Active complaints

Showing items 21 to 40 of 51
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
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Date of incident Location
COMESA
EAC
SADC
Reporting country or region
COMESA
EAC
SADC
Status
Actions
NTB-000-803 2.6. Additional taxes and other charges 2018-02-28 Tanzania: Importation into Tanzania Malawi In process View
Complaint: CORI Ltd visited Tanzania last year to look for export markets for cooking oil in Tanzania. CORI was informed that the government in Tanzania does not promote/support importation and that Tanzania has a 15% surcharge on the importation of cooking oil.  
NTB-000-802 2.6. Additional taxes and other charges 2018-02-28 Zimbabwe: Ministry of Industry & Commerce Zimbabwe Malawi In process View
Complaint: CORI Ltd visited Zimbabwe last year to explore their local market to check if there is potential for their products (cooking oil). CORI Ltd discovered that they could not export cooking oil into Zimbabwe as the government in Zimbabwe has instituted Statutory Instrument (S.I 64) that banned imports of a variety of products (cooking oil is one of them).

Zimbabwe also has 40% (or $0.50/litre) duty on cooking oil imports
 
Progress: On 3rd April 2018, Zimbabwe Focal Point reported that SI 64 of 2016 has been consolidated with other SIs through SI 122 of 2017 which was gazetted on 22 September 2017. The consolidated SI removed the requirement for import and export licences on some products. The new requirements of SI 122 of 2017 will be recorded in the Non Tariff Measures database for Zimbabwe  
NTB-000-800 2.3. Issues related to the rules of origin 2017-11-01 In process View
Complaint: Lack of preferential treatment to Cerelac product manufactured in Kenya and exported into Tanzania on the basis that Kenya via Legal Notice No.EAC/70/2017 was granted stay application of CET in respect to raw sugar.

EAC Legal Notice No.EAC/70/2017 granted Kenya duty remission on raw sugar not a stay. For a company to import, it has to follow due process of gazettement. So far no company has applied, no DRS application received and no company has been gazetted to import raw sugar.
 
NTB-000-797 1.14. Lack of coordination between government institutions 2018-01-02 South Africa In process View
Complaint: Distell, a Tape Town based exporting company is experiencing delays and high costs of processing SAD500 entries and SADC certificates for their wine exports to Zimbabwe. The current procedure where the Distell driver cannot take the SAD500 entry and SADC certificate to Customs to have it stamped and signed over the counter is cumbersome and costly for the company. The company has to wait for at least 2 days for either the release notification or the stamped and signed SADC certificates. This leads to the truck waiting at the depot for the documents, which results to either standing time cost at the depot or standing time at the border.
The requirement is as follows: Distell Company loads Bulk orders in Tanktainers and Drums from Monis in Paarl or Adam Tas in Stellenbosch, Cape Town which goes by road to Zimbabwe. Currently export documents can only be done by the Freight forwarder immediately after the Tanktainer or Drums are loaded. Export documentation cannot be processed earlier, as company has to wait for the final weight loaded into the truck. The alternative method to use flow meters and cut off the loading on a specific amount of liters is used because it is does produce accurate measurements.
Actual Current process for Bulk - Tanktainers (Tankerservices transport)
- Truck to be arranged for loading very early on a Tuesday morning @ 07:00am
- Most of the time 2 to 3 truckloads which will load one after the other.
- The following is all also done on the Tuesday:
o The wine is loaded.
o Distell invoices and forward the relevant documentation to Imperial Logistics in Johannesburg.
o Imperial Logistics processes the Customs entry via EDI.
- Once EDI release is received (after at least 2 days), Imperial Logistics sends the Release notification via e-mail.
- Distell advises Tanker Services to collect the relevant documentation and leave for the border.
- Imperial Logistics will have the SADC certificate stamped at the border.
- Tanker services driver to collect the original SADC certificates at the border.
A permanent solution for exporters in Cape Town to provide an over the counter service for our SAD500 & SADC entries is required.
 
