Active complaints

Showing items 41 to 60 of 84
Complaint number NTB Type
Category 1. Government participation in trade & restrictive practices tolerated by governments
Category 2. Customs and administrative entry procedures
Category 5. Specific limitations
Category 6. Charges on imports
Category 7. Other procedural problems
Category 8. Transport, Clearing and Forwarding
Check allUncheck all		 Date of incident Location
COMESA
EAC
SADC
Reporting country or region (additional)
COMESA
EAC
SADC
Status
 Actions
NTB-001-271 2.6. Additional taxes and other charges 2024-12-01 COMESA Egypt In process View
Complaint: Unipak Nile Ltd., a subsidiary of INDEVCO Group in Egypt, export corrugated boxes to Kenya under the COMESA Agreement.

The Kenyan government imposed a 25% excise duty on corrugated boxes imported from Egypt, violating the principles of the COMESA Agreement and creating an unfair competitive environment. This tax favours local Kenyan producers, some of whom do not pay the required taxes, further distorting the market.

This unilateral action undermines ability of Egyptian exporter to compete fairly and has halted UNIPAK Nile Ltd export operations and expansion plans in Kenya whose exports to Kenya reached $9–10 million annually, particularly in the agriculture and dairy sectors. 		 
NTB-001-218 2.6. Additional taxes and other charges 2024-10-29 Tanzania: Dar es Salaam Kenya In process View
Complaint: Tanzania's Finance Act 2024 introduced an excise duty for ‘’imported’’ products under HS Code 32.08 (Paints and varnishes including enamels and lacquers) of T Shs. 500 per kilo. However, this excise duty has NOT been imposed on any local manufacturers of the same products.

We intend to import items under this heading made in Kenya. Under the spirit of the EAC Trade protocols, which allows for free movement of goods, no duties, taxes or other non-tariff barriers should be imposed on any goods from a EAC partner country that a local manufacturer does not pay.

Therefore we believe this excise duty represents a huge disincentive to Kenyan manufacturers and hindrance to free trade within the EAC.
After writing to the TRA for assistance in the above issue, we were told that the Excise duty is chargeable to all goods falling under that heading even if it is of Kenyan origin (see our letter and their response)
We therefore request your assistance on way forward for us to import items under the HS codes mentioned from Kenya without being subject to this new excise duty of 500 T Shs. Per kilo. 		 
Progress: 1. The SCTIFI of May 2025 noted that, although the Republic of Kenya had not provided transactional evidence on the reported excise duty, broader concerns remain regarding the misapplication of the term “imports” within the EAC context. Partner States were reminded that Article 15 of the Customs Union Protocol on National Treatment prohibits discriminatory treatment of goods originating from other EAC Partner States. The meeting therefore urged all Partner States to harmonize the interpretation and application of the term “imports” in national laws and practices with the EAC legal framework, in order to facilitate intra EAC Trade.
2.During 39th RMC,URT reported that they were still consulting will update by December 2025
3. The 40th RMC was informed that the United Republic of Tanzania is implementing SCFEA Directives and is commited to resolve the NTB by 30th June 2026 		 
NTB-001-204 2.9. Issues related to transit fees 2024-10-01 Rwanda: Gatuna Uganda In process View
Complaint: Republic of Rwanda is charging un harmonized flat rates for vehicles transiting through the Rwanda borders. This is against the agreed principle of distance x weight for transit vehicles.
Uganda is upholding the principle of distance*weight.
  
Progress: 1.The RMC of 17th October 2024 was informed that the NTB on discriminatory road user charges was considered by the 45th Council of Ministers which noted the following submission from Partner States:The Republic of Rwanda informed the Council that:
a) The decision of TCM to calculate the Road User Charges based on weight and distance is discriminatory in nature. It favours big states and discriminates against smaller ones. In view of the above, Rwanda being a small state and landlocked as well cannot accept being punished based on its size.
b) The EAC Partner States had gone beyond this level by harmonizing fees and charges. The harmonization of charges, Levies and fees is ongoing. From 1 7 to 21 June 2024 in Entebbe - Uganda, the Community convened a regional meeting to identify and compile Fees, Levies and charges in Agriculture and Transport Sectors. The Republic of Rwanda proposes to continue in the same spirit of harmonizing charges and fees by putting in place flat rates.
c) That Road User Charges which are calculated based on axle load and distance should only apply to cargo trucks which originate from non-EAC Partner States i.e. SADC & COMESA Countries. EAC Partner States should enjoy equal benefits of regional integration by removing anything identified as barriers
d) That high transportation costs, including levies, fees, and charges, result in higher final prices, impacting businesses, trade, and end consumers, particularly in landlocked countries.
e) There is a need for the EAC to agree on fair and fact-based Road User Charges, not only focusing on micro-level factors like axle load/weight and distance but also considering other factors that favour all of us as a region
f) There is a need to do a study to determine the impact of the Road User Charges on the EAC economies.

The Republic of Burundi informed the Council that:
a) The bilateral meeting between the Republic of Burundi and the United Republic of Tanzania as directed by the TCM has not yet been convened by the Secretariat; and
b) They were still consulting on the matter.
The Council therefore observed that:
a) Road User Charges are intended for infrastructural development and maintenance, end-to-end facilitation of transportation, and not revenue; and
b) All the Partner States participated in the meeting of the SC TCM that adopted the proposals and recommendations of SC TCM on harmonisation of Road User Charges.
The Sectoral Council (TCM) Directed:
a) Partner States to apply the distance + weight (axles) charging principle;
b) Partner States that use flat rates to abolish them and adopt distance + weight (axles) charging principle.
c) Partner States to charge Road User Charges based on the following three categories of vehicles:
• Buses;
• Trucks of three or less axles; and
• Heavy Goods Vehicles of more than three axles (truck with a drawbar trailer or articulated vehicles/semi-trailers);
d) Partner States applying COMESA harmonised rates between themselves to continue doing so;
e) Partner States to reciprocate the distance + weight (axles) rates charged by counterpart states;
f) The Secretariat to prepare Terms of Reference for a study to review the existing Road User Charges and develop harmonised charging formulas to be applicable in the EAC;
g) Secretariat to mobilise funds for the study in (vi) above;
h) Foreign registered vehicles to be charged RUCs on the basis of a round trip from the point of entry to the destination and back provided the destination is within the country of entry;
i) Partner States to always display the gazetted RUC rates at all points of entry; and
j) Partner States to prepare a schedule of distances and their respective computed charges from their point of entry to various destinations within their respective territories and display them at all points of entry.
The Council directed the Secretariat to refer the Harmonization of Road User Charges in the Community back to the Sectoral Council on Transport Communication and Meteorology (TCM) for consideration and report back to the 46th meeting of Council (EAC/CM 45/ Directive 56). As per the directives of TCM, there are two Road User Charges adopted in the Community.
(i) distance + weight (axles) rates
(ii) COMESA harmonised rates of USD 10 per 100 KM
The Republic of Rwanda committed to consult and revert during the 38th RMC.
2.Directives from 18th Sectoral Council on TCM:
The 18th Sectoral Council (TCM) Directed:
(a) Partner States to apply the distance + weight (axles) charging principle;
(b) Partner States that use flat rates to abolish them and adopt distance + weight (axles) charging principle.
(c) Partner States to charge Road User Charges based on the following three categories of vehicles:
● Buses;
● Trucks of three or less axles; and
● Heavy Goods Vehicles of more than three axles (truck with a drawbar trailer or articulated vehicles / semi-trailers);
(d) Partner States applying COMESA harmonized rates between themselves to continue doing so;
(e) Partner States to reciprocate the distance + weight (axles) rates charged by counterpart states;
(f) The Secretariat to prepare Terms of Reference for a study to review the existing Road User Charges and develop harmonized charging formulas to be applicable in the EAC;
(g) Secretariat to mobilize funds for the study in (vi) above;
(h) Foreign registered vehicles to be charged RUCs on the basis of a round trip from the point of entry to the destination and back provided the destination is within the country of entry;
(i) Partner States to always display the gazetted RUC rates at all points of entry; and
(j) Partner States prepare a schedule of distances and their respective computed charges from their point of entry to various destinations within their respective territories and display them at all points of entry.
Updates from the 45th Council of Ministers:
The NTBs on Road User Charges were also considered by the 45th Council of Ministers which noted the following submission from Partner States:
The Republic of Rwanda informed the Council that:
(a) The decision of TCM to calculate the Road User Charges based on weight and distance is discriminatory in nature. It favors big states and discriminates against smaller ones. In view of the above, Rwanda being a small state and landlocked as well cannot accept being punished based on its size.
(b) The EAC Partner States had gone beyond this level by harmonizing fees and charges. The harmonization of charges, Levies and fees is ongoing. From 1 7 to 21 June 2024 in Entebbe - Uganda, the Community convened a regional meeting to identify and compile Fees, Levies and charges in Agriculture and Transport Sectors. The Republic of Rwanda proposes to continue in the same spirit of harmonizing charges and fees by putting in place flat rates.
(c) That Road User Charges which are calculated based on axle load and distance should only apply to cargo trucks which originate from non-EAC Partner States i.e. SADC & COMESA Countries. EAC Partner States should enjoy equal benefits of regional integration by removing anything identified as barriers
(d) That high transportation costs, including levies, fees, and charges, result in higher final prices, impacting businesses, trade, and end consumers, particularly in landlocked countries.
(e) There is a need for the EAC to agree on fair and fact-based Road User Charges, not only focusing on micro-level factors like axle load / weight and distance but also considering other factors that favor all of us as a region
(f) There is a need to do a study to determine the impact of the Road User Charges on the EAC economies.

