| Complaint number |
NTB Type
|
Date of incident |
Location |
Reporting country or region (additional) |
Status |
Actions |
|
NTB-001-359 |
5.5. Import licensing requirements |
2026-02-17 |
Zimbabwe: |
Botswana |
New |
View |
|
Complaint:
|
Business Botswana member - Flotek has reported that In Zimbabwe, imports exceeding USD 5,000 require an import licence issued through the Zimbabwe Revenue Authority (ZIMRA). These licences are generally valid for only three months and must be secured before goods can enter the market. The company indicated that most of its consignments exceed the threshold, meaning nearly all exports to Zimbabwe are affected by the licensing requirement. Delays in obtaining or renewing licences can disrupt deliveries, delay customer projects, and create financial losses. In addition, Zimbabwe requires mandatory Bureau Veritas (BV) pre-shipment inspections for trucks entering the country, with inspection fees charged on a per-invoice basis rather than per shipment. Flo-Tek stated that the fees range between USD 250 and USD 300 per invoice, resulting in significant cumulative costs for shipments containing multiple invoices. According to the company, this creates unnecessary inefficiencies and increases the cost of exporting into Zimbabwe.
Flo-Tek maintains that the NTBs imposed by these countries undermine Botswana’s export competitiveness, increase the cost of cross-border trade, and contradict the broader objectives of SADC regional integration and trade facilitation. The company therefore requested that relevant mechanisms be triggered to resolve this NTB. |
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|
NTB-001-358 |
8.8. Issues related to transit |
2026-02-02 |
South Africa: |
Botswana |
New |
View |
|
Complaint:
|
Business Botswana member -Flo-Tek has highlighted challenges relating to road transit bonds and cabotage restrictions. The company noted that South African authorities shifted responsibility for road transit bonds from transporters to the importer or owner of the goods. As a result, Flo-Tek is now directly responsible for administering and carrying the liability associated with transit bonds for shipments passing through South Africa. The company argues that this arrangement places an unfair financial and administrative burden on exporters, despite the transporter being in physical control of the cargo during transit. Flo-Tek also raised concerns about South Africa’s cabotage regulations, which prevent Botswana-registered trucks from completing deliveries in situations where the South African entity is the invoice holder or where goods are destined for onward export to neighbouring countries such as Lesotho. Consequently, cargo must be transferred to South African trucks before final delivery, resulting in additional transport arrangements, delays, cargo handling risks, and increased logistics costs. Flo-Tek believes these restrictions are largely protectionist in nature and hinder regional trade integration.
Flo-Tek maintains that the NTBs imposed by these South Africa undermine Botswana’s export competitiveness, increase the cost of cross-border trade, and contradict the broader objectives of SADC regional integration and trade facilitation. |
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|
NTB-001-357 |
2.6. Additional taxes and other charges |
2026-03-30 |
Zambia: |
Botswana |
New |
View |
|
Complaint:
|
Business Botswana member, Flo-Tek is currently facing trade barrier in Zambia, Flo-Tek raised concerns regarding the imposition of a mandatory entry permit fee of approximately USD 541 per truck shipment for Botswana-registered trucks transporting PVC and HDPE pipes. According to the company, the fee applies regardless of the size or value of the shipment and significantly increases the cost of exporting to the Zambian market, particularly for smaller and more frequent consignments. In addition, Zambia imposes a 20% Selected Goods Surtax (SGS) on PVC pipes, HDPE pipes, and fittings. While the surtax is reportedly intended to protect local manufacturers, Flo-Tek argues that Zambia does not manufacture the large-diameter pipes supplied by the company, meaning there is no local industry being protected in this particular market segment. The company therefore views the surtax as an unnecessary trade barrier that inflates infrastructure project costs and weakens the competitiveness of Botswana manufacturers in the regional market.
The NTB's undermine Botswana’s export competitiveness, increase the cost of cross-border trade, and contradict the broader objectives of SADC regional integration and trade facilitation. The company therefore request resolution through bilateral and regional trade mechanisms. |
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|
NTB-001-103 |
2.13. Issues related to Pre-Shipment Inspections |
2019-02-01 |
Botswana: Pioneer Gate |
South Africa |
In process |
View |
|
Complaint:
|
Since 2019, goods exported from S. Africa to Botswana require additional certification from a Certified Accreditation Body ( see attached ) This is now over and above documentation from an ILAC accredited test house that has always been acceptable in the past.
