SRO 691 is a concise but important notification. Its strength lies in its simplicity — but that also requires careful interpretation.
Below is a refined clause-by-clause breakdown.
1. Short Title & Commencement
The Order is titled:
“Transit of Goods through territory of Pakistan Order, 2026”»
• Immediate enforcement
• No phased rollout
TFN View:
This signals urgency and intent to operationalize transit without delay.
2. Definitions
The SRO defines key terms:
(i) Cross Stuffing
Transfer of goods between containers or modes under customs rules
👉 Practical meaning:
Allows flexibility at ports or en-route if required.
(ii) Customs Security
Financial guarantee equivalent to duties/taxes
👉 Practical meaning (ground reality):
• Transit cargo must be financially secured — however, in practice this may evolve into:
• TIR guarantee (international system)
• Bonded carrier guarantee (domestic system)
• AND potentially additional/custom guarantees imposed by Customs
TFN Critical Observation:
«There is a real risk that this mirrors the Afghan Transit model,
where multiple layers of guarantees are required — even when TIR is used.»
If that happens:
- TIR loses its efficiency advantage
- Cost of transit increases significantly
- Operational simplicity is compromised
👉 This is a key area to watch in implementation.
(iii) Shipper
Any party contracting carriage
👉 Standard definition — aligns with international practice
(iv) Transit
Movement across Pakistan where origin and destination are outside Pakistan
👉 Critical point:
Confirms non-import status of cargo
(v) Transit Transport Corridor
Defined route for transit
👉 Legal basis for route enforcement
3. Scope of the Order
«Applies to goods from a third country, destined for Iran, via Pakistan»
• Direction is clearly defined
• Port-based transit is implied
TFN Interpretation:
This enables:
«Cargo arriving at Karachi/Gwadar → moving inland → exiting into Iran»
4. Designation of Transit Transport Corridors
The SRO lists multiple routes, effectively forming two main corridors:
A. Karachi → Taftan Corridor (Inland Route)
Via:
• Hub
• Khuzdar
• Quetta
• Dalbandin
• Taftan
✓ Established corridor
✓ Connects to Zahedan
B. Gwadar / Karachi → Gabd (Rimdan) Corridor (Coastal Route)
Via:
• Gwadar
• Turbat
• Gabd
✓ Emerging corridor
✓ Connects to Chabahar region
5. Customs Procedures
«Governed under Customs Act 1969 and FBR procedures»
👉 No new system introduced
Operational implication:
• Processing through Pakistan Single Window (PSW)
• Movement under:
• TIR
OR bonded carriers
TFN Consolidated Interpretation
SRO 691 is:
✓ A route notification order
✓ A legal facilitation instrument
✓ A port-to-border transit enablement
Key Implementation Risk
«If multiple guarantees are imposed (as seen in Afghan Transit),
the corridor will face cost and efficiency barriers from day one.»
🔑 Final TFN Position
«Clarity exists in policy»