The Republic of Burundi informed the Council that:
(a) The bilateral meeting between the Republic of Burundi and the United Republic of Tanzania as directed by the TCM has not yet been convened by the Secretariat; and
(b) They were still consulting on the matter.
The Council therefore observed that:
(a) Road User Charges are intended for infrastructural development and maintenance, end-to-end facilitation of transportation, and not revenue; and
(b) All the Partner States participated in the meeting of the Sectoral Council on TCM that adopted the proposals and recommendations of the Sectoral Council on TCM on harmonization of Road User Charges.
The Council directed the Secretariat to refer the Harmonization of Road User Charges in the Community back to the Sectoral Council on Transport Communication and Meteorology (TCM) for consideration and report back to the 46th meeting of Council (EAC / CM 45 / Directive 56).

Update from the 19th Sectoral Council on TCM:
The 19th Sectoral Council on TCM considered the matter and received inputs from Partner States as follows:

United Republic of Tanzania
Tanzania provided a presentation containing the background, findings and recommendations on the issues of Road User Charges as follows:
(i) Prior to the 18th TCM, United Republic of Tanzania was charging a rate of USD 16 / 100km for vehicles over three axles and USD 6 / 100 km for vehicles of up to 3 axles;
(ii) After the 18th TCM, United Republic of Tanzania reviewed her rates to USD 10 / 100km for vehicles above three axles and USD 06 / 100 km for vehicles below three axles
(iii) Under the road-user principle, road users are supposed to pay RUCs to compensate damage caused by vehicles;
(iv) There is need for non-discriminatory charging for road users from foreign vehicles;
(v) Studies reveal that the principles to be used to calculate RUCs should be foreign operators to pay for road use; non-discrimination and charges related to damage caused on the road infrastructure.

Uganda

Uganda submitted that:
(i) All roads are paid for by citizens through taxes and there are no free roads
(ii) Roads have a design life, and the main cause of deterioration is the weight (load carried by vehicles), and the distance moved. The heavier the weight carried the more the degradation and the longer the distance the more the degradation; hence the higher the repair costs required;
(iii) Road user charges are not profits for utilization of the roads but a contribution for the maintenance and repair of the roads;
(iv) The position of the 18th Sectoral Council of TCM is not discriminatory at all as it stipulates that whoever degrades the roads should meet a proportionate contribution to their repair and maintenance; moreover, all Partner States were involved in making that decision;
(v) The weight + distance consideration in the road user charge is an equitable basis for contributing to the maintenance and repair of roads;
(vi) Tanzania has already carried out a study similar to the one being proposed by some Partner States whose results were shared in the meeting, and they support the weight + distance basis for determining the road user charges;
(vii) Deferring the decision on the user charges will cause an unnecessary vacuum which will have serious effects in the road sector; the largest mode of transport at the moment.
The Republic of Uganda therefore supports the position of the 18th TCM.

Burundi

Burundi was of the view that landlocked countries should not be disadvantaged to access the world markets through high transit charges along coastal countries. The fixed rate for RUCs should be maintained. The RUCs include fuel levy for road maintenance, vehicle license fees, international transit fees and others such as congestion fees. The concern raised by Burundi is that RUC should be restricted to transit fees. The road user from neighbouring countries pay for damage to the road network is catered for by the fuel levy.

Rwanda
Rwanda was of the opinion that the rates should be determined by the Committee responsible for fees, charges and levies since that committee handles all sectors of the economy that includes all modes of transport. What was needed was the timeline within which to harmonize the charges. The charges incurred by transporters are actually borne by the citizens, who are the end users of the cargo being transported.

Kenya

Kenya supports the directives of the 18th TCM. However, EAC Secretariat was supposed to prepare TORs for a regional study on harmonized RUCs. Alternatively, the study could be done by a TWG. Through a bilateral arrangement, Kenya and Tanzania harmonized their charges to comply with COMESA rates. But the proposed study by the Secretariat should take into account the principals. further, the quality of roads in the region are not the same, hence there was a need to harmonize the road quality standards so that the cost of maintenance of roads is similar for all countries.
The Secretariat clarified that the draft TORs had been prepared but needed to be updated and submitted to Partner States for review in two weeks. Regarding the modality for the study, the TCM had agreed that the study be carried out by an independent consultant oversighted by a technical working group. The issue of RUCs is also an agenda in SADC and COMESA and, therefore, is a Tripartite issue. Currently discussions are ongoing with the EU and TMA, and it is hoped that a solution will be found.