Products: 2204.10: Sparkling wine of fresh grapes  
NTB-000-788 2.3. Issues related to the rules of origin 2017-06-01 Ethiopia: All Ethiopian banks. Egypt In process View
Complaint: Ethiopian banks are requiring invoices for sales to Ethiopian customers to be stamped by a Chamber of Commerce in Egypt as validation for letters of credit, which is contrary to COMESA rules. Indeed, as per Rule 10 of the COMESA Protocol on Rules of Origin, the only documentary evidence to demonstrate that a good originates from a COMESA Member State is a certificate of origin (not invoices). Consequently, any company should be able to issue an invoice from any country inside or outside the COMESA region, as long as the origin of the products themselves is correctly documented according to COMESA rules through a certificate of origin. Ethiopian banks should comply with Rule 10 of the COMESA Protocol on Rules of Origin and stop requiring invoices to be stamped by predetermined entities (including, inter alia, by a Chamber of Commerce in Egypt).  
NTB-000-781 2.6. Additional taxes and other charges 2015-11-19 Mozambique: Delegação Aduaneira de Goba (Road) Eswatini In process View
Complaint: An import surcharge is applie to all imported sugar (i.e. SADC and non-SADC) ased on the difference between Dollar-based reference price (DBRP) and the world marker price quoted on the New York #11 and London no.5 commodity exchanges for brown and white sugars respectively. The current DBRP is US$806 per tonne for brown sugar and US$932 per tonne for white sugar.  
Progress: 1. On 5th November 2017, Mozambique Focal Point updated that Mozambique is still working on the matter and a multisectorial team, which involves Revenue Authority (Customs and International Cooperation Directorate) and Ministry of Industry and Trade has been established to analyse the matter and the answer will be sent as soon as possible..

2. On 1st September 2017, Mozambique and Swaziland Focal Points reported that they are urgently following up with relevant authorities to assist the complainant . All efforts are being made to resolve the matter expeditiously.
 
NTB-000-776 8.7. Costly Road user charges /fees
Policy/Regulatory
2017-05-05 Tanzania: Ministry of Works, Transport & Communications Uganda In process View
Complaint: Tanzania still charges US$500 to Uganda trucks compared to US$152 charged on Rwanda trucks.  
Progress: 1. During the Extra Ordinary SCTIFI, the issues of Road User Charges were referred to the Sectoral Council on TCM for resolution.
2. The meeting Senior Officials meeting that met in October, 2017 noted that this NTB would be resolved if Road User Charges were harmonised with in the EAC. The meeting therefore urged the Secretariat to expedite the process of harmonisation of the Road User Charges to facilitate resolving this NTB.
3.The Ministerial bilateral meting held on 19 December 2018 directed that Experts and Senior officials of the two countries should engage and harmonize the charges and report progress to the Ministers by end of June 2019.
4. The 27th Regional Monitoring Committee meeting held from 29 April - 3 May noted that Tanzania was committed to resolve this NTB as agreed during the Bilateral meeting. Uganda requested that this NTB be discussed during the PSs level
Bilateral meeting.
 
NTB-000-769 2.3. Issues related to the rules of origin 2017-05-05 Tanzania: Tanzania Revenue Authority Kenya In process View
Complaint: Despite Kenya Tobacco raw material being fully sourced in Kenya, the manufacturers are required to pay 80 per cent higher excise for cigarettes exports into Tanzania. Cigarettes manufactured in Kenya exported to Tanzania required to have a local 75% tobacco.  
Progress: 1. The Bilateral meeting that took place in January 2018 noted that Kenya and Tanzania need to harmonize their domestic taxes and local content policies and request the EAC Secretariat to fast track the process of harmonization in all partner states.The meeting also agreed that the two Partner States should take cognizance of the national treatment provision under Article 15 of Custom Union Protocol not to impose directly or indirectly internal taxation on goods from other partner states in excess of that imposed on similar domestic goods.
2.During the Bilateral Meting held from 23- 27 April 2019, both parties reiterated their 2018 commitments to champion harmonization of their domestic taxes and local content policies and therefore request the EAC Secretariat to fast track the process of harmonization. In this regard, United Republic of Tanzania maintained that, both parties should implement the 2018 bilateral agreement on harmonization of their domestic taxes and local content policies. Kenya, however, maintained that this is a trade restrictive matter and should be resolved at the Community level in accordance to Article 15(2) of the EAC Customs Union Protocol. The bilateral Meeting therefore agreed to escalate this matter to the Council of Ministers.
 
