| Complaint number |
NTB Type
|
Date of incident |
Location |
Reporting country or region (additional) |
Status |
Actions |
|
NTB-000-982 |
1.4. Preference given to domestic bidders/suppliers |
2020-08-24 |
Botswana: Ministry of Trade and Industry |
Zimbabwe |
In process |
View |
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Complaint:
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On 24 August 2020, Botswana’s Ministry of Investment, Trade and Industry released a statement that the country would be restricting the importation of baked goods. This will affect products such as pastries, cookies, muffins and other products derived from some form of grain.
The statement was supported by S.I 102 of 2020. The Botswana’s Ministry of Investment, Trade and Industry highlighted that the move is meant to protect the domestic producers. |
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Progress:
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1. On 3 February 2026, Botswana Focal Point reported that the Ministry shared the relevant Statutory Instrument (SI), and request Zimbabwe to advise on the specific challenges being experienced to enable Botswana to initiate engagements with a view to resolving the NTB.
The Control of Goods, Prices and Other Charges (Restriction on the Importation of Baked Goods) Regulations, 2020 applies to the importation of baked goods such as: Bread, pies, pastries, rolls, cookies, muffins, cakes, cupcakes, and similar baked products.
Where a Zimbabwean company exports any of these products to Botswana, the regulation becomes applicable. In such cases, the import permit application must be submitted by the importer (the Botswana buyer), rather than the Zimbabwean exporter. Applications can be processed through the Ministry of Trade and Entrepreneurship in Botswana.
The Zimbabwean exporting company is expected to support its Botswana customer by providing the necessary documentation, including:
Product details; Invoice; Quantity information and Shipping documents
To facilitate further engagements, Botswana requests an update from Zimbabwe on how this Statutory Instrument has affected trade flows between Botswana and Zimbabwe since it was introduced in 2020. |
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NTB-001-312 |
5.10. Prohibitions |
2021-12-01 |
Zimbabwe: Kariba |
Zambia |
In process |
View |
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Complaint:
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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-000-820 |
4. Sanitary & phyto-sanitary (SPS) measures
A12: Geographical restrictions on eligibility
Policy/Regulatory |
2010-12-01 |
Zambia: Ministry of Agriculture and Livestock |
Kenya |
In process |
View |
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Complaint:
|
Brookside Dairy Ltd of Kenya, exports of UHT milk are denied entry into Zambia for reasons that, an inspection audit of the source of milk, export facility, milk product and relevant standards in use in Kenya by the Zambian authorities raised sanitary concerns pointing out that Zambia cannot accept milk products from the raw milk that did not meet the Zambian milk standard. The Zambian standard on raw milk for use in production of milk products is a maximum of 200,000 colon forming units (cfu) whereas Kenya legislation allows for a maximum of 2, 000,000 cfu in raw milk used in making UHT milk, which is above the 200,000 cfu allowed in Zambia. Kenya applies the EAC graded standards which allow for a maximum of 2,000,000 cfu and a minimum of 200,000 cfu and below for raw milk. |
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Progress:
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1. Various bilateral meetings and technical audits have been undertaken between the two countries in an attempt to resolve the NTB. The thirty-Third Meeting of the COMESA Trade and Customs Committee held on 15-17 September 2017 recommended that :
i) COMESA should harmonize SPS measures through implementation of the COMESA Green Pass (CGP) to facilitate trade in agricultural products.
ii) Member States should adhere to the NTB resolution time frames set out in the COMESA Regulations on Elimination of NTBs to ensure timely resolution of NTBs and enhance intra-regional trade.
2. In August 2019 Zambia Focal point reported that Zambia and Kenya held a bilateral meeting during the 5th TFTA focal points meeting held in Nairobi in August, 2019 during which Zambia proposed to have the complaint removed from the online platform in view of the fact that the issue was now in the hands of COMESA Secretariat who are expected to facilitate the harmonisation of the SPS standards. However, Kenya was still of the view that the complaint be maintained on the platform. Zambia therefore sought the guidance of COMESA Secretariat whether it is in order to maintain an issue which has been determined to be a legitimate SPS requirement following a recommendation for COMESA Secretariat to facilitate the harmonization SPS standards.
3. On 30 July 2021, COMESA NTB Unit requested Kenya to provide progress on the request to furnish Zambia with testing methods as agreed during the 1st meeting of the COMESA NTB Forum in March, 2021.
4. The 3rd meeting of the COMESA Regional NTBs Forum held on 20- 22 September 2023 thatBoth countries to undertake verification missions between 27th – 30th November 2023. The Secretariat will provide support to Member States to undertake the activity
5. During the NTBs workshop, 17 – 19 April 2024 in Nairobi both countries agreed on the bilateral meeting for market access to increase trade between the two countries rather than focusing on this product.
