| Complaint number |
NTB Type
|
Date of incident |
Location |
Reporting country or region (additional) |
Status |
Actions |
|
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-001-309 |
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. |
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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. |
|
|
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-001-311 |
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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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-001-329 |
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:
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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. |
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|
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. |
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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-001-333 |
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-001-342 |
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 |
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NTB-001-345 |
|
2025-06-26 |
Djibouti: Djibouti sea port |
Ethiopia |
New |
View |
|
Complaint:
|
A procedural inconsistency exists in the handling of export shipments from Ethiopia to the Djibouti Free Zone, whereby the acceptance of tarpaulin-covered trucks is applied inconsistently in comparison to containerized cargo. In practice, some shipments transported in tarpaulin-covered trucks are permitted entry into the Free Zone, while others are denied access and required to be containerized without clear justification or prior notice. This inconsistent enforcement creates uncertainty among traders and transport operators, leading to delays, additional handling and transportation costs, and operational inefficiencies.
As a result, exporters particularly small-scale traders face difficulties in planning their logistics and complying with requirements, which ultimately reduces their competitiveness and limits smooth market access along the corridor. |
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NTB-001-347 |
|
2026-03-17 |
Zimbabwe: |
Zambia |
New |
View |
|
Complaint:
|
Informal traders carrying small quantities of goods, such as fresh produce, cooking oil, rice, sugar and pasta.
These traders cross the Victoria Falls border post by bike or foot.
The complaint concerns over 50 traders per day, crossing the border.
When entering Zimbabwe, they get stopped by Customs and will face seemingly arbitrary restrictions on quantities of goods that can enters (which change on a daily basis and depending on the specific officer on duty). When these arbitrary quantities are exceeded, the officers often confiscate all of the goods or demand bribes to release the traders. They also face threats when questioning the behaviour of the officer.
When returning after selling goods on the market in Zimbabwe, and after clearing the Zimbabwe Customs, they will often get stopped by police or soldiers in the no-mans-land between the borders to be demanded further bribes from the proceeds of their sales.
If bringing merchandise from Zimbabwe back to Zambia, depending on the officers at the border and despite the small quantities carried, they will be asked to obtain an export license from Harare. Or to pay another bribe to be released. |
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NTB-001-348 |
1.5. Requirement for counter trade |
2025-11-23 |
Democratic Republic of the Congo: Office de Gestion du Fret Multimodal (OGEFREM) |
Uganda |
New |
View |
|
Complaint:
|
The Government of the Democratic Republic of the Congo, through the Office de Gestion du Fret Multimodal (OGEFREM), introduced an additional requirement mandating the acquisition of the OGEFREM Certificate. OGEFREM (Office de Gestion du Fret Multimodal) is a real DRC agency involved in port/freight management and levies.This measure constitutes a Non-Tariff Barrier (NTB), particularly given that it’s paid for both in Uganda and DRC for the same product; apart from livestock, the fees aren’t standardised, and it’s not clear what value It adds. It constrains cross-border trade and undermines the principles and objectives of the East African Community (EAC) agreement, which promotes free movement of goods and regional integration.
Furthermore, this whole process creates delays and extra costs for cross‑border trade.
Traders have therefore proposed that the requirement to have an OGEFREM certificate be removed, and to the least have the cost of the OGEFREM Certificate be standardized and reduced. They note that small-scale traders are disproportionately affected, as they are often subjected to varying and elevated fees for the certificate, in addition to paying further OGEFREM-related charges that aren’t documented upon entry into the DRC. |
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NTB-001-350 |
1.7. Discriminatory or flawed government procurement policies |
2026-02-02 |
Rwanda: RRA |
Kenya |
New |
View |
|
Complaint:
|
Introduction of discriminative excise duties of 35% by Rwanda to Kenya confectionary, not subjected to local manufacturers in Rwanda. |
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|
NTB-001-351 |
1.7. Discriminatory or flawed government procurement policies |
2025-07-15 |
Tanzania: TRA |
Kenya |
New |
View |
|
Complaint:
|
Tanza Tanzania discriminatory treatment of IndustIndustrial Development Levy of 10% on metal and metal products. The same is not being subjected to Tanzania local manufacturers |
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NTB-001-353 |
5.14. Restrictive licenses |
2026-04-10 |
Rwanda: Rwanda FDA |
Kenya |
New |
View |
|
Complaint:
|
wanda FDA is subjecting Kenya products to costly charges for re-testing and registration of the products despite the products being certified by the Kenya bureau of standards with valid standardization mark.
The two products include ace pine fresh and ace citrus fresh liquid toilet cleaners. Rwanda FDA informed that the certifications for the two products had been revoked on the basis that they allegedly contained Nonyl Phenol despite successfully applying for and receiving product registrations from Rwanda FDA under certificates Rwanda FDA‑ADP‑MA‑0070 and Rwanda FDA‑ADP‑MA‑0072. Further the manufacturer confirmed they not using Nonyl Phenol
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NTB-001-356 |
1.14. Lack of coordination between government institutions |
2026-04-15 |
Zimbabwe: Robert Gabriel Mugabe International Airport |
COMESA |
New |
View |
|
Complaint:
|
Zimbabwe's on line COMESA system has been down since September last year. This has resulted in exporters facing some challenges in producing online COMESA certificates. We did a shipment to Tunisia and had to fill in a new COMESA certificate on a PDF format printed from the computer. This resulted in Tunisian customs rejecting this document claiming that it doesn't have a serial number, therefore its not authentic, even though it was stamped and signed by ZIM customs (ZIMRA). We notified our authorities of the ordeal, and they confirmed that the system was still being rectified. To bail out the situation ZIMRA confirmed that it would contact the Tunisian customs and clarify the prevailing issue currently in Zimbabwe with regards to the on line COMESA certificates. Our market in Tunisia is still facing some clearance problems cause of this incident. We understand that Tunisian customs, wants to resend back the shipment to Zimbabwe at our cost as the shipper. We hereby seek your intervention with regards to this matter. We are dealing with Horticultural fresh and dried produce. Tunisia has proved to be a reliable market, considering the COMESA trade agreements and both countries being member states. We look forward to your earliest response towards in solving our issue. Currently our client is exposed to USD500.00 storage fees per day. |
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Products:
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0802.90: Nuts, fresh or dried, whether or not shelled or peeled (excl. coconuts, Brazil nuts, cashew nuts, almonds, hazelnuts, filberts, walnuts, chestnuts, pistachios, macadamia nuts, kola nuts and areca nuts) |
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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-001-358 |
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-001-359 |
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-001-360 |
2.4. Import licensing |
2026-03-01 |
South Sudan: Nimule |
Uganda |
New |
View |
|
Complaint:
|
The implementation of electronic permits (e-permits) and related electronic cargo tracking for goods entering South Sudan from Uganda has led to significant delyas and costs to traders eg Over 1,000 trucks are currently stranded at the Nimule border due to challenges with the e-permit system such as additional charges, and slow processing. On the same issue,there are complaints of Extortion.Truck drivers have reported that some officials refuse electronic payments and instead demand cash, leading to corruption and higher, unofficial fees. |
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NTB-001-361 |
|
2026-01-14 |
Ethiopia: Dilla Customs Office |
Ethiopia |
New |
View |
|
Complaint:
|
The Dilla Customs Office has repeatedly delayed the clearance of export goods destined for the Moyale Border for extended periods, despite all required documents and formalities having been duly completed. These products were issued permits with specific validity periods, yet the delays persist, causing unnecessary disruptions. This issue has occurred several times at the same government institution. |
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