Conclusion
Uganda, Kenya and Tanzania were of the opinion that the principles of charging agreed by the 18th TCM (distance + weight) should be maintained, as the region awaits the outcome of the study by the Secretariat. However, Rwanda and Burundi positions are that the charges should be further analyzed by the Committee on rates, fees and levies.
The meeting noted that the 19th TCM among others reiterated its directive to Partner States applying the COMESA rates on RUCs as directed by the 18th TCM (EAC / TCM 19 / Directive 08).
The Republic of Rwanda and Republic of Burundi were of the view that the study should come first before implementation of the TCM Directives.
Permanent / Principal / Under Secretaries noted the need for the study by TCM on harmonization of road user charges, as they have direct impact on the cost of doing business in the Region and be subjected to the joint consideration by the Sectoral Council on TCM and SCTIFI.
The Sectoral Council on Trade, Industry, Finance and Investment took note of the directives of the Sectoral Council on Transport, Communications and Meteorology on the harmonized road user charges; and recommended to Council to direct the Secretariat to convene a joint meeting of the Sectoral Council of the Sectoral Council on Transport, Communications and Meteorology and Sectoral Council on Trade, Industry, Finance and Investment to consider the recommendations of the study on the harmonization of road user charges once finalized by the Sectoral Council on Transport, Communications and Meteorology (EAC / SCTIFI 45 / Directive / 47).
3.The 46th Council considered the NTB and gave the following directives:
(a) directed Partner States applying COMESA harmonized rates between themselves to continue doing so (EAC/CM 46 / Directive 17);
(b) directed Partner States to retain status quo with respect to the Road User Charges (EAC/CM 46 / Directive 18); and
(c) direct the Secretariat to prioritize and expedite undertaking the study on harmonization of EAC Road User Charges within six months and report to the 47th Council. (EAC/CM 46 / Directive 19) 		 
NTB-001-197 1.8. Import bans 2024-09-11 Democratic Republic of the Congo: Ministry of External Trade Uganda In process View
Complaint: The Democratic Republic of Congo (DRC) suspended the transfer of soft drinks and beer from other countries, citing that only products from nations with bilateral agreements will be accepted. This suspension directly contravenes the spirit of the East African Community (EAC) and its commitment to fostering free trade and economic cooperation among Partner States.
The Memorandum of Understanding (MOU) that limits acceptance of products to those from countries with bilateral agreements undermines the EAC's principles of regional integration and free movement of goods. It creates unnecessary trade barriers and hinders the seamless exchange of goods between EAC Partner States, which is fundamental to the EAC Customs Union's objectives.
Addressing this issue is critical to ensuring that all EAC partner States can trade without restrictions and continue to benefit from the shared economic goals outlined in the EAC Treaty. 		 
Progress: 1. DRC informed the RMC meeting of 17th October 2024 that the measure is temporary based on WTO Law on Safeguard measures and is meant to protect domestic industries.
The RMC meeting noted that even based on WTO Rules, DRC had not followed the right procedures for the application of the safeguard measures as there was no investigation done to show proof of serious injury or threat to injury caused to DRC factories by the excess transfer of drinks from other Partner States and there was no investigation done to establish the causal link between the closure of the factories and the transferred of goods from EAC Partner States. The meeting further observed that DRC is a member of EAC and any safeguards measures taken should be per the EAC Customs Union Protocol Safeguard Measures stipulated under Article 19.
2.Democratic Republic of Congo informed the meeting that the measure is temporary based on WTO Law on Safeguard measures and is meant to protect domestic industries which were dying as a result of transfers from Partner States. The meeting noted that even based on WTO Rules, Democratic Republic of Congo had not followed the right procedures for the application of the safeguard measures as there was no investigation done to show proof of serious injury or threat to injury caused to Democratic Republic of Congo factories by the excess transfer of drinks from other Partner States and there was no investigation done to establish the causal link between the closure of the factories and the transferred of goods from EAC Partner States. The meeting further observed that the Democratic Republic of Congo is a member of EAC, and any safeguards measures taken should be per the EAC Customs Union Protocol Safeguard Measures stipulated under Article 19.
The Sectoral Council on Trade, Industry, Finance and Investment urged Democratic Republic of Congo to lift the ban on soft drinks and beer from the EAC Partner States as it contravenes the EAC Treaty and report to the 46th Sectoral Council for Trade, Industry, Finance and Investment (EAC / SCTIFI 45 / Directive / 51).
3.During the RMC, DRC submitted that the temporary measure had been removed.
The meeting noted that the NTB was imposed through a Ministerial order and hence agreed that DRC should submit evidence of removal of the temporary measure through the same means to resolve the NTB.
4.During the 39th RMC, DRC requested 2 weeks to resolve the NTB.
5. During the 40th RMC DRC commited to identify the underlying causes of these decisions by the Minister of Trade and to find solutions to strengthen the competitiveness of protected Congolese businesses in December 2026 because these measures have just been extended for 6 months, it is difficult to suspend it before 6 months. The meeting guided DRC to adhere to the Summit Directive to resolve the issue by 30th June 2026 and issue a decree to remove this by June 2026. 		 
NTB-001-227 2024-08-01 Tanzania: Tunduma South Africa New View
Complaint: Certain African countries are now requiring annual renewal of all test reports for our safety footwear crossing their borders. Financially, this translates to approximately R55,000 per test per style. For manufacturers such as ourselves exporting multiple styles annually, the cost could potentially run into millions, significantly impacting our margins but also creating potential delays or disruptions.  
NTB-001-296 2.7. International taxes and charges levied on imports and other tariff measures 2024-07-30 Madagascar: Mauritius In process View
Complaint: Madagascar has imposed a duty of 24% on imports of cartons which it referred to as a 'safeguard duty'. However, Mauritius is of the view that the duty cannot be considered as a safeguard duty given that Madagascar has not taken binding commitment on these products at WTO level. It has simply imposed duties on these products including on the SADC and COMESA Member States. It is violating its regional market access commitments.
Mauritius has requested bilateral consultations with Madagascar on this issue and is still awaiting same. 		 
Progress: 1. On 10 April 2026, Mauritus Focal Point reported that the two countries held several bilateral consultations and where Mauritius informed Madagascar that the imposition of the duty to protect its domestic industry is violating its commitments taken at regional level, namely at SADC and COMESA whereby Members have taken commitments to eliminate duties on all intra-regional trade. Mauritius is therefore of the view that Madagascar is using the safeguard measure as a barrier to intra-regional trade. The measure should have been discussed and negotiated at regional level before imposition.
2.ollowing bilateral consultations held during the SADC Regional NTBs meeting in April 2026, an e-mail was sent to the Ministry of Trade of Madagascar as well as to the ANMCC to explain that the imposition of the safeguard duty violated Madagascar's regional market access commitments at SADC level. It was also highlighted that Mauritius was not the main exporter of these products to Madagascar and yet Madagascar was exempting the main exporters and was discriminating against Mauritius. Mauritius shared the trade data, from TradeMap, which shows that the main suppliers of these products to Madagascar. Mauritius requested that the discriminating duty be eliminated immediately against its exports. The Ministry of Trade of Madagascar agreed to consult with ANMCC with a view to resolving the NTB and a response will be provided to Mauritius by 24 April 2026.
3. In a letter dated 6 April 2026, Mauritius informed the COMESA Secretariat that, through the Mauritian Embassy in Madagascar, three bilateral meetings had been held with Madagascar on 17 December 2025, 20 January 2026, and 3 April 2026. Mauritius further indicated that an additional bilateral meeting was facilitated by the Southern African Development Community (SADC) on 19 March 2026.
4. During a bilateral meeting on 2nd April 2026 Madagascar proposed to waive the 24% tariff for Mauritius but replace it with a tariff rate quota (TRQ). 		 
NTB-001-200 2.4. Import licensing 2024-07-16 Zimbabwe: Ministry of Trade Malawi In process View
Complaint: In June 2024, a member of Malawi Confederation of Chambers of Commerce and Industry, Nuline Textiles Blanket Manufacturers Limited, entered into an agreement with a Zimbabwean company, Middlefield Investment Pvt. Ltd, to supply them with blankets.
Starting on July 11, 2024, Nuline Textiles Blanket Manufacturers Limited completed all the necessary procedures in Malawi to facilitate the export of blankets to Zimbabwe under the COMESA trade agreement to ensure they would receive preferential treatment. On July 16, 2024, the Export Bill of Entry No. E 3645 (dated July 15, 2024) was released by Customs in Malawi, and the consignment was loaded onto Truck No. NE 10666 / NE 10702.
However, on the same day, just as the truck driver was about to depart, Nuline Textiles received a call from their client in Zimbabwe, instructing them to hold off on the shipment. The following day, the client, Middlefield Investment Pvt. Ltd, informed Nuline Textiles that the blankets required an import permit or license, which the client had not yet obtained. They assured Nuline Textiles that they were working to secure the permit as quickly as possible.
On July 18, 2024, Middlefield Investment Pvt. Ltd requested additional time to work on obtaining the import license and asked Nuline Textiles to offload the truck and return the blankets to their warehouse.
As of today, the import license has still not been secured. 		 
Progress: 1. During the SADC Regional Meeting on Non-Tariff Barriers (NTBs) held from 14–15 April 2026, the National Focal Points from Malawi and Zimbabwe met to discuss this NTB.
It was noted that Zimbabwe’s domestic blanket manufacturing industry has been facing significant challenges due to the influx of imported blankets, which has led to market saturation and negatively affected local producers. As a result, the Government of Zimbabwe introduced measures aimed at protecting and supporting the growth of the domestic industry by restricting the importation of blankets.
Furthermore, it was clarified that, in accordance with Statutory Instrument 59 of 2026, the current position allows individuals to import one blanket per person every month. This measure is intended to balance support for the domestic industry while still permitting limited personal imports. 		 
NTB-001-251 2.3. Issues related to the rules of origin 2024-07-05 Tanzania: TRA Kenya In process View
Complaint: URT is subjecting full CET of 35% on ZESTA JAM manufactured in Kenya by Trufoods. The Zesta Jam is manufactured using locally sourced sugar.
We request Tanzania and Kenya to conduct on spot verification on June 2025 to ascertain origin as the jam transferred is using locally manufactured sugar and qualify under the EAC Preferential treatment.
Kenya communicated to TRA vide letter ref: C&BC/HQ/8 Dated 24/9/2024 requesting Tanzania for application for Zesta Jam to be granted preferential treatment. 		 
Progress: 1. During 47th SCTIFI, noted that the matter is administrative and referred to Customs Committee where the two Partner States agreed to conduct bilateral verification to ascertain the origin criteria by end of February 2026
2.The 40th RMC was informed that the United Republic of Tanzania and the Republic of Kenya have convened a verification mission to be undertaken by 11th May 2026 to ascertain the origin of the product 		 
NTB-001-199 1.8. Import bans 2024-06-20 Democratic Republic of the Congo: Ministry of External Trade Uganda In process View
Complaint: The Democratic Republic of Congo (DRC) has instituted a suspension on the transfer of grey cement and clinkers to its Western and Eastern regions. This action raises concerns as it disrupts trade flows and hinders the movement of these essential construction materials within the region.
Such a suspension could have broader implications for trade and economic cooperation within the region, affecting both producers and consumers. The measure may also contravene regional trade agreements aimed at facilitating the free movement of goods, as outlined in the East African Community (EAC) protocols, and could undermine the spirit of regional integration.
A review of this suspension is essential to ensure the continued trade of critical materials and to uphold the principles of regional cooperation.
  