NTB-000-754 7.3. Corruption 2017-07-01 Mozambique: Police checkpoint in Dondo Mozambique In process View
Complaint: A week or so ago one of the drivers got stopped at Dondo Check Point in Mozambique.
They told the driver that his International Driving Permit (AA) was fake.
We ended up having to pay a fine of 50,000 mts equating to $833.00. With administration charges we have paid out $1,026.00 (fine attached)
The AA have verified our Driving permit is actually not fake.
Attached the report from our agent in Beira of Beloma Mr. Dirk Dieltiens.
Attached his report and correspondence.
Attached the old and new Permit from AA and the letter confirming documentation is in good order.

 
Progress: The Mozambique Focal Point reported that consultations had been initiated with the focal point in the Ministry of Industry and Trade, who will get in touch with the police to clarify this issue, as soon as possible  
Products: 98 - 99: Service  
NTB-000-751 8.7. Costly Road user charges /fees 2017-05-01 Zambia: Ministry of Trade Zambia In process View
Complaint: Transporters have noted the many benefits of using Botswana as a transit instead of Zimbabwe. It is a well known fact that Zimbabwe borders are slow and congested, there are many tolls we pay (for no service), numerous road blocks (harrassment of drivers and lack of adherence to SADC appreciation of the Soveriegnty of Foreign COF's), high fuel costs and failing road infrastructure. The completion of the Kazungulu Bridge is a much anticipated event that will give transporters access to an efficient and cost effective transit to Zambia.

On the 11th November 2016, Zambia issued SI 85 of 2016, The Tolls Act in which the Second Schedule Section A and B outlines Entry Tolls for COMESA/SADC and other Countries. Botswana was not included under SADC and awarded tolls higher than other SADC States. On the 1st May 2017, Botswana retaliated by issuing an Amendment of the Road Traffic and Road Transport (Permits) regulations, 2017. Under this Amendment, tolls were increased and in turn, Zambian Transporters handed a hefty penalty. The result is that as a Zambian Transporter our Transit Fees through Botswana increased by 70%.

This makes the Botswana route unattractive and given the congestion at Kazungulu, we have had to run through Zimbabwe again. We are delayed here by congestion, delays in ZIMRA electronic sealing processes and run the gauntlet as described above.

Surely the whole idea of building the Kazungula Bridge is to improve the flow of traffic through Botswana and create economic advantage? With the increase in the tolls in a tit for tat manner, building the bridge is a waste of time.

Could the member States please meet and look at treating each other in the spirit encouraged by SADC.
 
NTB-000-745 6.1. Prior import deposits and subsidies 2017-01-19 Zambia: Kazungula Ferry South Africa In process View
Complaint: “SARS received an escalation in January 2017 from Deloitte, regarding a complaint by fuel exporters from South Africa. The complaint is regarding Zambia Revenue Authority (ZRA) Circular No. 9 of December 2016, notifying its officers “that all fuel imported from South Africa under preferential arrangements should be subjected to payments of a monetary deposit equivalent to the full customs duty payable.

The modalities of collection of the said deposit will be temporarily suspending both SSA and SDC preferential rates against goods of HS 2710.12.10 and 2710.19.10 until the Origin verification process is finalised”.

SARs is of the view that the collection of the monetary deposits on fuel imported from South Africa is against the spirit of the SADC Protocol on Trade and the WTO, as this treatment applies only to oil imported from South Africa. It pre-supposes that the ZRA is nullifying the SADC Protocol on Trade relating to those specific products without following the proper procedures regarding derogation on infant industries.

SARs has tried several times to get answers from Zambia Revenue Authority (ZRA) to explain their reasoning behind the circular and so far, they have not provided any correspondence to this matter.
 
Progress: 1. On 25th January 2018, Zambia Focal Point reported that the deposit was a temporal measure pending origin inquiry. The inquiry has reached advanced stage and will soon be concluded and stakeholders will be fully advised on the way forward. This is consistent with the provisions of the protocol on trade which allow for collection of such deposits where necessary, while origin verification is underway.

2. During the 15th meeting of the SADC Sub Committee on Trade facilitation held in may 2017, Zambia reported that consultations will be undertaken with relevant authorities and report back.
 