6. On 17th June 2025, the two Member States convened a bilateral meeting where both Member States agreed that there was a need for a technical review of the documentation (Standards, audit and other reports) that had been prepared towards resolution of the NTB to inform the way forward on the resolution.
i. Kenya and Zambia to provide information on their milk standards for the review by the Technical Committee to prepare a concept note for the next bilateral meeting by August 2025..
ii. Secretariat to share reports and documents that can help with the resolution of the milk NTB including records of initiatives undertaken to resolve the issue in the past by August 2025.
iii. Both Member States to submit names of experts to be members of the Technical Committee to develop a technical brief for consideration by the next bilateral meeting by August 2025.
iv. Technical Working Group to examine the provisions on the conformity requirements in the standards for raw milk and UHT (finished product) and make recommendations to the next bilateral meeting, by September 2025. |
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NTB-000-742 |
3. Technical barriers to trade (TBT)
B1: Import authorization/licensing related to technical barriers to trade |
2017-02-20 |
Uganda: Port Bell Lake port |
South Africa |
In process |
View |
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Complaint:
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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 |
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Progress:
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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 . |
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NTB-000-818 |
3. Technical barriers to trade (TBT)
B42: TBT regulations on transport and storage |
2018-05-17 |
Botswana: Ministry of Transport |
South Africa |
In process |
View |
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Complaint:
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Failure to implement Article 5.8 (6.2 Road Traffic Policy) leading to variable treatment of the transport of High Cube containers with height exceeding 4.3 metres.
The transport of High Cube Containers, on “standard” deck height (1.5 metres) vehicles and trailers results in overall height of approximately 4.5 metres.
Botswana: Imposes requirement for abnormal load permits for each load.
South Africa threatens to repeal moratorium on prosecution from 1 Jan 2019
Other countries ignoring “illegal” height, but “illegality” leaves insurance threats to operators.
Zambia (4.8), Zimbabwe 4.65), Malawi (4.6); Tanzania (4.6) have increased legal height to at least 4.6 metres.
Uncertainty in region is causing growing concerns regarding viability of international transport routes amid fears of further enforcement costs and barriers. |
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Progress:
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The Meeting of NTB-Market Access Task Force 18-20 March 2020 in Gaborone reported that MCBRTA standards agreed at the TSMCI of 31 October 2029 maximum vehicle height of 4.6m which will resolve this NTBs if South Africa complies with this standard. |
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NTB-001-048 |
3. Technical barriers to trade (TBT)
B31: Labelling requirements |
2022-01-03 |
Tanzania: Standards Authority |
South Africa |
New |
View |
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Complaint:
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Vague Labelling requirement "Statutory Warning" Clause 12 (k), rejection of the UK Chief Medical Warning which is accepted in other African countries such as Uganda, Kenya without any objection in addition to their requirement. |
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Progress:
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The stakeholder consultative meeting organized by the SADC Business Council which was attended by the concerned parties from South Africa and Tanzania and SADC Secretariat on 7 march 2022, agreed that the UK Chief Medical Officers Guidelines labelling should be retained (The UK Chief Medical Officers recommend adult do not regularly drink more than 14 units per week) provided that the Wine producer affixes an additional sticker which covers all missing information on the product package.
The additional sticker (label) should be legibly and indelibly marked.
The additional sticker should be submitted to the Tanzania Bureau of Standards for approval accompanied by the declaration letter from the Manufacturer stating that additional label originating from them and products imported in Tanzania will be labelled as such. |
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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 |
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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. |
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NTB-001-193 |
3. Technical barriers to trade (TBT)
B14: Authorization requirements for importing certain products |
2023-12-10 |
Botswana: Instructions provided to the Rwanda's commercial agent based in Botswana |
Rwanda |
New |
View |
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Complaint:
|
Requirement by Botswana authority in charge of food imports that Rwanda needs to provide a " Free Sale certificate" prior to exporting coffee to Botswana. The issue is that such certificate is not required in 20 countries where Rwanda is exporting coffee globally. In addition, there is no institution in Rwanda that issues such certification. |
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Products:
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0901: Coffee, whether or not roasted or decaffeinated; coffee husks and skins; coffee substitutes containing coffee in any proportion. |
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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 |
COMESA |
New |
View |
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Complaint:
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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-001-106 |
6.5. Variable levies |
2022-07-05 |
Zimbabwe: Zimbabwe Revenue Authority |
Zambia |
New |
View |
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Complaint:
|
Zambia exports into Zimbabwe on beverages attracts additional duty of $ 0.05/Litre.Lengthy Compliance processes, Multiple agency approvals and complex certification requirements further discourage sincere exporters as these layers increase the product turnaround time and further increase RTM cost and delivery time.
For example: - COC, Inspection, Route plan B, Importer licenses & various agency registrations (Multiple window clearance, COMESA certificate) |
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Progress:
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1. During the NTBs workshop 17th - 19th April 2024, NFPs for the two countries agreed to hold a virtual bilateral meeting in April to discuss NTBs affecting both counties and this issue will form part of the Agenda.
2. On 17 April 2024, Malawi Focal Point reported that they were following up with the agencies involved in this issue to resolve the NTBs and gave assurance the this issue was being discussed at length and feedback on the outcomes of the consultations would be provided as soon as possible.