Progress: 1. DRC informed the RMC meeting of 17th October 2024 that the measure is temporary based on WTO Law on Safeguard measures and is meant to protect domestic industries.The RMC meeting noted that even based on WTO Rules, DRC had not followed the right procedures for the application of the safeguard measures as there was no investigation done to show proof of serious injury or threat to injury caused to DRC factories by the excess transfer of drinks from other Partner States and there was no investigation done to establish the causal link between the closure of the factories and the transferred of goods from EAC Partner States. The meeting further observed that DRC is a member of EAC and any safeguards measures taken should be per the EAC Customs Union Protocol Safeguard Measures stipulated under Article 19.
2.The meeting observed that when the Democratic Republic of Congo joined the Community a roadmap was developed to help the Democratic Republic of Congo to be integrated into EAC Projects and Programmes. Democratic Republic of Congo should commence implementation of the roadmap and comply with EAC Laws, among others, the Customs Union Protocol to allow free movement of goods. The Sectoral Council on Trade, Industry, Finance and Investment urged Democratic Republic of Congo to lift the ban on cement and clinker from the EAC Partner States as it contravenes the EAC Treaty and report to the 46th Sectoral Council for Trade, Industry, Finance and Investment (EAC / SCTIFI 45 / Directive / 52).
2.During the RMC, DRC submitted that the temporary measure had been removed.
The meeting noted that the NTB was imposed through a Ministerial order and hence agreed that DRC should submit evidence of removal of the temporary measure through the same means to resolve the NTB.
3.During the 39th RMC, DRC requested 2 weeks to resolve the NTB.
4. During the 40th RMC DRC commited to identify the underlying causes of these decisions by the Minister of Trade and to find solutions to strengthen the competitiveness of protected Congolese businesses in December 2026 because these measures have just been extended for 6 months, it is difficult to suspend it before 6 months. The meeting guided DRC to adhere to the Summit Directive to resolve the issue by 30th June 2026 and issue a decree to remove this by June 2026. 		 
NTB-001-156 8.7. Costly Road user charges /fees 2024-03-09 Rwanda: Rusumo Tanzania In process View
Complaint: Republic of Rwanda is charging USD 270 from Rusumo border to Kigali which is equivalent to USD 80.83 per 100KM, while Tanzania is charging USD 10 per 100KM.This is against the agreed principle of distance x weight for transit vehicle.  
Progress: 1. On 29 April 2024, Rwanda Focal Point reported that : 'Considering the financial implication of these rates, Rwanda was still reviewing this proposal pending the finalization of the EAC study on harmonization of RUC. However, Rwanda will engage URT bilaterally to discuss how to resolve this outstanding issue.
2.The 36th RMC was informed that the charge amounts to 70 USD and is also affecting the Republic of Kenya. The RMC also noted that it is an obligation of the Government to offer security in the Country and it should not be at the expense of the traders. RSS should stop collecting this fee which is not in the RSS Laws and do not attach it to the process of the RTF on the fees, levies and charges.
3.The 46th Council considered the NTB and gave the following directives:
(a) directed Partner States applying COMESA harmonized rates between themselves to continue doing so (EAC/CM 46 / Directive 17);
(b) directed Partner States to retain status quo with respect to the Road User Charges (EAC/CM 46 / Directive 18); and
(c) direct the Secretariat to prioritize and expedite undertaking the study on harmonization of EAC Road User Charges within six months and report to the 47th Council. (EAC/CM 46 / Directive 19)
4.During the 39th RMC meeting, Rwanda reported that they maintain the Status quo as Directed as awaits the finalization of the study. 		 
NTB-001-239 6.6. Border taxes
Policy/Regulatory 		2024-03-01 Kenya: KAJIADO COUNTY Burundi In process View
Complaint: THE COUNTY OF KAJIADO CHARGES TRANSIT FEES OF 2000 KSH PER FOREIGN TRANSIT TRUCKS  
Progress: 1. Kenya informed the SCTIFI that the Amendments to be effected in the 2025 / 2026 Financial year by 1st July 2025
2.During the 39th RMC , Kenya committed to continue engaging internally to resolve the matter and report to the next RMC.
3. During the 40th RMC Kenya informed the meeting that by 30th June the Tax Law will have been reviewed to resolve the NTB. 		 
NTB-001-152 8.8. Issues related to transit 2024-02-07 Tanzania: Dar-es-Salaam Port Zambia New View
Complaint: All the Private Inland Container Depot Operators at Dar Port are refusing to discharge the vessel Ladonna MV for onward delivery of shipment to Zambia and DRC. Private Inland Container Depot Operators that were willing to discharge the vessel have been threatened by trading competitors to the current vessel owner/trader who is a new entrant in the regional market with total loss of current business if they discharged this vessel Dar Port. This is a clear violation of the WTO-TFA (World Trade Organization Trade Facilitation Agreement), AU (African Union), Comesa/SADC Regional protocols and agreements as well as individual Bi-lateral agreements relating to Trade Facilitation. Zambia has worked hard to secure this business to supply chemicals to the World Largest Copper Producer DRC in order to boost regional exports and promote continental economic growth. However, the private sector in Tanzania are now blocking these efforts despite the government working so hard to restore Dar Ports Image as the preferred port of choice on the Eastern Coast of Africa. These actions have potential to make serious negative impact to all 3 countries Tanzania, Zambia & DRC and overall the African Continent and therefore should be addressed to minimize the high costs of doing business.  
Products: 2503: Sulphur of all kinds, other than sublimed sulphur, precipitated sulphur and colloidal sulphur.  
NTB-001-169 7.2. Discrimination 2024-01-01 Burundi: Rugerero Tanzania In process View
Complaint: Republic of Burundi is charging USD 152 Flat rate on Road user Charges from Kobero/Kabangato Bujumbura which is equivalent to USD 65.5 per 100KM, While Tanzania is charging USD 10 per 100KM. This discriminatory charge is contrary to directives made on the 18th Meeting of Sector Council on Transport,Communication and Meteorology  
Progress: 1.The 18th Sectoral Council (TCM) Directed:
(a) Partner States to apply the distance + weight (axles) charging principle;
(b) Partner States that use flat rates to abolish them and adopt distance + weight (axles) charging principle.
(c) Partner States to charge Road User Charges based on the following three categories of vehicles:
● Buses;
● Trucks of three or less axles; and
● Heavy Goods Vehicles of more than three axles (truck with a drawbar trailer or articulated vehicles / semi-trailers);
(d) Partner States applying COMESA harmonized rates between themselves to continue doing so;
(e) Partner States to reciprocate the distance + weight (axles) rates charged by counterpart states;
(f) The Secretariat to prepare Terms of Reference for a study to review the existing Road User Charges and develop harmonized charging formulas to be applicable in the EAC;
(g) Secretariat to mobilize funds for the study in (vi) above;
(h) Foreign registered vehicles to be charged RUCs on the basis of a round trip from the point of entry to the destination and back provided the destination is within the country of entry;
(i) Partner States to always display the gazetted RUC rates at all points of entry; and
(j) Partner States prepare a schedule of distances and their respective computed charges from their point of entry to various destinations within their respective territories and display them at all points of entry.
2. Updates from the 45th Council of Ministers:
The NTBs on Road User Charges were also considered by the 45th Council of Ministers which noted the following submission from Partner States:
The Republic of Rwanda informed the Council that:
(a) The decision of TCM to calculate the Road User Charges based on weight and distance is discriminatory in nature. It favors big states and discriminates against smaller ones. In view of the above, Rwanda being a small state and landlocked as well cannot accept being punished based on its size.
(b) The EAC Partner States had gone beyond this level by harmonizing fees and charges. The harmonization of charges, Levies and fees is ongoing. From 1 7 to 21 June 2024 in Entebbe - Uganda, the Community convened a regional meeting to identify and compile Fees, Levies and charges in Agriculture and Transport Sectors. The Republic of Rwanda proposes to continue in the same spirit of harmonizing charges and fees by putting in place flat rates.
(c) That Road User Charges which are calculated based on axle load and distance should only apply to cargo trucks which originate from non-EAC Partner States i.e. SADC & COMESA Countries. EAC Partner States should enjoy equal benefits of regional integration by removing anything identified as barriers
(d) That high transportation costs, including levies, fees, and charges, result in higher final prices, impacting businesses, trade, and end consumers, particularly in landlocked countries.