NTB-000-742 3. Technical barriers to trade (TBT)
B1: Prohibitions/restrictions of imports for objectives set out in the TBT agreement
2017-02-20 Uganda: Port Bell Lake port South Africa In process View
Complaint: Verification Agencies (SGS) apply standards that are higher than International accepted standards requiring additional tests and certificates which is of high costs. Additional tests include tests for copper, iron, manganese, lead and coliforms which are expensive tests adding to the costs of doing business. The additional tests last for a week in addition to the export process. The Agency offers Route B or C product registration. Product meant for Kenya, Tanzania and Uganda are tested once a year Route C is a security factory audit for wine export to the abovementioned countries  
Progress: This matter was brought to the attention of the Uganda Focal Points along the margins of the 23rd EAC NTBs forum on 6 May 2017 . Uganda private sector Focal Point reported that consultations had been initiated with the Ministry of Trade , Industry and cooperatives to try and resolve the matter amicably. They will provide feedback in due course .  
NTB-000-725 2.6. Additional taxes and other charges 2016-11-01 Angola: Port of Luanda South Africa In process View
Complaint: Angola has Cumbersome and costly documentation and export/import requirements. The following is list of documentation required for a single consignment : i) 2x1 Original Bill of Landing; (ii)Original stamped and signed Commercial invoice; (iii) Original stamped and signed packing list; (iv) Analysis certificates if so required by consignee; (v) Loading Certificate (known as ARC or CNCA) PIP number prior to loading (required to do the pre-inspection) - not compulsory ; (vi) Voluntary pre-shipping control of merchandise (to be done at place of origin by inspector that issued the PIP number) Certificate of Origin( if so required by consignee) transport documents, full load container have to be sealed; (vii) letter from consignee nominating Orey as his forwarder agent; (viii) letter of responsibility from consignee to the carrier accepting full responsibility for demurrages and eventual container damages; (ix) copy of tax payer card of consignee; (x) Ministry of Commerce to issue license upon presentation of the commercial invoice; (xi) Ministry of Commerce to provide DU number, each invoice has different DU number.
The expected time frame is 72 hours (3 days) to get a DU number. CNCA certificate can only be issued upon presentation of the DU number for each specific shipment. Cost to produce DU number is 10 USD per invoice + Process DU (MINCO) FOB value 0.2%.

Costs
There is Fixed delivery and clearance rates in Luanda. Transport costs of 25% as from 15/1/2016, plus other additional chargers. Lab analysis costs 3000 USD per invoice. Analysis are mandatory to any imported edible goods, from water to beverages.

Delivery costs to Luanda per 20" + - 800 USD + 250 USD per night time delivery within city limits. overtime applies all the time due to restriction on delivery during the day due to traffic. Exporters are forced to pay incentives costs to EHO by OREY for DDP shipments. 20" => 150 USD if customs clearance handled by Orey, 40" => 170 USD if customs clearance handled by Orey.

Other fees charged are:
Shipment tracking & dispatch, BL Validation 160 per unit, Container deposit 1000 per unit
Delivery order 25 USD per unit. Port Tax 93.00 per unit, Wharfage 280.00 USD per unit, Tracking fee 100 USD per unit, Clearance transport and petties 350 USD per unit, delivery between Luanda /Soyo 3500.00 USD, return empty 400 USD per unit, transport between Luanda and Cabinda 11000.00 USD per unit, co-ordination 2.5% minimum USD 50.00. Consumption Tax of 5% service costs rendered in Angola. Taxes in all alcohol beverages is high 30% Cocktail 50% Ciders 51%

We believe this costs makes it difficult for investors to do business in Angola, most of them amount to tariff and non-tariff barriers we would like Regulators to review them.
 