3. During the 10th Meeting of the TTFSC held on 2 – 4 July 2025, Zimbabwe updated the meeting that national consultations and engagements with Zambia towards the resolution of the outstanding NTBs were ongoing. Zambia confirmed the engagement with Zimbabwe and the Secretariat will be updated on the outcomes from the consultations. |
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NTB-001-242 |
6.5. Variable levies |
2024-12-27 |
Kenya: Ministry of Finance |
Tanzania |
In process |
View |
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Complaint:
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Through, the Tax Laws (Amendment) Act, 2024 of Kenya passed on 11 December 2024 and came into force on 27 December 2024, the Government of Kenya, among other things, introduced excise duty on various products such as marble, transformers, float glass, coal imported from outside Kenya including East African Community countries. Also, has increased the valuation rates in calculating tax on tiles when they are sold in the country. These challenges have affected production due to the decline in the market for the products in Kenya caused by competition after the prices of the products in question became high |
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Progress:
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1.On excise duty charged on originating goods from Tanzania, Kenya was urged to refrain from enacting discriminatory laws that treat EAC originating goods as imports. The RMC was informed by Kenya that, through the Supplementary Legal Notice, excise duty was removed from Glass and Transformer. Kenya provided the supplementary gazette removing the two products.
(b) On valuation rates on tiles from Tanzania and Uganda when they are sold in the country as per the complaint from Tanzania below, entries as evidence on valuation adjustments examined showed adjustments as noted in the Internal KRA Memo on valuation for tiles from Uganda & Tanzania. The meeting noted that valuation of goods is administrative and operational, hence the valuation matter be referred to the Sectoral Committee on Customs for Commissioners (SCOC) to consider and resolve. The EAC guided that Valuation in EAC is guided by Section 122 and Fourth Schedule of the EAC CMA.
2. The 38th RMC meeting referred the NTB on valuation to SCOC for consideration and resolution and report back to the next RMC
3.The 39th RMC noted that transformers, float glass, coal had been granted preferential treatment. |
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NTB-001-244 |
6.5. Variable levies |
2020-10-13 |
Uganda: URA |
Kenya |
In process |
View |
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Complaint:
|
Uganda is subjecting Kenya manufacture furniture to discriminative excise duty of 20% that it is not subjected to Uganda manufactured furniture.
Uganda is requested to remove the discriminative excise taxes on Kenya furniture transferred to Uganda as it is prohibited in the EAC Customs Union Protocol; Articles 1 and 75 (6) of the Treaty as well as Articles 15 (1) (a) and (2) of the Customs Union Protocol on National Treatment, and Article 6 (1) of the Common Market Protocol of the Community Laws.
The charges are also in violation of Article 10 of the Custom Union Protocol that obligates Partner States to remove all internal tariffs and other charges of equivalent effect. |
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Progress:
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During 39th RMC, noted that the matter is under bilateral discussions and will be handled as per the agreement. |
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NTB-000-530 |
8.6. Vehicle standards
Policy/Regulatory |
2012-09-10 |
Zambia: Zambia Bureau of Standards |
South Africa |
In process |
View |
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Complaint:
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This complaint is registered by FESARTA.
Zambia is requiring all foreign tankers either delivering product to Zambia, or transiting Zambia, to comply with its Standards 371:2008 and 429-4:2008.
Furthermore, it is charging transporters to obtain a permit to certify that the tankers comply with the Standards. This requirement is affecting the free flow of goods into Zambia.
Zambia is requested to recognise the foreign vehicles national certificates of roadworthiness as it is difficult for Transporters operating tankers into Zambia to alter the design of their tankers at short notice.This is against the objectives of trade facilitation, will create monopolies and increase the cost of transport. |
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Progress:
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1. On 25 January 2018, Zambia Focal Point advised that the Zambia Bureau of Standards had taken into account the concerns raised. The standard (ZS 371:2008) is currently under revision to address concerns among other matters.
The matter had also been tabled under SADC in an effort to harmonize the standard in the region
2. During the 15th SADC Sub Committee on Trade facilitation held in May 2017, Zambia reported that this NTB had been resolved. However, South Africa Focal Point undertook to verify with complainant and provide feed back on the status.
3. The Meeting of NTB-Market Access Task Force 18-20 March 2020 reported that through SADCSTAN and Tripartite Transit Transport Facilitation Programme had recently agreed on the standard on transportation of dangerous goods which covers fuel tanks that will resolve this matter. |
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NTB-000-670 |
8.6. Vehicle standards |
2015-05-08 |
Tanzania: Tunduma |
South Africa |
In process |
View |
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Complaint:
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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. |
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Progress:
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Awaiting feedback from Focal Points |
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NTB-000-689 |
8.6. Vehicle standards |
2016-03-23 |
Botswana: All Border posts or entry points into Botswana by road |
South Africa |
In process |
View |
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Complaint:
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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. |
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Progress:
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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. |
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