(e) There is a need for the EAC to agree on fair and fact-based Road User Charges, not only focusing on micro-level factors like axle load / weight and distance but also considering other factors that favor all of us as a region
(f) There is a need to do a study to determine the impact of the Road User Charges on the EAC economies.
3. The Republic of Burundi informed the Council that:
(a) The bilateral meeting between the Republic of Burundi and the United Republic of Tanzania as directed by the TCM has not yet been convened by the Secretariat; and
(b) They were still consulting on the matter.
4. The Council therefore observed that:
(a) Road User Charges are intended for infrastructural development and maintenance, end-to-end facilitation of transportation, and not revenue; and
(b) All the Partner States participated in the meeting of the Sectoral Council on TCM that adopted the proposals and recommendations of the Sectoral Council on TCM on harmonization of Road User Charges.
The Council directed the Secretariat to refer the Harmonization of Road User Charges in the Community back to the Sectoral Council on Transport Communication and Meteorology (TCM) for consideration and report back to the 46th meeting of Council (EAC / CM 45 / Directive 56).
Update from the 19th Sectoral Council on TCM:
The 19th Sectoral Council on TCM considered the matter and received inputs from Partner States as follows:
United Republic of Tanzania
Tanzania provided a presentation containing the background, findings and recommendations on the issues of Road User Charges as follows:
(i) Prior to the 18th TCM, United Republic of Tanzania was charging a rate of USD 16 / 100km for vehicles over three axles and USD 6 / 100 km for vehicles of up to 3 axles;
(ii) After the 18th TCM, United Republic of Tanzania reviewed her rates to USD 10 / 100km for vehicles above three axles and USD 06 / 100 km for vehicles below three axles
(iii) Under the road-user principle, road users are supposed to pay RUCs to compensate damage caused by vehicles;
(iv) There is need for non-discriminatory charging for road users from foreign vehicles;
(v) Studies reveal that the principles to be used to calculate RUCs should be foreign operators to pay for road use; non-discrimination and charges related to damage caused on the road infrastructure.
Uganda
5. Uganda submitted that:
(i) All roads are paid for by citizens through taxes and there are no free roads
(ii) Roads have a design life, and the main cause of deterioration is the weight (load carried by vehicles), and the distance moved. The heavier the weight carried the more the degradation and the longer the distance the more the degradation; hence the higher the repair costs required;
(iii) Road user charges are not profits for utilization of the roads but a contribution for the maintenance and repair of the roads;
(iv) The position of the 18th Sectoral Council of TCM is not discriminatory at all as it stipulates that whoever degrades the roads should meet a proportionate contribution to their repair and maintenance; moreover, all Partner States were involved in making that decision;
(v) The weight + distance consideration in the road user charge is an equitable basis for contributing to the maintenance and repair of roads;
(vi) Tanzania has already carried out a study similar to the one being proposed by some Partner States whose results were shared in the meeting, and they support the weight + distance basis for determining the road user charges;
(vii) Deferring the decision on the user charges will cause an unnecessary vacuum which will have serious effects in the road sector; the largest mode of transport at the moment.
The Republic of Uganda therefore supports the position of the 18th TCM.
Burundi
6. Burundi was of the view that landlocked countries should not be disadvantaged to access the world markets through high transit charges along coastal countries. The fixed rate for RUCs should be maintained. The RUCs include fuel levy for road maintenance, vehicle license fees, international transit fees and others such as congestion fees. The concern raised by Burundi is that RUC should be restricted to transit fees. The road user from neighboring countries pay for damage to the road network is catered for by the fuel levy.
Rwanda
7. Rwanda was of the opinion that the rates should be determined by the Committee responsible for fees, charges and levies since that committee handles all sectors of the economy that includes all modes of transport. What was needed was the timeline within which to harmonize the charges. The charges incurred by transporters are actually borne by the citizens, who are the end users of the cargo being transported.
Kenya
8.Kenya supports the directives of the 18th TCM. However, EAC Secretariat was supposed to prepare TORs for a regional study on harmonized RUCs. Alternatively, the study could be done by a TWG. Through a bilateral arrangement, Kenya and Tanzania harmonized their charges to comply with COMESA rates. But the proposed study by the Secretariat should take into account the principals. further, the quality of roads in the region are not the same, hence there was a need to harmonize the road quality standards so that the cost of maintenance of roads is similar for all countries.
9.The Secretariat clarified that the draft TORs had been prepared but needed to be updated and submitted to Partner States for review in two weeks. Regarding the modality for the study, the TCM had agreed that the study be carried out by an independent consultant oversighted by a technical working group. The issue of RUCs is also an agenda in SADC and COMESA and, therefore, is a Tripartite issue. Currently discussions are ongoing with the EU and TMA, and it is hoped that a solution will be found.
Conclusion
10. Uganda, Kenya and Tanzania were of the opinion that the principles of charging agreed by the 18th TCM (distance + weight) should be maintained, as the region awaits the outcome of the study by the Secretariat. However, Rwanda and Burundi positions are that the charges should be further analyzed by the Committee on rates, fees and levies.
11. The meeting noted that the 19th TCM among others reiterated its directive to Partner States applying the COMESA rates on RUCs as directed by the 18th TCM (EAC / TCM 19 / Directive 08).
The Republic of Rwanda and Republic of Burundi were of the view that the study should come first before implementation of the TCM Directives.
Permanent / Principal / Under Secretaries noted the need for the study by TCM on harmonization of road user charges, as they have direct impact on the cost of doing business in the Region and be subjected to the joint consideration by the Sectoral Council on TCM and SCTIFI.
The Sectoral Council on Trade, Industry, Finance and Investment took note of the directives of the Sectoral Council on Transport, Communications and Meteorology on the harmonized road user charges; and recommended to Council to direct the Secretariat to convene a joint meeting of the Sectoral Council of the Sectoral Council on Transport, Communications and Meteorology and Sectoral Council on Trade, Industry, Finance and Investment to consider the recommendations of the study on the harmonization of road user charges once finalized by the Sectoral Council on Transport, Communications and Meteorology (EAC / SCTIFI 45 / Directive / 47).
The 46th Council considered the NTB and gave the following directives:
(a) directed Partner States applying COMESA harmonized rates between themselves to continue doing so (EAC/CM 46 / Directive 17);
(b) directed Partner States to retain status quo with respect to the Road User Charges (EAC/CM 46 / Directive 18); and
(c) direct the Secretariat to prioritize and expedite undertaking the study on harmonization of EAC Road User Charges within six months and report to the 47th Council. (EAC/CM 46 / Directive 19)
12.The 46th Council considered the NTB and gave the following directives:
(a) directed Partner States applying COMESA harmonized rates between themselves to continue doing so (EAC/CM 46 / Directive 17);
(b) directed Partner States to retain status quo with respect to the Road User Charges (EAC/CM 46 / Directive 18); and
(c) direct the Secretariat to prioritize and expedite undertaking the study on harmonization of EAC Road User Charges within six months and report to the 47th Council. (EAC/CM 46 / Directive 19)
13.During 39th RMC, Burundi informed the meeting that, she is still waiting for the outcome of the study.
14. During the 40th RMC Burundi informed the meeting that they are implementing the status core directed by the 46th Council and hence considers the complaint resolved as Council lagalised the charges each Partner State was charging at that moment. Other Partner States, however, were of the view that status core as directed by the Council does not solve the challenge for harmonised road user charges and hence insisted on the finalisation of the study on Harmonisation of EAC Road User Charges. 		 
NTB-001-155 2.6. Additional taxes and other charges
Policy/Regulatory 		2023-11-03 Egypt: Egyptian Tax Authority Zambia In process View
Complaint: On November 3, 2023, the Egyptian Official Gazette published Law No. 177 of 2023 amending provisions of the Value Added Tax Law promulgated by Law No. 67 of 2016, including the provisions related to the tiers of cigarette taxation. The amendments to Serial 1/B of Law No. 177 of 2023 bluntly prohibits imported cigarettes from of the first tier and restricts them to “cigarettes produced by local factories”, which favors and gives preferential treatment to local products.