Progress: During the 15th meeting of the SADC Sub Committee on Trade facilitation held in may 2017, the Secretariat requested Angola to submit names of its Focal points to enable processing of reported NTBs. Angola reported that : (i) based on their research, the documents are necessary and that these are part of universal documents required for import permit. (ii) South AFrica was also imposing more cumbersome procedures than Angola as evidenced by the fact that the documents she require are the same as those required by Angola therefore this does not constitute NTB.; (iii) the Ministry of Trade is the focal point and there is a national secretariat for SADC through which all SADC Affairs are channeled ; (iv) . Angola was working on establishing the Trade facilitation committee after which focal points will be appointed; (v) she was in the process of revising its commercial legislation that considers trimming the number of import/export documentation; (vi) The ministry would undertake consultations with Ministry of Transport to simply the procedures . 3. In response, South Africa reported that consultations will be made to find out the reasons for the complaint. South Reported that she does not require numerous documentation.  
NTB-000-720 2.3. Issues related to the rules of origin
Policy/Regulatory
2016-06-07 Sudan: Sudan Customs Authority Egypt In process View
Complaint: Sudan Customs authority has stopped applying the customs exemption on Egyptian Ceramic tiles products despite the fact that the consignments are accompanied by a COMESA certificate of origin .  
Progress: 1. During the 5th meeting of the COMESA NTBs Focal Points held in Nairobi from 23-25 August 2016 Sudan reported that it had established a committee comprising the relevant stakeholders to analyse the problem and inform the Minister within 30days. The matter will be presented to the next bilateral meeting between Egypt and Sudan scheduled in Cairo in October 2016. Further , COMESA Secretariat reported that communication had been sent to Sudan on this issue and Sudan undertook to respond to the communication from COMESA Secretariat once it is received.

2. During the 33rd Meeting of the COMESA Customs and Trade Committee, the Secretariat reported that response was being awaited to a follow up letter was sent to Sudan in September 2016.
 
NTB-000-718 8.8. Issues related to transit 2016-08-02 Mozambique: Beira Port Zambia In process View
Complaint: With reference to Resolved NTB-000-606, the matter is anything but resolved. We continue to experience attacks on our vehicles when using the Munhava Port Access. We have contacted numerous Security Companies in Beira to provide security for the vehicles, all have refused quoting the security situation. We have also been advised by other transporters that placing guards on the vehicles will only draw further action against the vehicles in an act of defiance/retribution. The Police do seem to be prepared to escort the vehicles, but we have no contacts nor tariffs charged. In the past week we have recorded 3 violent incidents.  
Progress: During the 15th meeting of the SADC Sub Committee on Trade facilitation, Mozambique reported that they noted the misbehavior by certain truck drivers sometimes they divert the trucks to inappropriate cites and are reported . Zambia has never reported those wrong doers and perpetrators. Mozambique requested Zambia to clarify the specific experiences. Zambia to provide feedback.  
NTB-000-689 8.6. Vehicle standards 2016-03-23 Botswana: All Border posts or entry points into Botswana by road In process View
Complaint: We have a problem in Botswana regarding the determination of Road User Charges at the border posts into Botswana.

The trailer manufacturers states the GVM to be 36 000 kg per unit (see attached vehicle registration papers)

This is the combined weight of the front and back link. However that is not what is reflected on the disc.

What it should say on the disc, is that the carrying capacity:

a) on the front link is 13000 kg.
b) The rear link is 23000kg.
c) The combined weight is thus 36 000kg.

We all know that it is not possible to carry 36000kgs on the front link and 36000kgs on the rear link. The axle configurations do not permit this to say the very least.

The problem arises on entry into Botswana at the border posts. They charge their road user fees per disc weight on the front and rear trailer.

therefore we end up paying for 36000kgs for the front trailer and 36000kgs for the rear trailer, this is 72 000kgs per unit.

To change the SA disc the following procedure will have to be followed.

1) W/bridge
2) Road worthy
3) Registration certificate
4) Certificate of compliance
5) Certificate model
6) Builders certificate
7) Ten days to change details of GVM per trailer.

a) It is very costly
b) it is very time consuming
c) it is not practical
d) It defeats the object of standardization and harmonization in the SADC region.

In this day and age where we are all trying to tighten our belts in order to survive, we can ill afford such additional costs.

This matter requires the urgent intervention of the focal point group in Botswana to address this matter urgently with the Roads Department in Gaborone, all relevant documentation pertaining to this case has been attached.
 
