to boost Indian exports. But that’s for another day.
* This author had piloted the early JNCH TRS and NTRS.
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