It is worth noting that the addition of the aforementioned provision has significant repercussions on the competitive ability of other companies, especially that the first tier has the lowest priced cigarettes in the market and are more economical for citizens. Consequently, this contradicts COMESA national treatment article, causing harm through the discrimination of specific products that may lead to market monopolization.

Various companies manufacture their brands in factories in COMESA member states and import and sell it in Egypt. However, the recent tax amendments that imposed a value-added tax on low-priced cigarettes prevent companies from importing cigarettes and limits sales to local production. 		 
Progress: 1. Egypt to respond on the NTB with Zambia on the online reporting system by 1st Week of June 2024
2. During the NTBs workshop held from 17 -19 April 2024, the Egypt and Zambia agreed that this issue would form part of the agenda for the proposed bilateral meeting. The dates for the bilateral meeting to be facilitated by the Secretariat would be determined by the two Countries.
3. On 7 May 2024, Egypt Focal Point reported that consultations with the relevant national authorities were ongoing, and Egypt would provide updates as soon as possible.
4. On July 22, 2024, the Secretariat had a meeting with the exporter after receiving a reminder on the NTB dated 3rd July 2024. The aim of the meeting was to get the gist of the NTB and share other necessary information to start facilitating the resolution of the NTB.
5. As a policy issue, the NTB was escalated to Stage 1 on cooperation and elimination of NTBs under the COMESA Regulations on NTBs Elimination and on 26 August 2024, Zambia was advised to formally request the Secretariat to facilitate the bilateral meeting on behalf of the exporter. This comes after Zambia reported that she wrote to the Egyptian Embassy regarding the NTB but there was no immediate response and that was concerning as the matter was very urgent.
6. In a letter dated 2 September 2024, Zambia requested the Secretariat to facilitate a bilateral meeting between the two countries. The Secretariat has started preparation for the bilateral meeting including drafting a letter to Egypt and developing a draft agenda for the bilateral meeting between the two Member States.
7. On 24 September 2024, Zambia and Egypt convened a bilateral meeting and recommendations from the discussions as presented in the draft report were as follows"
i) Zambia will engage Roland Imperial Tobacco Company to consider selling their products under Tier 1 for favorable market conditions in Egypt.
ii) Egypt will consult with its Ministry of Health on the health requirements for importation of cigarettes and communicate with Zambia in due course.
iii) Egypt will further start the process of reviewing the Law 177 to remove elements of discrimination between imported and local products.
iv) Egypt will look into the possibility of allowing the 15 consignments in transit from the Tobacco Company to ascertain if there is a possibility of a rebate and if the rebate can be held over for the period until the Law is revised.
8. On 4th June 2025, the two Member States convened a bilateral meeting and the following updates were received:
i. Egypt is to consult with the Ministry of Finance on the NTB which has the elements of discrimination between the imported and local products; and
ii. The Secretariat to facilitate the next bilateral meeting between the two Member States, by October 2025.
9. On 25th August 2025, the representative of Tobacco informed the Secretariat that Egypt has gazetted legislative amendment to its Value Added Tax (VAT) Law in relation to tobacco under Law No. 157 of 2025, dated July 17, 2025. The key changes introduced by the amendment include:
i. Increased VAT rates on cigarettes.
ii. Structured annual increases of 12% to both minimum and maximum retail price thresholds for cigarettes, beginning November 5, 2025, and continuing through 2028.
The new cigarette price thresholds are as follows:
i. Local cigarettes priced below EGP 38.88 will increase to EGP 48.
ii. Cigarettes priced between EGP 38.88 and EGP 56.44 will increase to a range of EGP 48 to EGP 69.
iii. Imported brands priced up to EGP 56.44 will increase to EGP 69.
10. On 31 October 2025, Secretariat sent a reminder to Egypt on the outstanding discussions on the matter, however on 3 November Egypt updated that they has started taking the necessary steps to coordinate with the relevant national authorities from the Ministry of Finance and the Tax Authority to consider the proposal to amend the law. 		 
NTB-001-134 2.6. Additional taxes and other charges 2023-05-08 Kenya: Egypt In process View
Complaint: The Middle East Glass Manufacturing Company and its subsidiaries: 1) Misr Glass Manufacturing and 2) Middle East Glass Containers in Sadat. Being largest glass container manufacturer in the Middle East & North/East African region located in Egypt. The company has maintained strong business relation with Republic of Kenya over the last decade(s) being key glass supplier for more than 12 years to most of big manufacturing companies (some of them are big multinational companies) with superior track record of commitments in terms of quality standards and satisfying customer demands, continuity of supply, meeting their expectations and needs of glass container.
Egypt is member state of COMESA trade agreement (Common Market for Eastern and Southern Africa), which support enhancing the relation and volume of trade between the company and Kenyan customers. Below table shows the amounts that has been exported to Kenya in the last 5 years:

2019 = US$ 10,325,336
2020 = US$ 10, 929, 362
2021 = US$ 8, 122, 525
2022 = US$ 8, 848, 972
2023 = US$ 7,322,062

Starting March 2020, Kenya has applied Extra Excise of 25% on all imported glass bottles (excluding pharmaceutical glass bottles) – copy attached - which limit the advantage given to all COMESA countries. This law has been already appealed by other glass container manufacturer in Tanzania and they successfully were able to remove it.
In addition, Starting September 2023, Excise duty applied on imported glass bottles has been increased to be 35% instead of 25% with no clear reason or justification. This additional duty applies by the Finance Act No. 4 of 2023 – copy attached - has prevented Middle East Glass from its fair competition against other glass manufacturers in the region and also against the agreement of COMESA.
We believe the main reason behind all these amendments is to support the local producer Milly Glass Works Ltd. Address: Liwatoni Road, Mvita, Road, Mombasa, Kenya, Near the Mombasa Yacht Club.
Hence, we seek support to waive all the glass exported from Egypt to Kenya from implementation of the excessive Excise Duties similar to the case of Tanzania case. 		 
Progress: 1. During the NTBs workshop 17th - 19th April 2024, Egypt reported that the legislation is still providing a barrier to Egypt exports to Kenya. The two countries agreed that this issue will form part of the agenda for the proposed bilateral meeting by 28th June 2024.
2. On 28 August 2024, Egypt requested the Secretariat to facilitate a bilateral meeting between themselves and Kenya regarding this NTB. After the Secretariat initiated the bilateral meeting, on 3 September 2024, Kenya agreed to hold the bilateral meeting, following a stakeholder consultative meeting held on the same day.
3. Following the agreement by the Member States to conduct national consultations and explore the the opportunity for the inclusion of the NTB on the Joint Trade Committee (JTC) agenda, the Secretariat to facilitate a bilateral meeting between the two Member States to provide updates on the NTB by October 2025. 		 
NTB-001-108 3. Technical barriers to trade (TBT)
B9: TBT Measures n.e.s. 		2023-05-02 Kenya: Kenya Bureau of Standards South Africa In process View
Complaint: A South African Exporter has reported that the Kenyan authorities have issued notification on new requirements for exporters and importers to record all trademarks in aid to protect intellectual properties and prevent importation of counterfeit goods into Kenya under the Anti-Counterfeit Act, No. 13 of 2008. This requirement, while it is , has cost implications to the Wine industry of South Africa who have to incur additional costs to enforce it. Further, it is not clear how it will work in practice or how it will be managed especially that applications are done on line and that the registration has 1 year validity, after which it has to be renewed annually.The cost to record is estimated at USD25 000 for the Brands exported to Kenya. The exporters also have the same products analyzed by ISO 17025 labs and pay USD265 per container to confirm full compliance.

The Exporter is of the view that whenever products are to be exported, are certified by SGS as to who the proprietors of the products are. The annual required registration would result in increased cost of the products. 		 
NTB-001-203 2.6. Additional taxes and other charges
Policy/Regulatory 		2023-04-12 Malawi: Malawi Revenue Authority Zambia In process View
Complaint: Malawi Laundry & confectionary imports into Zambia are levied MK20,000 to MK25,000 per invoice, where
Zambian products going to Malawi are charged with 13-27% (MBS, Surcharge, Excise duty). 		 
Progress: 1. NFPs for the two countries to hold bilateral meeting by August 2024. This issue was also discussed during bilateral meeting held in Addis Ababa at the 4th NTBs Forum . Malawi to report progress from internal consultations.
2. During the 10th Meeting of the TTFSC held on 2 – 4 July 2025, Zambia requested Malawi to confirm if the export subsidies is still implemented. However, Malawi did not provide an update on the status of the NTB. 		 
NTB-001-105 7.8. Consular and Immigration Issues
Policy/Regulatory 		2023-03-01 Zambia: Ministry of Home Affairs Mozambique Complaint registered with REC View
Complaint: New Migration Fees Introduced by The Republic of Zambia
The Ministry of Industry and Commerce of Mozambique, has received a complaint/ notification from the Mozambican private sector regarding to the introduction of migration fees by the Zambian Government Authorities. The referred fees are applicable only to foreign citizens, promptly implementing the respective price list, since the beginning of June 2022.
From a practical point of view, and with regard to the resulting costs, for road freight transporters in particular, the introduction of these fees means that, for the fee valid for 1 year, the amount to be paid is approximately US$1250.For one way trip (immediate validity), the amount to be paid is approximately US$490.This fee apply only to foreign road freight transporters, including Mozambicans, and does not apply to locals.
Other measures which Zambia introduced and are adding to cost of doing business are (1). the introduction of a ban on filling fuel reserve tanks for foreign trucks, with a view to obliging them to purchase fuel in Zambian territory, (2). the introduction of road charges and, (3). the obligation to send 50% of the transported cargo to the Republic of Zambia.
We believe that the way which the Government of Republic of Zambia acts violates the Agreements signed by it in relation to the policies adopted by SADC, in the field of road transport, for which the Member States agreed to develop a harmonized transport policy that safeguards the principles of equal treatment, non-discrimination, reciprocity, fair competition, harmonized operating conditions that promote the creation of an integrated road transport system in the region.
In this regard, Mozambique requests the intervention of the Zambian Authorities, with a view to the immediate elimination of the Migration fees, introduced in this country, as well as other deterrents to carrying out the cargo transport activity in the Country, and applicable only to carriers foreigners or alternatively, and if the country is not available to do so, immediately use the principle of reciprocity, by applying the same measures to carriers in that country, if they are in transit or enter the national territory
  