This is an additional cost that must be passed on the consumers ( inflationary aspect )
Measures such as this are puzzling as they are not in the spirit of the African Continent Free Trade Agreement and actually restrict the free flow of goods
It is a questionable move as with Botswana being a member of SACU, the country relies on S. Africa to disburse shares of import duties collected at S. African ports |
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NTB-001-309 |
7.4. Costly procedures |
2025-12-13 |
|
|
In process |
View |
|
Complaint:
|
KEBS rejected the application to renew the Illovo's Diamond Mark certification which expired on 13Dec2025. The new requirement states that Illovo should appoint a Kenyan registered agent or open up a branch in Kenya. This agent will be awarded a Diamond Mark certificate on behalf of Illovo. This is costly and it also restricts product quality visibility through to the end-user. |
|
|
Progress:
|
On 29 March 2026, Kenya Focal Point reported that:
a) All importers that have the Diamond Mark are required to have an Agent. Under our Diamond Mark scheme, the permit is issued to a local registered entity. The entity assume all responsibilities of the product. This is applied across all manufacturers under the Diamond Mark Scheme.
b) An imported/ Exporter can still ring the product in to the country without the agent under the normal import process procedure either through the PVOC Scheme or Destination Inspection. This will allow the visibility that client is seeking.
c) Illovo can still export the sugar to Kenya without an agent outside the Diamond Mark. Hence there is no NTB and the matter should be considered as resolved
2.Kenya advised that there is another option to faciloitate resolution of the NTB is where the importer can register his products and comply with the requirements. Once registered using the portal at KEBS they will be accepted without inspection. |
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Products:
|
1701.99: Cane or beet sugar and chemically pure sucrose, in solid form (excl. cane and beet sugar containing added flavouring or colouring and raw sugar) |
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NTB-001-329 |
5.3. Export taxes |
2026-02-20 |
Ethiopia: Galafi |
Ethiopia |
In process |
View |
|
Complaint:
|
The Small scale cross border traders who were able to export different live animals and agricultural products to Djibouti through the Galafi Border are required to pay export tax per head of the livestock at the border. The total export amount allowed in a month is up to USD 1,000 per cross border trader that are found in different parts of the Afar region.
The export tax in Dewele border is not yet implemented and it is considered as a discriminatory compared to the Dewele border of the country. |
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Products:
|
0106.13: Live camels and other camelids [Camelidae], 0104.20: Live goats and 0703.10: Fresh or chilled onions and shallots |
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|
NTB-001-330 |
2.3. Issues related to the rules of origin |
2026-03-11 |
Mozambique: DGA - Mozambique
SARS - South Africa |
Mozambique |
In process |
View |
|
Complaint:
|
Conferring of origin in a member state on non-originating material. This then affects the issuance of a SADC certificate for the issuing country being Mozambique.
Mozambique customs authority and DGA consider that the process taking place within Mozambique, does not confer origin.
The exact same process carried out in South Africa, receives a SADC certificate from SARS.
SARS as the importing country does not dispute or challenge that the process confers origin and is satisfied that the process under which a SADC certificate is issued, and therefore receives preferential duty in the importing country is sufficient and complies with the SADC trade agreement.
While the SADC agreement, lists simple processes, which do not confer origin, under chapter 63 there is a specific declaration made, where rags is included, before the word, except, and then it lists exceptions. It states that for chapter 63, origin is conferred, the requirement stated is " manufacture from materials of any heading except that of the product"
What is peculiar, is that the issuing country being Mozambique contends the conference of origin, but it has not been raised by the importing country being South Africa.
We know, with absolute certainty, that a SADC for the exact same process is issued by South Africa for exports to Mozambique and to Botswana, and neither of these countries have ever referred them back for investigation or referral on the back of the SADC certificate as is the protocol and possibility if there is a contention. |
|
|
Progress:
|
On April 15th, 2026, Mozambique focal point reported that they are working with the relevant authorities to provide a response on this matter. Within 10 days, we will update the information. |
|
|
Products:
|
6310.10: Used or new rags, scrap twine, cordage, rope and cables and worn-out articles thereof, of textile materials, sorted |
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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-001-296 |
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). |
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|
NTB-001-333 |
2.3. Issues related to the rules of origin |
2026-02-01 |
Zambia: Chirundu |
|
In process |
View |
|
Complaint:
|
ZIMRA is not clearing the products originated in Zambia using the STR Declaration even the products are under the Common List. The goods are subjected to the submission of Formal Customs Declaration and subject to pay customs duties, instead of granting preferential tariff treatment under the COMESA FTA. |
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|
Products:
|
2009.12: Orange juice, unfermented, Brix value <= 20 at 20°C, whether or not containing added sugar or other sweetening matter (excl. containing spirit and frozen) |
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|
NTB-001-231 |
2.6. Additional taxes and other charges |
2024-12-12 |
Tanzania: Immigration |
Rwanda |
In process |
View |
|
Complaint:
|
Illegal fees on Rwandan nationals crossing into Tanzania more than three times a month.$100 is charged on Rwandan nationals crossing into Tanzania more than three times a month, this was identified by the Central Corridor Team during a survey from Rusumo to Dar es Salaam port. |
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|
Progress:
|
1. During the 38th RMC, Tanzania informed the meeting that the fee is not illegal, but it is a special pass paid once in 90 days to all EAC Citizens. However, if the person exits URT within 90 days and wants to re-enter URT the person will again be charged $100.