Progress: This issue was discussed during the Botswana / South Africa Bi-National Commission, which was held in Gaborone in November 2017. As per item 3.2.2.1 bullet point number one (1), the Republic of South Africa was to formerly request for a waiver from Botswana on the matter, while South Africa is still sorting out the system that causes the problem. Botswana is still awaiting correspondence from South Africa to that effect. We kindly advice the South African Focal Point to consult the Department of Transport in South Africa for further clarifications.  
NTB-000-676 2.3. Issues related to the rules of origin 2015-07-31 SADC Mauritius In process View
Complaint: The 2 stage transformation needed on clothing is too stringent as it stifles investment in manufacture of clothing due to economic reason and prices. Our company would want to invest in Bio organic fabrics. We invest in stock form India for knitted fabric jersey 100% but with this fabric we have issues to get the SADC certificate of origin as in the rules of origin it does not have 2 value added process. But we are a brand, we produce the garment here in Mauritius we do also the printing at our factory. Therefore there is two process, the cloth is cut here, and then printing.Please can our case be studied as we are a SME factory and for our survival we need to export to Africa. Can this case be study for the rules of origin be modified if the printing process is big part on the value of this product  
Progress: During the 15th meeting of the SADC Subcommittee on Trade facilitation, the Secretariat reported that work is underway to review the Rules of origin. This matter was on the agenda of the next meeting on rules of origin for consideration.  
NTB-000-670 8.6. Vehicle standards 2015-05-08 Tanzania: Tunduma South Africa In process View
Complaint: Despite the passing and acceptance of EAC Vehicle Overload Bill of 2012, whereby it states under the Fourth Schedule s.5 (1) (c) - VEHICLE DIMENSIONS, AXLE LOAD CONFIGURATIONS AND VEHICLE COMBINATIONS, that the maximum vehicle combination length permissible is 22 m and which includes and covers the South African designed and developed Interlink combination of 22 m maximum. Tanzania are still insisting on abnormal vehicle permits to be issued to these vehicles on entry into Tanzania at Tunduma Border Post at a cost of US $20 per entry or face heavy penalties including the impounding of vehicles if they are not in posesion of an abnormal permit.

This is in breach of the Bill which has been accepted by all EAC Member Countries including Tanzania and this policy needs to be revoked ASAP.
 
Progress: Awaiting feedback from Focal Points  
NTB-000-662 8.8. Issues related to transit 2015-02-19 Mozambique: Weighbridge at Matola on the Maputo corridor Zimbabwe In process View
Complaint: Zimbabwean truck drivers are now facing police harassment near the weighbridge at Matola on the Maputo corridor. The police are taking Zimbabwe drivers licence and their passports, supposedly to check the authentication of the driver holding the documents. The driver is released in order to go and off load and is briefed that the police will have an answer for him on his return.

On his return driver is told that the licence is a fake and the driver is to pay a spot fine of ZAR5000.00. It appears that the police are rubbing the metal disc with something, so that certain information is now very faded, and not legible. When the driver produces his international drivers’ licence, to confirm the validity that is taken away by police, who only return it after some hours, with the expiry date is now illegible. The ZAR 5000.00 rand fine is enforced. The language is a convenient barrier, as the police claim not to be able to speak English. All fines in Mozambique seem to be ZAR 5000.00.

Drivers are detained for days until they come up with some sort of cash ranging from ZAR400.00 upwards if they are lucky. This problem is more prevalent during weekends.

Please can we have a stop put to this practice? Defacing a Government document I believe is an offence, and should not be tolerated. Business is challenging enough as it is, without trade barriers being further forced upon the transport industry.
 
Progress: During the 15th meeting of the SADC Sub Committee held in May 2017, the Secretariat reported that the SCCC made general observations on similar issues where receipts are not issued. SCCC recommended that border authorities should put measures in place such as hidden cameras etc to identify culprits. Member States will report on progress regarding the recommendation.  
NTB-000-657 5.15. Other
Policy/Regulatory
2014-12-11 Tanzania: Various State Agencies EAC In process View
Complaint: Numerous monetary charges required by various agencies in the United Republic of Tanzania on exports of dairy products  
Progress: 1. At the 16th EAC NTBs Forum held in Kigali, noted that the SCTIFI urged Partner States to forward charges on dairy products to the EAC Secretariat in order to work modalities to harmonize them. The Secretariat informed the meeting that it was only the Republic of Kenya and Rwanda who had submitted their charges. The meeting recommended the other Partner States to submit their charges by 31st December, 2014. The time frame for addressing this issue is June 2015.
2. At the 26th Regional Monitoring Committee meeting, the Secretariat reported that they had sent a letter to Partner States to submit the additional charges for harmonization
 
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