Progress: During the SADC regional workshop held in April 2026, Mozambique and Zambia Focal Points agreed that Mozambique will look for proof of the fees, if not then it was agreed that this matter be regarded as resolved. Zambia we will reach out to relevant authorities to establish the nature and status of the fees and provide feedback.  
NTB-001-342 3. Technical barriers to trade (TBT)
B42: TBT regulations on transport and storage 		2023-01-01 Zimbabwe: Kariba In process View
Complaint: Administrative arbitrary ban of buses using Kariba border by ZIMRA AND ZAMBIA REVENUE AUTHORITY previously buses were Administratively suspended to use Kariba border siting strength of the the bridge now it has come with another angle prior to the suspension Kariba border was doing well in terms of facilitating trade for small scale cross border traders  
NTB-001-092 2.6. Additional taxes and other charges 2022-12-01 Uganda: Uganda Revenue Authority Egypt In process View
Complaint: Egypt has received a complaint from one of our exporters who also intends to invest in Uganda and establish a manufacturing plant of the products ( processed food products ) he is currently exporting to Uganda and the importing company is “ Afromarket King – Imports &Exports LTD” . The complaint is concerned with the imposition of high taxes and duties , in addition to top ups on exported goods by Egypt of processed food in specific the following HS codes including :
200990 210330
210320 210390
210390 210320
210690 210390

The incident of imposing high tax , duty values and top ups has been repeated on two separate occasions:

1- On Entry no. C116891: (latest incident )

A consignment of foodstuff (Ketchup and BBQ sauce HS codes : 2103200010; 2103900090) of a value of USD 5672.64 (five thousand six hundred seventy two dollars and sixty four cents ) was subjected to very high values of tax and duty of UGX 25,979,379 which was paid on 1/12/2022. However, before the goods were released a top up of UGX 18,508,223,57 was imposed ( still not paid ) .
This shipment has not enjoyed the COMESA preferential rates , despite the fact it is accompanied by a COMESA certificate .

2- ON ENTRY NUMBER C58313 AND C58340 : (earlier incident)
The first assessment for both the entries was for C 58313 amounting to 14,351,118 with a delivery terms F.O.B and C 58340 amounting to 9,272,169shs with a delivery term CIF , that is a total of 23,623,287shs. Despite the amount was too much the importing company paid off the tax( paid on 18/6/2022, it was also noted to him that this high valuation was a mistake made by the clearing agent according to the officer. It is worth mentioning that the total value of goods in both entries was USD 3982 (three thousand and nine hundred eighty two US dollars).

After clearing all dues, a top up of 38,755,713shs was imposed, delaying the release of the goods. Yet, the importing company paid the top up amount to release the goods on 2/7/2022.
The reasons given at the time for the top up:
i. Alternative values had to be used as the primary method of determining the customs value of imported goods.
ii. As stated by the officer, “the information availed to customs shows that we are first-time importer of the assorted goods from Egypt. The sales contract No: UG-001 of 10/03/2022 indicates payment terms of 60days from Bill of Lading date. They wondered how the supplier can allow such terms to a first time buyer without a letter of credit or a bank guarantee”. It is worth mentioning that the importing company has a manufacturing all these food stuff in Egypt.

Furthermore, despite the fact that the importer submitted a COMESA certificate to qualify for the COMESA rates he was informed that goods don’t qualify for COMESA since they are sensitive products being manufactured by the local communities.
Having reviewed the Circulation of Uganda’s current Sensitive List to COMESA Member STATES(attached), it is evident that none of those products are in the sensitive list except for nectar juices (HS code 200990) which are subject to the EAC common external tariff of 35%.

It is worth mentioning that on the two occasions of the above mentioned cases “ Afromarket King – Imports &Exports LTD” made an Appeal to the Assistant Commissioner Trade , Uganda Revenue Authority , Head Office. Yet, no reply was received to date.
In light of the above , Egypt respectfully requests that the Ministry of Trade ,Industry &Cooperatives acting as the Focal point of Uganda looks into the reasons of imposing such high taxes and duties in addition to top ups , in coordination with Uganda Revenue Authority . The imposition of such high taxes , duties and top ups have the effect of discouraging new Egyptian exporters and investors from accessing Uganda’s market.
Egypt is looking forward to the explanation and clarifications of the Ministry of Trade, Industry & Cooperatives , as soon as possible, with respect to the taxes , duties and top ups noting that the first case consignment Entry no. C116891 (latest incident ) is not released yet and pending the payment of the top-up which is unjustifiable in Egypt's view .

 
Progress: 1. During the consultations held during the 12th TWG on TBT-SPS- NTBs , Uganda and Egypt Focal Points agreed to organise a bilateral consultative meeting between the Focal Points , Revenue Authorities and affected companies on Tuesday 24th Januray 2023
2. A bilateral meeting between the two countries was held on 1st Feb. 2023 where it was observed that Uganda Revenue Revenue Authority had not granted preferential treatment to the goods in accordance with COMESA rules
and therefore charged the high duties . In that regard, the meeting agreed, among other things, that Uganda provides the sensitive list of products exempted from receiving preferential treatment by 3rd Feb. 2023 to establish if the affected products were on the sensitive list of products or not. Subsequently, the Secretariat uploaded onto the online system the following documents forwarded by Uganda to the Secretary General:
a. EAC CET 2017
b. Finance Act 2014 and
c. Uganda Finance Bill 2016
3. The Secretariat convened a stakeholders bilateral consultative meeting to take place on 22 August 2023. However the meeting could not take place because stakeholders from Uganda were not available.
4. During the 3rd meeting of the COMESA Regional NTBs Forum held on 20- 22 September 2023 , it was agreed that this NTB will be considered resolved subject to Uganda providing evidence in the online platform of the following : .
i. The sensitive list has been revised and goods from Egypt are granted COMESA preferencies ;
ii. URA is applying valuation for the goods in according to the WTO rules;
iii. The process to refund duties and other charges has commenced and the client was officially notified accordingly; and
iv. Uganda to share the revised sensitive list and also evidence on communication to client.
5. During the NTBs workshop 17th - 19th April 2024 in Nairobi, it was agreed that Uganda to upload sensitive list of products by 30th April 2024. Further, Uganda is requested to inform Egypt whether or not the refund to the Egyptian exporter has been paid by 30th April 2024.
6. During the 10th Meeting of the TTFSC held on 2 – 4 July 2025, the following updates were received:
i. Egypt requested Uganda to provide an update regarding the refund to the importer, however Uganda did not provide an update at the time.
ii. With regards to the updated Sensitive List, the Secretariat sent Uganda a reminder email to submit the updated list as per the decision by the 45th Meeting of the Council of Ministers. 		 
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