The meeting agreed that the matter be referred to the Regional Implementation Committee on the Common Market Protocol for further discussion and resolution
2. During the 40th RMC, the United Republic of Tanzania informed the meeting that specific Business Pass are issued to persons for the purpose of undertaking temporary special assignments or professional activities as per the EAC CMP. Tanzania further clarified that for EAC Citizens a fee of USD 100 is charged for this category of persons. The 40th RMC noted that cross-border traders who cross the borders several times should not be subjected to this fee and recommend that the URT to sensitize relevant authorities on the application of business passes and Secretariat to sensitize on the Simplified Trade Regime (STR) in the EAC by 30th December 2026. |
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|
NTB-001-288 |
1.7. Discriminatory or flawed government procurement policies |
2025-08-20 |
Tanzania: TRA |
Kenya |
In process |
View |
|
Complaint:
|
URT imposition of discriminative Excise Duty on Unilever Soaps, detergents and bleaches -10%; Industrial Development Levy-5-15%
VAT Rate-18%
Impact to business
• Increased production costs due to excise and industrial levies.
• Reduced competitiveness against imported products, especially if inputs are taxed.
• Pressure on pricing, potentially leading to higher consumer prices or reduced margins.
Limited relief for manufacturers despite EAC integration goals.
This tax favours local Tanzania producers of whom do not pay the 10% excise duties, further distorting the market.
3401.11.00 Soap and detergents 10%, 3401.19.00 Soap and detergents 10%, 3402.50.00 Soap and detergents 10%, 3402.90.00 Soap and detergents 10% |
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NTB-001-311 |
5.3. Export taxes |
2026-03-02 |
Democratic Republic of the Congo: Kasumbalesa |
|
In process |
View |
|
Complaint:
|
It is reported by the Truckers Association of Zambia that the DRC Revenue Authority - General Directorate of Taxes, 3 weeks ago, introduced an import and export tax of about $85, and this has been reported at Kasumbalesa Border Post. The procedure and rationale in which this was introduced is unknown to Zambia, therefore, feedback is sought from our colleagues in DRC on this matter. |
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Progress:
|
1. On 9 March 2026, DRC Focal Point reported that they were going to contact the Authorities in the Katanga Province to actually verify this payment.
2. On 4 May 2026, Zambia Focal Point reported that they had not received any feedback or official communication from the complaint. Additionally, no complaint had been brought forward again by Zambian nationals so teh matter can be regarded as a resolved. |
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NTB-001-312 |
5.10. Prohibitions |
2021-12-01 |
Zimbabwe: Kariba |
Zambia |
In process |
View |
|
Complaint:
|
Republic of Zimbabwe maintains a ban on Eggs entering Zimbabwe from Zambia at all shared borders. Zambia is yet to see any documentation/legislation that supports this measure to date. Considering the spirit of the shared COMESA vision and Oneness, this measure has affected traders who export Eggs into Zim, considering also that this product is on the agreed STR common list.
Selected Commodities: Zimbabwe has reportedly prohibited the importation of the following commodities from Zambia; Eggs, Milkit, Biscuits, Kombucha, Mazoe juice and other beverages and Second-hand clothes.
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NTB-001-302 |
2.6. Additional taxes and other charges |
2026-02-06 |
Zambia: ZAMBIA REVENUE AUTHORITY |
Kenya |
In process |
View |
|
Complaint:
|
10% Selected Goods Surcharge (SGS) Imposed by Zambia
Zambia has introduced a 10% Selected Goods Surcharge (SGS) on CIF value, identified only upon reviewing the attached ASYCUDA import entry for Kenya manufacturer Carbacid LTD recent CO₂ shipment. This surcharge was unexpected and has a significant commercial impact on our exports.
CO₂ Is COMESA Originating and Should Not Be Charged discriminatively.
Carbacid LTD food grade CO₂ (HS 281121) is fully COMESA originating, supported by a valid Certificate of Origin for every shipment.
Under COMESA Treaty Article 49(1), Member States must remove existing NTBs and refrain from imposing new restrictions on goods originating from COMESA countries.
The COMESA NTB Regulations (2020) prohibit new discriminatory or trade restrictive measures.
The SGS surcharge therefore constitutes:
• A discriminatory charge
• A trade restrictive NTB
The surcharge raises the Kenya manufacturer landed cost and undermines Kenya’s products competitiveness in Zambia. As CO₂ is essential for soft drink bottling, the measure operates as a protectionist NTB in violation of COMESA obligations.
