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Pre-shipment inspection for certain goods exported to Zimbabwe – adding to the cost of doing business


Pre-shipment inspection for certain goods exported to Zimbabwe – adding to the cost of doing business

Willemien Viljoen, tralac Researcher, discusses the implications of the recently re-launched Consignment Based Conformity Assessment and Valuation Programme (CBCA) for exporters looking to sell goods to Zimbabwe

Exports to Zimbabwe have just become more costly. This, after the Zimbabwean Ministry of Industry and Commerce re-launched the Consignment Based Conformity Assessment and Valuation Programme (CBCA). This programme was the cause of confusion and uncertainty when initially launched at the beginning of March this year – it was set to be fully operational from 16 May (after a 2 month transitional period) but shortly after the deadline the Ministry retracted the programme due to ‘outstanding administrative and technical issues’ and ‘issues that arose during the awareness campaigns.’ After the postponement was announced exporters hoped for the cancellation of the CBCA due to the time-consuming and costly nature of these pre-shipment inspections. However, the relief was short lived as importers received notice on 20 July that the CBCA will be implemented from 27 July, with a transitional period running until 31 October and full implementation taking place from 1 November. During the transitional period non-compliant goods will not be issued with a certificate of compliance, but a note indicating the corrective measures which need to be taken for compliance. However, these non-compliant goods will not be refused entry into the Zimbabwean market until full implementation in November.

The aim of the CBCA is to ensure the importation of hazardous and substandard products is reduced and customs duty collection is improved. The CBCA entails a pre-shipment inspection which needs to take place in the exporting country, prior to shipment. These inspections will be completed by a third party, Bureau Veritas for the next four years until such a time that the Zimbabwe Quality Standards Regulatory Authority has been established. The CBCA will increase the cost of exports as the general fee applicable for the service is 0.7 percent of the Free on Board value of the consignment, with a minimum and maximum fee of US$ 350 and US$ 7500 per consignment, respectively. Inspections will also add to the lag time between consignments. Based on countries’ experiences with pre-shipment inspections required for Kenya, Tanzania, Mozambique, Uganda, Togo, Egypt and Ivory Coast these inspections add between 3 to 7 days to the export process.

The list of goods subject to inspections (and quality testing if deemed necessary) is extensive. It includes approximately 137 products at the HS4 level in 41 HS Chapters, including food and agricultural products, building materials, wood and wood products, clothing and textiles and transport equipment.

  • In 2014 the countries which were the main exporters of the products now CBCA listed were Singapore (39.76% of all CBCA listed products imported into Zimbabwe), South Africa (29.23%), China (5.04%), United Kingdom (4.66%) and Japan (3.52%).

  • Apart from South Africa, other countries in the region which fall under the top ten exporters of the CBCA listed products are Mozambique (1.89%), Zambia (1.69%) and Botswana (1.43%).

  • Based on the CBCA listed products that each country exports to Zimbabwe as a percentage of their total Zimbabwean exports, the countries that will be adversely affected by the increase cost of the CBCA include Singapore (99.62% of exports are CBCA listed products), Switzerland (81.11%), Egypt (70.8%), Japan (66.55%) and the United Kingdom (65.37%).

  • Other African countries whose total exports to Zimbabwe include a significant share of the CBCA listed products include Uganda (65.04% of all exports are CBCA listed), Kenya (47.12%), Nigeria (44.72%), Mauritius (38.83%) and Mozambique (37.29%).

  • 31.27 percent of all South Africa’s exports to Zimbabwe are CBCA listed products, mainly fertilizers (HS 3102 and 3105), other petroleum oils and preparations (HS 271019), organic surface-active detergents (HS 3402), soap (HS 3402) and non-alcoholic beverages (HS 2202).

Pre-shipment inspections are allowable under the World Trade Organization (WTO), as long as the requirements in the WTO Agreement on Pre-shipment Inspections are met – non-discrimination, transparency and review and appeals processes. These inspections were also deemed necessary to fulfil a precise purpose; ensuring that the quality and customs valuation of goods are in line with the domestic regulations of the importing country. Due to the cost and time constraints associated with these inspections, increased awareness and utilisation of internationally accepted standards, harmonisation, mutual recognition and equivalence of standards and the acceptance of the multilateral rules on customs valuation the popularity of these inspections has been on the wane; especially in developed countries. However, it seems that African countries are increasingly reverting to pre-shipment inspections to guard their consumers and domestic producers at great cost for exporters. This tendency seems to be directly related to capacity constraints relating to domestic standards and standard authorities and the lack of implementation of internationally accepted standards in the majority of African countries.



WTO (https://www.wto.org/english/tratop_e/preship_e/preship_e.htm);

Freight and Trading Weekly (http://www.ftwonline.co.za/FTWeditions/2015/2157-3July2015/index.html);

TradeMap (www.trademap.org);

Delmas (http://www.delmas.com/);

Bureau Veritas (http://www.bureauveritas.com/)


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