Zambia to remove the 10% SGS surcharge on COMESA originating CO₂ and restores compliance with COMESA trade rules, ensuring Kenyan goods are not unfairly discriminated against. |
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NTB-001-272 |
2.6. Additional taxes and other charges |
2025-07-08 |
Kenya: Kenya Revenue Authority (KRA) |
Uganda |
In process |
View |
|
Complaint:
|
Kenya has introduced a 25% excise duty on Aluminium products falling under chapter 76 of the Harmonized System, as stipulated in its financial Act of 2025.This measure is in contravention o the East African Community (EAC) Common Market Protocol, which seeks to promote the free movement of goods among member states. The imposition of this duty not only disrupts intra- regional trade and delays business operations but also undermines the spirit of regional and economical cooperation within the EAC. |
|
|
Progress:
|
1. During 39th RMC, Kenya informed the meeting that the matter is being handled internally, it is at the parliament level
2.During the 40th RMC Kenya informed the meeting that by 30th June the Tax Law will have been reviewed to resolve the NTB. |
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|
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-001-289 |
1.7. Discriminatory or flawed government procurement policies |
2025-06-20 |
Rwanda: Rwanda Revenue Authority |
Kenya |
In process |
View |
|
Complaint:
|
Rwanda has introduced a 39% excise duty on juice products manufactured in Kenya and transferred into Rwanda. The excise subjected to Kenya juice is a charge on import. EAC is a local market, additionally, as stipulated in its financial Act of 2025.This measure is in contravention of the East African Community (EAC) Common Market Protocol, which seeks to promote the free movement of goods among member states. The imposition of this duty not only disrupts intra- regional trade and delays business operations but also undermines the spirit of regional and economical cooperation within the EAC. |
|
|
Progress:
|
1. The issue will be included in the list to be submitted for consideration by the 2nd Extra Ordinary SCFEA.
2. This issue was listed among the discriminatory charges imposed on Kenyan products by the Republic of Rwanda. Rwanda is treating Kenyan juice as an import and applying a charge, yet this movement is a transfer within the EAC Customs Union—not an import. As directed by SCFEA and SCTIFI, all discriminatory charges be removed, and therefore Kenya requests Rwanda to consider Kenya juice as a transfer and not an import and cease applying this levy.
3. During the 40th RMC Rwanda informed the meeting that by 30th June the Tax Law will have been reviewed as directed by SCFEA to resolve the NTB |
|
|
NTB-001-279 |
1.7. Discriminatory or flawed government procurement policies |
2025-05-19 |
Tanzania: Tanzania Dairy Board |
Kenya |
In process |
View |
|
Complaint:
|
Tanzania Dairy Board discriminatively charging 1.75% F.O.B value of on Kenya dairy produce on Pasteurized whole
Milk, Skimmed, Condensed, Yoghurt, ice cream and Powdered milk.
TDB is violating the Article 15 of the EAC Custom Union Protocol on national treatment. Same treatment as Tanzanian products in terms of charges. |
|
|
Progress:
|
1. During 39th RMC, URT informed the meeting that this is among the identified list of fees, levies and charges hence it is to be considered during harmonization process
2. On 26 March 2026, Kenya Focal Point further reported that The Tanzania Dairy Board (TDB) is discriminatively imposing a charge of 1.75% of the F.O.B. value on Kenyan dairy products—specifically pasteurized whole milk, skimmed milk, condensed milk, yoghurt, ice cream, and powdered milk. This measure cannot be justified as for ‘harmonisation’ as it clearly violates the EAC Treaty and the EAC Customs Union Protocol, which prohibit Partner States from applying discriminatory charges on goods originating from Kenya and other EAC countries.
Furthermore, both SCTIFI (Sectoral Council on Trade, Industry, Finance and Investment) and SCFEA (Sectoral Council on Finance and Economic Affairs) have expressly directed all Partner States to remove all discriminatory levies and consider EAC products as transfer and not import. In line with these directives, the United Republic of Tanzania (URT) should cease the application of this charge and fully comply with the established EAC legal framework and Council decisions.
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 |
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NTB-001-281 |
1.7. Discriminatory or flawed government procurement policies |
2025-08-08 |
Tanzania: TRA |
Kenya |
In process |
View |
|
Complaint:
|
Tanzania imposition of discriminatory Excise Duty on exports/Transfers that hinders Chocolate export from Kenya into Tanzania. The same is not subjecting to chocolate manufactured in Tanzania |
|
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Progress:
|
1. During 39th RMC, URT informed the meeting that she is still consulting and will report back by December 2025
2. 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 |
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